Privacy Policy

This Privacy Policy for InnerText (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at https://www.inner-text.com or any website of ours that links to this Privacy Policy
• Use the InnerText platform as a creator or fan
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at support@inner-text.com.

Summary of Key Points

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
• Do we process any sensitive personal information? We do not intentionally collect sensitive personal information. We do not process racial or ethnic origins, sexual orientation, or religious beliefs.
• Do we collect any information from third parties? We do not collect any information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
• How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
• What are your rights? Depending on where you are located geographically, applicable privacy law may mean you have certain rights regarding your personal information.
• How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request or by contacting us at support@inner-text.com.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On To Process Your Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. Do We Use Cookies and Other Tracking Technologies?
6. How Long Do We Keep Your Information?
7. How Do We Keep Your Information Safe?
8. Do We Collect Information From Minors?
9. What Are Your Privacy Rights?
10. Controls for Do-Not-Track Features
11. Do United States Residents Have Specific Privacy Rights?
12. Do We Make Updates to This Policy?
13. How Can You Contact Us About This Policy?
14. How Can You Review, Update, or Delete the Data We Collect From You?

1. What Information Do We Collect?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include:

• Names
• Phone numbers
• Email addresses
• Usernames
• Passwords
• Contact or authentication data
• Contact preferences
• Creator profile information (bio, profile photo, pricing tiers)
• Bank account or payout information for creators receiving earnings disbursements

Sensitive Information. We do not intentionally process sensitive personal information, including racial or ethnic origins, sexual orientation, or religious beliefs.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by our third-party payment processor(s). Please refer to the checkout experience for applicable payment processor privacy notices.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, including your IP address, device information, browser type and settings, and information about your activity in the Services (date/time stamps, pages and files viewed, searches, and other actions).
• Device Data. Information about your computer, phone, tablet, or other device you use to access the Services, including your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. Information about your device's location, which can be either precise or imprecise. You can opt out by disabling your location settings on your device, though this may affect certain features of the Services.
• SMS and Messaging Data. As an SMS-based platform, we collect the content of messages sent and received through our Services, including text, media files (images, video, audio/voice notes), and metadata associated with those messages (timestamps, delivery status, read receipts). This data is stored and processed for the purpose of delivering the Services and managing creator fan relationships.
• Video and Audio Call Session Data. When you participate in a video or audio call through InnerText, we collect call session metadata (duration, session identifiers, participant information, and purchase records). Actual call audio and video content is not recorded or retained by InnerText. Calls are powered by Daily.co; please refer to Daily.co's privacy policy for information on how in-session data is handled on their infrastructure.

2. How Do We Process Your Information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user, including SMS subscription management, PPV content delivery, voice and video calls, tips, and creator payouts.
• To send administrative information to you, including details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications between creators and their fans through the platform's SMS infrastructure.
• To process payments and manage creator payouts.
• To request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• To protect our Services, including fraud monitoring and prevention, content moderation, and enforcement of our SHAFT Policy and Content Standards.
• To comply with legal obligations and respond to lawful requests from public authorities.
• To save or protect an individual's vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On To Process Your Personal Information?

For Users in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

For Users in Canada

We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

4. When and With Whom Do We Share Your Personal Information?

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Payment Processors. We share payment information with our designated payment processor(s) solely for transaction processing, fraud prevention, dispute handling, compliance review, subscription management, and creator payout administration.
• Authorized Alt-Login Users. Creators may grant access to their InnerText account to authorized alt-login users (chatters or agency staff). These users can view fan conversation data, fan profiles, and media vault content as permitted by the creator. InnerText logs all activity by alt-login users and associates it with the creator's account for audit and dispute purposes.
• SMS Carriers and Infrastructure Providers. We share limited technical information with SMS carriers and messaging infrastructure providers solely for the purpose of delivering SMS messages through our Services. Mobile messaging opt-in data and consent will not be sold or shared with any third party for marketing or promotional purposes. SMS opt-in information is not shared with third parties for purposes unrelated to the InnerText platform.
• Legal Authorities. We may disclose your information to law enforcement, government authorities, or other third parties when required by law or when we believe it is necessary to protect the rights, property, or safety of InnerText, our users, or the public.

5. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar tracking technologies (such as web beacons and pixels) to collect information when you interact with our Services. This section explains what cookies are, which types we use, and how you can control them.

What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites work or work more efficiently, as well as to provide information to site operators. Cookies may be “session cookies” (which expire when you close your browser) or “persistent cookies” (which remain on your device for a set period or until you delete them).

Types of Cookies We Use

• Strictly Necessary Cookies. These cookies are essential for the Services to function and cannot be switched off. They are typically set in response to actions you take, such as logging in, setting your privacy preferences, or filling in forms. Without these cookies, parts of the Services cannot be provided. These cookies do not store any personally identifiable information beyond what is necessary to deliver the service.
• Functional Cookies. These cookies enable enhanced functionality and personalization, such as remembering your preferences and settings. They may be set by us or by third-party providers whose services we use. If you disable these cookies, some features of the Services may not function properly.
• Performance and Analytics Cookies. These cookies collect information about how visitors use our Services, for example which pages are visited most often and whether visitors receive error messages. All information collected by these cookies is aggregated and anonymous. We may use this data to improve the performance of our Services.

Third-Party Tracking Technologies

We may permit third-party service providers to place cookies or similar technologies on our Services for analytics and service improvement purposes. These third parties have their own privacy policies and are independently responsible for the cookies they place. We do not control the cookies placed by third parties and encourage you to review their respective privacy policies.

Your Cookie Choices and Controls

You have the right to decide whether to accept or reject non-essential cookies. You can exercise your cookie preferences in the following ways:

• Browser Settings.Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies, delete existing cookies, or alert you when cookies are being sent. Please note that disabling certain cookies may affect the availability and functionality of the Services. For more information, refer to your browser's help documentation.
• Mobile Device Settings.If you access our Services through a mobile device, you can manage certain tracking preferences through your device's operating system settings.
• Do Not Track.Some browsers include a “Do Not Track” (DNT) feature that signals to websites that you do not want to have your online activities tracked. Because there is currently no uniform technology standard for recognizing and implementing DNT signals, we do not currently respond to DNT signals. However, you may use the browser and device controls described above to limit tracking.

Legal Basis for Cookie Use (EEA and UK Users)

For users in the European Economic Area (EEA) and United Kingdom (UK), we rely on the following legal bases for placing cookies on your device:

• Strictly necessary cookies: Processed on the basis of our legitimate interest in operating a functional and secure platform, and our contractual obligation to provide the Services to you.
• Functional and analytics cookies: Processed on the basis of your consent, where applicable. You may withdraw consent at any time by adjusting your browser settings as described above.

California Residents (CCPA)

Under the California Consumer Privacy Act (CCPA), California residents have the right to opt out of the “sale” or “sharing” of personal information. We do not sell your personal information. To the extent any cookie-based tracking on our Services constitutes a “share” of personal information for cross-context behavioral advertising purposes under the CCPA, you may opt out by adjusting your browser settings as described above, or by contacting us at support@inner-text.com.

6. How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. No purpose in this policy will require us keeping your personal information for longer than twenty-four (24) months past the start of the idle period of the user's account. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. You should only access the Services within a secure environment.

Data Breach Notification

If we become aware of a data breach affecting personal information, we will investigate the incident and notify affected users, regulators, or other required parties in accordance with applicable law.

8. Do We Collect Information From Minors?

InnerText is strictly intended for users who are 18 years of age or older. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent and warrant that you are at least 18 years of age. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from users under 18, please contact us at support@inner-text.com.

9. What Are Your Privacy Rights?

Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying STOP or UNSUBSCRIBE to any SMS messages that we send, or by contacting us using the details in Section 13 below.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at support@inner-text.com.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

Categories of Personal Information We Collect

Your Rights

You have rights under certain US state data protection laws. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request or by emailing us at support@inner-text.com.

California Shine The Light Law

California Civil Code Section 1798.83, also known as the Shine The Light law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided in Section 13 below.

12. Do We Make Updates to This Policy?

Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this Privacy Policy from time to time. The updated version will be indicated by an updated date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may email us at support@inner-text.com or contact us by post at:

14. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please submit a data subject access request by emailing support@inner-text.com.