Privacy Policy

Information you provide directly:

• Account registration details: name, email address, password.
• Profile information: display name, bio, profile picture, cover image.
• Payment information: we do not store raw card details — payments are processed by our PCI-compliant payment processor (Stripe). We store transaction records and the last 4 digits of bank accounts for payout purposes.
• Identity verification documents (for age/KYC verification), stored encrypted.
• Content you upload: images, captions, tags, live stream data.
• Communications: messages sent through the platform's messaging feature.

Information collected automatically:

• Log data: IP address, browser type, pages visited, time and date of visits.
• Device information: device type, operating system, unique device identifiers.
• Usage data: clicks, feature interactions, subscription activity.
• Cookies and similar tracking technologies (see Section 7).

We use your information to:

• Provide, operate, and improve the platform.
• Process payments and payouts.
• Verify user age and identity to ensure legal compliance.
• Communicate with you about your account, transactions, and updates.
• Enforce our Terms of Service and Content Policy.
• Detect and prevent fraud, abuse, and illegal activity.
• Comply with legal obligations, including law enforcement requests.
• Personalize your experience and recommend relevant content.
• Send marketing communications where you have opted in (you can opt out at any time).

We do not sell your personal data to third parties.

If you are located in the European Economic Area or United Kingdom, we process your data under the following legal bases:

• Contract: Processing necessary to perform our agreement with you (providing the platform service).
• Legitimate Interests: Platform security, fraud prevention, improving our services.
• Legal Obligation: Compliance with applicable laws (age verification, tax reporting, law enforcement).
• Consent: Marketing communications and non-essential cookies.

We may share your information with:

• Payment processors (e.g., Stripe) to process transactions.
• Identity verification providers to confirm age and identity.
• Cloud infrastructure providers to host and deliver the platform.
• Analytics providers to understand platform usage (data is anonymized where possible).
• Law enforcement or regulatory authorities when required by law, court order, or to protect safety.
• Successors in the event of a merger, acquisition, or asset sale, with appropriate notice to you.

All third-party service providers are contractually required to process data only as instructed by us and to implement appropriate security measures.

We retain your personal data for as long as your account is active or as needed to provide services. After account deletion, we retain certain data for up to 7 years as required by financial regulations (transaction records) and applicable law. Identity verification records are retained as required by 18 U.S.C. § 2257.

You may request deletion of your account and associated data at any time (subject to legal retention requirements) by contacting privacy@twinkletoes.com.

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate data.
• Deletion: Request deletion of your personal data (subject to legal obligations).
• Portability: Receive your data in a structured, machine-readable format.
• Objection / Restriction: Object to or restrict certain processing activities.
• Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.
• California (CCPA): California residents have additional rights including the right to know about data sold (we do not sell personal data) and the right to non-discrimination.

To exercise your rights, contact: privacy@twinkletoes.com. We will respond within 30 days.

We use cookies and similar technologies to:

• Keep you logged in (session cookies).
• Remember your preferences.
• Understand how the platform is used (analytics).
• Prevent fraud and improve security.

You can control cookie preferences through your browser settings. Disabling certain cookies may affect platform functionality. We do not use advertising cookies or share data with ad networks.

We implement industry-standard technical and organizational measures to protect your data, including:

• Encryption of data in transit (TLS/HTTPS) and at rest.
• Access controls and principle of least privilege.
• Regular security assessments.
• Secure, PCI-compliant payment processing.

No system is 100% secure. In the event of a data breach that affects your rights, we will notify you as required by applicable law.

Twinkle Toes is strictly an adult platform (18+). We do not knowingly collect personal information from individuals under the age of 18. If we become aware that a minor has created an account, we will immediately terminate the account and delete all associated data. If you believe a minor has accessed the platform, contact us immediately at safety@twinkletoes.com.

Your data may be transferred to and processed in countries other than your country of residence. For transfers from the EEA/UK, we rely on Standard Contractual Clauses approved by the European Commission or equivalent safeguards to ensure your data receives adequate protection.

We may update this Privacy Policy from time to time. We will notify you of material changes by email or prominent notice on the platform. The "Last updated" date at the top indicates the most recent revision. Continued use of the platform after changes constitutes acceptance.