Privacy Policy

1.1 Purpose. This Privacy Policy explains how Caprice, operated by Anyone LLC, 1178 Broadway, 3rd Floor #1504, New York, NY, United States (“we,” “us,” “our,” “the Platform”), collects, uses, shares, and protects your personal information when you use our platform and services. We respect your privacy and are committed to protecting your personal information through industry-leading practices and transparent policies.

1.2 Scope. This Privacy Policy applies to all users of the Platform, including Senders and Creators, and covers all information collected through our website, mobile applications, and related services, regardless of how you access or use them.

1.3 Acceptance. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, you must not use our Platform. Your continued use constitutes your ongoing consent to this Privacy Policy.

1.4 Changes.We reserve the right to modify this Privacy Policy at any time. We will notify you of material changes by updating the “Last Updated” date, displaying a prominent notice on the Platform, and sending an email to the address associated with your account for significant changes. Your continued use after changes constitutes acceptance.

2.1 Account Information. When you create an account, we collect:

• Full name
• Email address
• Username
• Password (stored in encrypted form)
• Date of birth (to verify age eligibility)
• Country of residence
• Profile information you choose to provide

2.2 Creator Profile Information. For Creators, we additionally collect:

• Profile pictures
• Biographical information
• Links to social media accounts
• Professional information
• Minimum offer amount preferences
• Any other information you choose to share on your profile

2.3 Payment Information. When you make or receive payments, we collect:

• Credit/debit card details (processed securely through Stripe)
• Billing address
• Transaction history
• Bank account information (for Creators receiving payments)
• Tax identification information (where required by law)

All payment processing is handled securely through Stripe. We do not store your full credit card information on our servers. Stripe may require additional Know Your Customer (KYC) verification as part of their compliance requirements.

2.4 Communications. We collect and store communications between Senders and Creators on the Platform. These communications are encrypted end-to-end and are not accessible to us except in specific circumstances outlined in Section 3.5.

2.5 Usage Data. We collect information about how you use the Platform, including pages visited, features used, actions taken, offers made and received, acceptance and rejection patterns, time and duration of activities, referral sources, and search terms.

2.6 Device Information. We collect device type and model, operating system, browser type, IP address, mobile device identifiers, connection information, time zone settings, location information (if enabled), and language preferences.

2.7 Cookies and Similar Technologies. We use cookies and similar tracking technologies to remember your preferences, understand how you use the Platform, improve your experience, provide personalized content, and analyze the effectiveness of our features. You can control cookies through your browser settings.

2.8 Information from Third Parties. We may receive information about you from service providers, identity verification services, fraud prevention services, and public databases.

3.1 Providing and Improving Services. We use your information to create and maintain your account, operate the Platform, process transactions, improve and personalize your experience, develop new features, analyze usage patterns, provide customer support, and send service-related notifications.

3.2 Processing Payments. We use your payment information to process transactions between Senders and Creators, hold funds securely until requests are fulfilled, release funds after successful fulfillment, process refunds, prevent fraud, comply with financial regulations, and generate transaction records.

3.3 Facilitating Communication. We use your information to enable secure encrypted communication between Senders and Creators, send service notifications, respond to inquiries, send administrative messages, provide security alerts, and facilitate offer negotiations.

3.4 Dispute Resolution. We may use your information, including communications, to investigate and resolve disputes, verify fulfillment of requests, process refund requests, enforce our Terms of Service, and protect the rights and safety of our users.

3.5 Decryption of Communications. Communications between Senders and Creators are encrypted end-to-end and are not accessible to us except in the following limited circumstances:

• When a dispute is formally filed through our SealGuard resolution system;
• When required by valid legal process (such as a court order, subpoena, or search warrant);
• When necessary to investigate violations of our Terms of Service;
• When necessary to protect the safety, rights, or property of users or the Platform;
• When a user initiates a chargeback through their payment provider.

In all cases, access to decrypted communications is strictly limited to authorized personnel on a need-to-know basis, subject to appropriate security controls, and only for the specific purpose required.

3.6 Platform Security. We use your information to verify your identity, detect and prevent fraud, debug platform errors, monitor for suspicious activity, and ensure the integrity of the Platform.

3.7 Legal Compliance. We use your information to comply with applicable laws and regulations, respond to lawful requests from public authorities, enforce our Terms of Service, and establish, exercise, or defend legal claims.

3.8 Marketing. With your consent where required by law, we may use your information to send you news and updates, communicate about new features, provide personalized recommendations, and conduct surveys. You can opt out of marketing communications at any time.

4.1 Contract Performance. We process your personal information when necessary to perform our contract with you, including creating and managing your account, processing transactions, providing customer support, facilitating communication, and resolving disputes.

4.2 Legitimate Interests. We process your personal information when necessary for our legitimate interests, including improving and personalizing our services, ensuring security, preventing fraud, analyzing usage patterns, and enforcing our Terms. We balance our interests against your privacy rights.

4.3 Legal Compliance. We process your personal information when necessary to comply with legal obligations, including responding to legal requests, complying with tax and financial regulations, maintaining required records, and preventing illegal activities.

4.4 Consent. We process your personal information based on your consent when you opt in to marketing communications, you provide sensitive information voluntarily, or as required by applicable law. You may withdraw your consent at any time.

5.1 Between Users. We share information between Senders and Creators as necessary to facilitate interactions, including profile information visible to other users, communications between matched users, transaction details, and dispute-related information when necessary.

5.2 Service Providers. We may share your information with third-party service providers who perform services on our behalf, including Stripe for payment processing, cloud hosting and storage providers, analytics services, customer support services, email providers, and security and fraud prevention services. These providers are contractually obligated to protect your information.

5.3 Legal Requirements. We may disclose your information if required by law or in response to valid requests by public authorities, including court orders, subpoenas, and law enforcement investigations.

5.4 Business Transfers. If we are involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership and your choices regarding your personal information.

5.5 Chargebacks. In the event of a chargeback, we may share relevant information with payment processors, banks, and financial institutions to defend against the chargeback. This may include transaction details, communications, evidence of service delivery, and account activity logs.

5.6 Aggregated Data. We may share aggregated or anonymized information that cannot reasonably identify you for industry analysis, demographic profiling, research, and improving our services.

5.7 With Your Consent. We may share your personal information with third parties when you have given us consent to do so. You can withdraw consent at any time.

6.1 End-to-End Encryption. Communications between Senders and Creators are encrypted end-to-end. Only the intended recipients can access message content, except in the specific circumstances outlined in Section 3.5.

6.2 Security Measures. We implement appropriate technical and organizational measures to protect your information, including encryption of data at rest and in transit, regular security assessments and penetration testing, multi-factor authentication for administrative access, access controls and authentication mechanisms, secure network configurations, regular security training for staff, and continuous monitoring for suspicious activities.

6.3 Data Breach Procedures. In the event of a data breach affecting your personal information, we will notify you without undue delay, provide information about the breach and its impact, outline steps we are taking to mitigate the breach, offer guidance on protecting yourself, and notify relevant regulatory authorities as required by law.

6.4 Payment Security. All payment information is processed through Stripe, a PCI-DSS compliant payment processor. We do not store your full credit card information on our servers.

6.5 Limitations. While we take reasonable steps to protect your information, no security system is impenetrable and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials, using strong passwords, and reporting any suspicious activities to us immediately.

7.1 Account Information Access. You can access and update your account information at any time by logging into your account or contacting our support team.

7.2 Communication Preferences. You can manage your communication preferences through your account settings, using unsubscribe links in marketing emails, or contacting us directly. You may opt out of non-essential communications, but we may still send you service-related communications necessary for the Platform.

7.3 Data Portability. You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format. Contact us at [email protected].

7.4 Data Deletion. You may request deletion of your personal information by using the account deletion option in your settings or contacting us at [email protected]. We will respond within a reasonable timeframe. We may retain certain information as required by law or for legitimate business purposes.

7.5 Objection to Processing. You have the right to object to our processing of your personal information in certain circumstances. Contact us at [email protected] with details of your objection.

7.6 Do Not Track Signals. Due to the lack of a common standard for interpreting Do Not Track signals, our Platform currently does not respond to them. You can use other tools described in this Privacy Policy to control data collection.

8.1 Active Account Data. We retain your personal information for as long as your account is active or as needed to provide you with our services.

8.2 Terminated Account Data. After account termination, we may retain certain information to comply with legal obligations, resolve disputes, prevent fraud, enforce our Terms, and complete pending transactions. We will typically delete or anonymize your personal information within 90 days of termination, except as noted below.

8.3 Dispute-Related Data. Information related to disputes, including decrypted communications, may be retained for up to 3 years after the dispute is resolved.

8.4 Payment Information. We retain payment information as required by financial and tax regulations, typically for 7 years. This includes transaction records, payment receipts, tax documents, and chargeback and refund information.

8.5 Communication Records. Encrypted communications are retained for the duration of your account and for a reasonable period after termination to allow for dispute resolution and legal compliance. After this period, communications are permanently deleted or anonymized.

8.6 Legal Holds. Notwithstanding the above, we may preserve information for longer periods if required by law, for litigation purposes, or to comply with legal obligations.

9.1 Cross-Border Processing. Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. Our servers are located in the United States, and our service providers may be in various countries.

9.2 Safeguards. When we transfer your information internationally, we implement appropriate safeguards including standard contractual clauses approved by the European Commission, binding corporate rules, and contractual commitments from recipients.

9.3 EU-US Transfers. For transfers from the European Economic Area to the United States, we rely on appropriate safeguards such as the EU-US Data Privacy Framework, standard contractual clauses, or other valid transfer mechanisms.

10.1 Age Restrictions. The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. All users must be at least 18 years old.

10.2 Removal of Minor's Data. If you believe we have collected information from a child under 18, please contact us at [email protected] and we will promptly investigate and delete such information.

10.3 Age Verification. We implement age verification measures during registration, including date of birth verification and monitoring for indicators of underage users.

11.1 Payment Processors.We use Stripe to process payments. When you make or receive payments, you may be subject to Stripe's terms and privacy policies. Stripe may require additional KYC verification. We are not responsible for Stripe's processes or decisions.

11.2 External Links. Our Platform may contain links to third-party websites or services. We are not responsible for their content or privacy practices. We encourage you to review their privacy policies.

11.3 Social Media Features. Our Platform may include social media features such as share buttons. These features may collect your IP address and set cookies. Your interactions with these features are governed by the privacy policy of the providing company.

12.1 California (CCPA/CPRA). If you are a California resident, you have the right to: know what personal information we collect, use, and disclose; delete your personal information (subject to exceptions); correct inaccurate information; opt out of the sale or sharing of your information; limit the use of sensitive personal information; and not be discriminated against for exercising these rights. We do not sell your personal information for monetary consideration. To exercise your California privacy rights, contact us at [email protected].

12.2 European (GDPR).If you are in the European Economic Area, United Kingdom, or Switzerland, you have the right to: access your personal information; rectify inaccurate information; erase your information (“right to be forgotten”); restrict processing; data portability; object to processing; rights related to automated decision-making; and withdraw consent. To exercise these rights, contact us at [email protected]. We will respond within one month. You also have the right to lodge a complaint with your local data protection authority.

12.3 Other Jurisdictions. We respect and comply with applicable local laws regarding data protection and privacy in all jurisdictions where we operate. Contact [email protected] with jurisdiction-specific inquiries.

13.1 Data Protection Officer. We have appointed a Data Protection Officer who can be contacted at [email protected] for any inquiries related to our data protection practices.

13.2 Records of Processing. We maintain records of our data processing activities as required by applicable law, including purposes of processing, categories of data subjects, recipients of personal data, and security measures.

13.3 Data Protection Impact Assessments. We conduct data protection impact assessments for processing operations that may result in high risk to the rights and freedoms of individuals.

13.4 Privacy by Design. We implement privacy by design and default principles in our products and services, considering privacy at the design phase and implementing appropriate measures to ensure that only necessary personal data is processed.

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

• Privacy: [email protected]
• Data Protection Officer: [email protected]
• Legal: [email protected]

We will respond to your inquiries within a reasonable timeframe, typically within 30 days. For complex requests, we may require additional time and will notify you accordingly.

If you have a privacy concern that we have not addressed satisfactorily, please contact our Data Protection Officer. If you are in the EEA, you also have the right to lodge a complaint with a supervisory authority.