Privacy Policy for Fans using Creator Platforms powered by fr3n

Last Updated: [07.10.2025]

fr3n GmbH ("fr3n," "we," "our," or "us") is committed to protecting your privacy.

This Privacy Policy explains how we collect, use, and share your personal information when you use creator platforms powered by fr3n technology (each a "Creator Platform").

It also explains your rights and choices regarding your personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

This Privacy Policy applies specifically to fans who interact with Creator Platforms operated by independent creators.

If you are a creator using the fr3n platform to manage your own community, please refer to the Creator Privacy Policy.

1. Applicability of this Privacy Policy

fr3n provides a white-label technology solution that enables creators, artists, and organizations to operate customized digital platforms for fan engagement, communication, and monetization.

This Privacy Policy applies to personal data collected:

• from fans who register on or interact with creator platforms powered by fr3n,
• from fans who purchase subscriptions or digital products from creators via the platform,
• and from visitors accessing these services for information or support purposes.

Please note:

• Creators act as independent data controllers for the processing of fan data on their respective platforms.
• fr3n acts as a data processor that provides hosting, infrastructure, and technical support on behalf of each creator.
• Fans should also review the privacy policy of the specific creator whose platform they use.

2. Information We Collect

2.1 Information Provided by Fans

We collect personal information that you provide directly when using a Creator Platform, including:

• Account and Registration Data: name, email address, password, and any profile information you provide.
• Engagement Data: comments, likes, direct messages, or participation in creator activities such as campaigns or events.
• Payment Information: billing details and transaction data processed securely by third-party payment providers (e.g., Stripe).
• Wallet Information: if you connect a digital wallet (e.g., for memberships or tokens), we collect your wallet address and transaction metadata. We do not store private keys.

2.2 Automatically Collected Data

When you access a Creator Platform, we and our partners may automatically collect:

• Device Data: IP address, device type, operating system, browser type, and general location (country or region).
• Usage Data: pages visited, navigation paths, time spent, and features used within the platform.
• Cookies and Tracking: cookies or similar technologies to ensure functionality and analyze engagement. You can manage these preferences in your browser or device settings.

3. How We Use Your Information

We process personal data to:

• Provide and manage the Creator Platform: including account creation, authentication, and content access.
• Facilitate payments and subscriptions: process transactions securely via trusted third-party providers.
• Enable direct engagement: support communication between fans and creators, such as messaging, notifications, and exclusive content.
• Enhance user experience: personalize your experience and improve platform performance.
• Ensure compliance and security: detect and prevent fraud, abuse, or unauthorized access.
• Analyze and improve services: use aggregated and anonymized data to understand platform usage and optimize performance.

We rely on Article 6(1)(b) GDPR (performance of a contract) and Article 6(1)(f) GDPR (legitimate interest) for most processing. Where required, we obtain your consent under Article 6(1)(a) GDPR.

4. Sharing and Disclosure of Information

4.1 Sharing with Creators

When you interact with a Creator Platform, your data (e.g., engagement analytics, subscription status, or contact details) is shared with the respective creator.

Each creator determines how they process and use this data under their own privacy policy.

4.2 Third-Party Services

We may share personal data with trusted service providers who help us operate the platform, such as:

• Payment processors (e.g., Stripe) for secure transaction handling,
• Wallet providers (e.g., thirdweb) for blockchain integrations,
• Cloud and hosting providers (e.g., AWS, Vercel) for platform infrastructure,
• Analytics providers (e.g., Google Analytics) for usage measurement and improvement.

All service providers are bound by contractual data protection obligations.

4.3 Compliance and Legal Requirements

We may disclose information to law enforcement or regulatory authorities when legally required, or to protect against fraud, misuse, or security threats.

5. Wallet Infrastructure and Blockchain Data

Some Creator Platforms include blockchain-based functionalities.

When you connect a crypto wallet or acquire blockchain-based assets (e.g., memberships or tokens), please note:

• Blockchain transparency: transactions are recorded publicly and cannot be altered or deleted.
• Data collected: we may process your wallet address and transaction metadata for identification and access purposes.
• No private key storage: fr3n never stores or has access to your private keys.
• Third-party integrations: wallet connections are provided through external services (e.g., thirdweb) in compliance with their respective privacy terms.

Blockchain transactions are inherently public and may be viewed by others via blockchain explorers.

6. Your Rights and Choices

As a data subject under the GDPR, you have the right to:

• Access: request a copy of the personal data we hold about you.
• Rectification: correct inaccurate or incomplete data.
• Deletion: request deletion of your personal data ("right to be forgotten").
• Restriction and Objection: limit or object to specific types of processing.
• Data Portability: receive your data in a structured, machine-readable format.
• Withdraw Consent: withdraw consent at any time without affecting prior processing.

To exercise your rights regarding data controlled by the creator, please contact the creator directly.

For processing carried out by fr3n as a processor, contact privacy@fr3n.tech.

You may also adjust cookie preferences via your browser settings.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this policy or as required by law:

• Fan account data: retained until you delete your account or terminate your relationship with the creator.
• Transaction data: retained for legal retention periods (typically 6-10 years).
• Wallet and blockchain data: retained as long as the connected wallet remains active.

8. Security Measures

We take extensive technical and organizational measures to protect your personal data, including:

• encryption of data in transit and at rest,
• strict access control and authentication procedures,
• regular system audits and vulnerability testing.

However, due to the nature of the internet and blockchain systems, no method of transmission or storage is completely secure.

9. International Data Transfers

If your personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, such as:

• EU Commission adequacy decisions, or
• Standard Contractual Clauses (SCCs) approved by the European Commission.

Copies of these safeguards can be requested at privacy@fr3n.tech.

10. Updates to this Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or business changes.

When updates are made, we will revise the "Last Updated" date above and, where appropriate, notify users through the Platform or by email.

11. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:

fr3n GmbH

Schaumburgstraße 3

48145 Münster, Germany

Email: privacy@fr3n.tech

Fans may also contact their respective creators directly for questions about data collected and processed by them.