Who we are
Spartacus Sports inc. its subsidiaries ("Desiren", "we", "us", "our") respect your privacy and we are committed to protecting the personal data we process about you. Desiren is a social network which enables: (i) "Creators" to share and monetise their own content (as well as subscribe to, and view, the content of other Creators); and (ii) "Fans" to subscribe to, and view, the content of Creators.
About this Policy
This privacy policy ("Policy") explains our practices with respect to the personal data we process about our Creators and Fans. Some parts of the Policy are specifically aimed at Creators, and some parts are specifically aimed at Fans. It also applies to how we process the personal data of individuals that feature in content uploaded by a Creator ("Content Collaborators"), and where we process personal data about you in the context of our business relationships.
We process your personal data when you use our website located at www.desiren.me ("Website") and for the provision of the services that we offer from time to time via our Website. We also process your personal data when you interact with us through our social media pages on third-party websites (e.g. Twitter and Instagram), or otherwise. We refer to these activities collectively as the "Services" in this Policy.
We are a "data controller" of the personal data that we process in connection with the Services. This means that we decide the reasons why we process personal data about you and how we do so.
Please review this Policy to understand how we process your personal data in connection with the Services. By using our Services, you acknowledge that you have read and understand the information in this Policy.
If you have any questions about this Policy or our processing of your personal data, please see Section 19 (assistance and contact information) for information about how to contact us.
What is personal data?
"Personal data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.
In addition, we may collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as deidentified, aggregated or anonymised information. This type of data is not personal data and our use of such data is not subject to this Policy.
Informing us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any point during your relationship with us. Updates or corrections can be made through your account settings on our Website.
Applicability of this Policy (18+)
This Policy is provided in addition to, but does not form part of, our Terms of Service(which includes our Acceptable Use Policy) that govern your use of our Website and the Services.
Our Services are strictly intended for individuals 18 years of age or older. Anyone under 18 years of age is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.
Third-party links
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you.
We are not responsible for, and this Policy does not apply to, the content, security or privacy practices of those other websites, plug-ins or applications. We encourage you to view the privacy and cookie policies / notices of those third parties to find out how your personal data may be used.
If you do not wish to provide personal data
We need to collect certain personal data from you in order to provide you with access to the Services or specific features and functionalities of the Services in accordance with our contract with you (i.e. our Terms of Service). We are also required to process certain personal data in accordance with applicable laws. Please note that if you do not wish to provide personal data where requested, we may not be able to provide you with access to the Services or specific features and functionalities of the Services.
Updates to this Policy
We may update this Policy from time to time, and any updates will be effective upon our posting of the revised Policy on our Website. We will use reasonable efforts to notify you in the event that material updates are made to this Policy, such as sending you a feed notification or a chat message via your account on our Website.
Categories of personal data
We process, or our third-party providers process on our behalf, different kinds of personal data about Creators and Fans, which we have grouped together as follows:
- full name*
- alias, if applicable
- residential address
- country of residence*
- email address
- telephone number
- a copy of the government identity document that you provide to us*
- a "selfie" of you holding your government identity document*
- third-party social media handle / personal website address (used to further verify your age and identity and to help us better understand the content which you are likely to share on our Website)
- signature on release forms if you feature in another Creator's content*
Please note: Items marked with * will be requested for Content Collaborators that are not existing Creators on the Website, via a release form.
Fans
- email address
- telephone number
Creators
- a copy of the government identity document that you provide to our third-party providers
- a short .gif, taken from a “selfie” that you provide to our third-party providers
- the results of the third-party age and identity verification process (pass / fail and reason for failing)
- metadata associated with the third-party age and identity verification process (e.g. start and finish time)
Fans
- for locations where we conduct third-party age and identity verification of Fans, a copy of the government identity document that you provide to our third-party providers
- for locations where we carry out third-party age estimation, or third-party age and identity verification of Fans, a short .gif, taken from a "selfie" that you provide to our third-party providers
- the results of the third-party age estimation process or third-party age and identity verification process (pass / fail and reason for failing)
- metadata associated with the third-party age estimation process or third-party age and identity verification process (e.g. user start and finish time)
Please see Section 10 (our onboarding processes), below, for further information. Third-Party Onboarding Data and Technical Data does not include Face Recognition Data, as set out below.
- profile name
- password
- avatars and headers of your Creator account
- your subscriptions, subscribers and referrals
- posts that you have made to your Creator account
- comments on posts made from your Creator account
- chat messages between you and other users
- customer support queries that you submit to us
Fans
- profile name
- password
- avatars and headers of your Fan account
- your subscriptions
- comments on posts made from your Fan account
- chat messages between you and other users
- customer support queries that you submit to us
- payment card details*
- billing address
- funds added to your wallet
- bank account information
- pay-out country
- corporate or business entity if registered for tax purposes
- social security number (for US Creators only) or other relevant tax information
- W-9 form (for US Creators only)
- 1099-MISC form (for US Creators only)
- 1099-NEC form (for US Creators only)
Fans
- payment card details*
- billing address
- funds added to your wallet
Please note: Any payments made to view the content of Creators are processed by our third-party payment providers. We do not receive your full payment card number, payment card expiration date, or the security code. Instead, the payment provider provides us with a "token" that represents your account, your payment card's expiration date, payment card type and the first six and last four digits of your payment card number.
- earnings
- pay-out requests
- payments made to your Creator account
- payments made from your Creator account to other Creators
- any failed payments
Fans
- payments made from your Fan account to Creators
- any failed payments
Internet or other electronic network activity information, including:
- internet protocol (IP) address (and associated location data)
- Internet Service Provider (ISP)
- device and type
- name and version of browser
We use cookies where necessary (to allow you to browse the Services and access certain pages of the Website) and, with your consent we will use cookies:
- for performance on the Website (e.g. to analyse how users interact with the Website to improve the Services and, where you are a Creator, so that we can recognise that you have referred another Creator through your unique referral code)
- for Website functionality (e.g. saving your logged-in status)
More information on our use of cookies, including how to delete or block cookies, can be found in our Cookie Notice. In some cases, data collected from cookies will be in a deidentified, aggregated or anonymised format.
We currently do not use any cross-site tracking technologies and we do not sell personal data collected about you, or share personal data collected about you for cross-context behavioural advertising.
- As described in more detail below in Section 10 (our onboarding processes), during onboarding, our third-party providers may use face recognition technology, so they can digitally verify you.
- The Face Recognition Data remains with our third-party provider and we do not ourselves collect, receive, possess, or have access to Face Recognition Data at any time.
Our onboarding processes - Creators
We have processes in place that are intended to ensure that all Creators on the Website: (i) are at least 18 years of age; and (ii) verify their identity. Before you can start a Creator account, we will:
- Ask you to provide Creator User Data, as set out at Section 9 (categories of personal data).
- Check your country of residence. This check is intended to ensure lawful access to the Website and the Services.
- Ask you to provide Financial Data, as set out at Section 9 (categories of personal data). This is necessary so that payments can be made to Creators for content, and so that Creators can access their earnings via the Website. Financial Data is also collected as a verification and anti-fraud measure.
- Ask you to go through a third-party age and identity verification process:some text
- This process involves our third-party provider collecting a short .gif, taken from a "selfie" and photo from a government identity document (in both cases, that you provide to the third-party provider). The third-party provider then uses Face Recognition Data to match the two images so they can digitally verify your age and identity.
- As described at Section 9 (categories of personal data), we do not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.
- Where permitted by applicable law, we receive from our third-party providers Third-Party Onboarding Data, and certain Technical Data, as set out at Section 9 (categories of personal data), to maintain a record of the age and identity verification process.
- Check that you have not previously been banned from using the Website and our Services (e.g. as a result of violating our Terms of Service).