FANENGINE_

Privacy Policy

Effective Date: June 16, 2026

1. Overview

FanEngine AI Inc., a Delaware corporation ("FanEngine," "we," "us," or "our"), operates the website at fanengine.ai (the "Site") and provides a fan-intelligence and engagement platform to creators and businesses (the "Platform"). This Privacy Policy explains what personal information we handle, the capacity in which we handle it, how we use and share it, and the rights available to individuals.

FanEngine acts in two distinct roles, and this Policy keeps them separate:

  • As a controller: for information we collect for our own purposes, such as visitors to our Site and our creator account holders. We decide why and how that information is processed, and this Policy governs it.
  • As a processor (service provider): for fan and end-user information we process on behalf of a creator who uses the Platform. In that role the creator is the controller, we do not own the data, and we process it only on the creator's documented instructions under our agreement (including a Data Processing Addendum) with that creator. The creator's own privacy policy primarily governs that data; we assist the creator in meeting its obligations.

2. Scope of This Policy

This Policy applies to personal information we handle through the Site and through our provision of the Platform. It does not govern the independent data practices of creators, partners, or third-party websites and services, which are subject to their own policies. Where we process fan or end-user data on a creator's behalf, that processing is governed by our agreement with the creator and that creator's privacy policy.

3. Information We Collect

3.1 Site Information (we act as controller)

Information We Collect How We Use It Who We Share It With
Contact details: name, email address, IP address, and social media handle you provide when you join our waitlist or request access. Add you to our waitlist; send product updates; respond to your requests. Service providers (e.g., hosting, email).
Site usage & device data: device type, browser, timezone, time on page, scroll depth, referring URL, and UTM parameters. Via Google Analytics and Microsoft Clarity: pages viewed, session duration, clicks, and approximate location derived from IP address. Understand how people discover and use our Site; improve our product and marketing; maintain security. Analytics providers (Google, Microsoft); service providers.

3.2 Creator Account Information (we act as controller)

When a creator or business signs up for the Platform, we collect business and contact information (such as company name, contact name, email, phone, address, and social handles), account credentials, and billing and revenue-tracking details necessary to provide and bill for the Services.

3.3 Fan & End-User Information (we act as processor on behalf of creators)

When a creator uses the Platform, we process information about that creator's fans, subscribers, and customers (which may include names, email addresses, phone numbers, social handles, engagement signals, and purchase or transaction history) solely to provide the Services to that creator. We process this information on the creator's documented instructions, we do not sell it, and we do not use it for our own independent purposes. The creator is the controller of this information.

4. How We Use Information

Where we act as a controller, we use personal information to: provide, operate, and improve the Site and Platform; communicate with you, including product updates and support; process transactions and administer accounts; maintain the security and integrity of our services; and comply with legal obligations. Where we act as a processor, we use fan and end-user information only to provide the Services to the relevant creator and as that creator instructs.

5. Legal Bases for Processing (EEA, UK, and Switzerland)

Where the EU GDPR, UK GDPR, or Swiss data protection law applies and we act as a controller, we rely on the following legal bases:

  • Contract: to provide the Site, Platform, and Services you or your organization request.
  • Legitimate interests: to operate, secure, and improve our services and understand how they are used, where not overridden by your rights.
  • Consent: where we ask for it, such as certain analytics cookies or marketing; you may withdraw consent at any time.
  • Legal obligation: to comply with applicable law.

Where we act as a processor, the relevant creator (as controller) is responsible for establishing the legal basis for the processing it instructs.

6. How We Share Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose personal information only as follows:

  • Service providers and subprocessors: vendors who help us run our business (e.g., cloud hosting, analytics, email, payment processing). They are bound by contract to keep information confidential and to process it only on our instructions. A current list of subprocessors is available on request.
  • At the creator's direction: where we act as a processor, we share fan and end-user data only as the creator instructs.
  • Legal and safety: to comply with law, respond to lawful requests, enforce our agreements, or protect the rights, safety, and property of FanEngine, our users, or others.
  • Corporate transactions: in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy.

7. International Data Transfers

We are based in, and store information in, the United States, and we may process information there and in other countries where we or our service providers operate. These countries may have data protection laws that differ from those where you live.

Where we transfer personal data from the EEA, UK, or Switzerland to the United States, we rely on a recognized transfer mechanism. FanEngine intends to self-certify to the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework (the "Data Bridge"), and to the Swiss-U.S. Data Privacy Framework. Where a Framework does not apply, we rely on the European Commission's Standard Contractual Clauses, together with the UK International Data Transfer Agreement or UK Addendum, and other appropriate safeguards.

8. Data Retention

Where we act as a controller, we retain personal information for as long as needed for the purposes described in this Policy, and then delete or de-identify it, unless a longer period is required to meet legal, accounting, or dispute-resolution obligations. Where we act as a processor, we retain fan and end-user data only as long as needed to provide the Services and as instructed by the creator, and we return or delete it on termination of the applicable agreement.

9. Security

We implement reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, or misuse. No method of transmission or storage is completely secure. Where we act as a processor and become aware of a confirmed personal data breach affecting a creator's data, we will notify the affected creator without undue delay and, in any event, within seventy-two (72) hours of confirmation, consistent with our agreement with that creator.

10. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information. Where we act as a processor on a creator's behalf, please direct requests to that creator; we will assist the creator in responding.

10.1 EEA, UK, and Switzerland

You may have the right to access, correct, delete, or receive a portable copy of your personal data; to object to or restrict certain processing; and to withdraw consent. You also have the right to lodge a complaint with your local supervisory authority. In the UK, that is the Information Commissioner's Office (ico.org.uk).

10.2 United States (California and other states)

Depending on your state, you may have the right to know what personal information we collect, to access or delete it, to correct inaccuracies, and to opt out of sale or sharing. As noted above, we do not sell personal information or share it for cross-context behavioral advertising. We will not discriminate against you for exercising your rights.

10.3 How to Exercise Your Rights

To make a request, email us at privacy@fanengine.ai. We may need to verify your identity before responding, and an authorized agent acting on your behalf must provide proof of authorization. We will respond within the time required by applicable law.

10.4 EU and UK Representatives

Where required, FanEngine will appoint and identify a representative in the EU and the UK to receive privacy inquiries from individuals and authorities in those regions.

11. Cookies & Analytics

Our Site uses cookies and similar technologies, including Google Analytics and Microsoft Clarity, to understand and improve how the Site is used. You can manage cookies through your browser settings and can opt out of Google Analytics at tools.google.com/dlpage/gaoptout.

12. Children's Privacy

The Site and Platform are not directed to children, and we do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, please contact us so we can delete it.

13. Third-Party Websites & Services

Our Site and Platform may link to or integrate with third-party websites and services that we do not control. We are not responsible for their privacy practices, and we encourage you to review their policies.

14. Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy with a revised effective date and, where required, notify you. Material changes may be communicated by email to the address you provided.

15. Contact Us

If you have questions or requests regarding this Policy or your personal information, contact us at:
FanEngine AI Inc.
privacy@fanengine.ai

© 2026 FanEngine AI Inc. All rights reserved.
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