Privacy Policy for collabcampfire.com

As of March 15, 2025

Introduction

Collab Campfire, LLC (“Company” or “we”) is committed to protecting your privacy by providing transparency and adhering to this policy.

This policy describes the information we might collect from you or that you might provide when you visit the website collabcampfire.com or any pages sharing the same root url (our “Website”) and our practices for collecting, using, maintaining, protecting, and sharing that information.

This policy applies to information we collect on our Website, email, text, and other electronic messages between you, other users of this Website.

This policy does NOT apply to information collected by third parties or any other websites operated by the Company. It does not apply to information through affiliates, advertisers, or other third parties that might be linked to/from this Website.

If you do not agree with our policies and practices, do not use our Website.

By accessing or using this Website, you consent to the practices described in this policy. We may change this policy from time to time (see Changes to Our Privacy Policy). If you continue to use the Website after we make changes, you will accept those changes so please check this policy periodically for updates.

Children Under the Age of 18

By creating an account, you have represented you are over the Age of 18. No one under 18-years old may provide any information to or on the Website. We do not knowingly collect personal information from children under 18-years old. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you might use. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@collabcampfire.com.

Information We Collect About You

Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data).

Depending on whether you are a visitor, a collaborator, or a producer, we collect and use different types of information from and about you such as:

  • Identity Data: including your legal name, stage name, username or similar identifier, social media identifiers, social security number or employer identification number, foreign tax identification number, government-issued photo identification, date of birth, gender, signed written consents, selfie photo, and voice and image (in any content that you upload or transmit). Through the user validation and profile setup process, we may also confirm you are in fact an online content creator or producer.
  • Location and IP Location Data: including the state of your address, the location of the collab, and the IP address of the collaborator.
  • Contact Data: including postal address, email address, and telephone numbers.
  • Financial Data: including bank or other payment account and payment card details. We store only limited, if any, Financial Data. Otherwise, our payment processor stores all Financial Data, and we encourage you to review their privacy policy and contact them directly for responses to your questions.
  • Contract Data: including details about agreements to and from you and other collaborators you have documented through our Website.
  • Health Data: including STI testing requirements and whether or not you completed the test prior to the shoot day if required as part of a collaboration workflow.
  • Affiliate Data: including whether or not you used a discount code, purchased products/services, or subscribed to services of an affiliate of the Company.
  • Technical Data: including internet protocol (IP) address, ISP name, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
  • Device Data: including the type of mobile device (“Device”) you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and IP address.
  • Content Data: including photos, video footage, audio (for example, music and other sounds), data, text (including comments and hashtags), metadata, images, interactive features, emojis, GIFs, memes, and any other material you upload on or through our Website. Please remember Content Data you upload might reveal personal information about yourself, including identifying information about yourself depicted in any Content Data.
  • Profile Data: including your username and password (including password hints and other information for authentication and account access), any images or URLs to other collabs, your status as a collaborator, your interests, preferences, feedback, and survey responses. Some information you choose to give us may be considered “special” or “sensitive” in certain jurisdictions, for example, your sex life and sexual orientation. Further, as part of becoming a ‘Verified’ collaborator, we may ascertain whether you are a registered sex offender and the fact you are not will be part of your profile. By choosing to submit special or sensitive information, you hereby consent to our processing of that information in accordance with this Policy.
  • Usage Data: including information about how you use our Website, products, and services.
  • Third-Party Login Data: includes your email address, username, and password if you choose to link a third-party account with us to facilitate account creation and logon process.
  • Marketing and Communications Data: including your preferences in receiving marketing from us and your communication preferences.

We also collect, use, and share Aggregated Data including statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information that will be used under this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless you voluntarily provide it. Please note that submitting health information related to a shoot may become the record associated with a collab and it may be shared and stored in that limited context.

We do not collect or store your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These third-party payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

Where we need to collect personal information by law, or under the terms of a contract we have with you and you do not provide that information when requested, we might not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How We Collect Information About You

We collect information from and about you:

  • Directly: You may give us information about you by filling in forms or by corresponding with us by email. This includes information you provide when you sign up; subscribe to services; create a profile; create and negotiate a collab, interact with fellow collaborators through our interactive services; request marketing to be sent to you; enter a competition, promotion, or survey; or give us feedback or contact us.
  • Automatically through Technology: As you interact with our Website, we may automatically collect Technical and Device Data about your equipment, browsing actions, and patterns as specified above. We collect this information by using cookies, server logs, log files, pixel tags, and other similar technologies (see Cookies and Automatic Data Collection Technologies below). We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please note that we do not recognize or respond to any do not track signals (DNT). For more information about DNT, visit www.allaboutdnt.com.
  • Nonparties or publicly available sources: We will receive personal information about you if you visit other websites employing our cookies or from nonparties including, for example, business partners (including affiliates in any affiliate marketing program); subcontractors in technical, payment, delivery, content moderation, and identity and age verification services; advertising networks; analytics providers; search information providers; and third-party websites, if you choose to register or login using an approved third-party website account.
  • User contributions: You also may provide collab terms for us to publish or display (“post”) on Website areas or transmit to other website users or nonparties. You submit this data for posting and transmission to others at your own risk. Additionally, we cannot control the actions of any Website users with whom you choose to share your collab details. Therefore, we cannot and do not guarantee that unauthorized persons will not view your collab information.

Cookies and Automatic Data Collection Technologies

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Website might become inaccessible and certain features might not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

Our Website pages and emails might contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics including recording Website content popularity or verifying system and server integrity.

Nonparty Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by nonparties, including affiliates, advertisers, ad networks and servers, content providers, and application providers. These nonparties might use cookies alone or with web beacons or other tracking technologies to collect information about you when you use our Website. They might associate the information collected with your personal information or they might collect information, including personal information, about your online activities over time and across different websites and other online services. They might use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these nonparty tracking technologies operate or how they might use the collected information. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use your information to provide you with products, offer you services, communicate with you, deliver marketing, or to conduct other business operations, including using information to improve and personalize your experiences. Examples of how we may use the information we collect (including any personal information) include but are not limited to:

  • Identify you as a visitor, collaborator, or producer on our Website.
  • Present our Website and its contents to you.
  • Provide you with the information, products, services, and support that you request from us.
  • Provide you with notices about your account or subscription, including expiration and renewal notices.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Help other collaborators contact you in relation to an agreement you may have entered into on our Website.
  • Notify you about changes to our Website or any products or services we offer or provide through it.
  • Allow you to participate in interactive features on our Website.
  • Verify your identity and age when you use the Website.
  • Verify your identity and age in the result of a regulatory audit or Reg. 2257 compliance check.
  • Review content before publishing a collab to ensure that it is not illegal and does not otherwise violate our terms of use.
  • Engage in real-time monitoring and removal of material we suspect might be illegal.
  • Monitor compliance with the Website’s terms of use or for quality assurance purposes.
  • Audit related to a current interaction with the user and concurrent transactions.
  • Comply with law.
  • Respond to your inquiries related to support or other requests.
  • Facilitate account creation and logon process if you choose to register or log in to our Website using a third-party account.
  • Deliver targeted advertising, newsletters, and other information.
  • Promote your content or account, including on other websites.
  • Promote our Website.
  • Use data analytics to improve our Website, products, services, marketing, customer relationships, and experiences.
  • Ensure that we present our Website content in the most effective manner for you and for your computer or device.
  • Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
  • Improve our Website, products or services, marketing, or customer relationships and experiences.
  • Protect our Website, employees, or operations.
  • Assist law enforcement and respond to subpoenas.
  • Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
  • We may also use your information to contact you about our own and nonparties’ goods and services that might be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or email us at privacy@collabcampfire.com. For more information, see Choices About How We Use and Disclose Your Information.
  • We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
  • We may use nonpersonal information for any business purpose.

We may also use your information to contact you about our own and nonparties’ goods and services that might be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or email us at privacy@collabcampfire.com. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may use nonpersonal information for any business purpose.

Disclosure or Sharing of your Information

We may disclose and use Aggregated Data about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy with:

  • Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
  • Business partners, suppliers, service providers, subcontractors, and other third parties we use to support our business. Examples include analytics and search engine providers that assist us with Website improvement and optimization, vendors that specialize in the validation of government identification to verify your identity and age, sex worker service providers, email delivery providers, hosting service providers, customer service providers, and marketing efforts. We may allow selected nonparties to use tracking technology on our Website, which will enable them to collect information about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use third party analytics and our own analytic tools to help us understand how our customers use our Website. For third parties, we contractually require these nonparties to keep that personal information confidential and use it only for the contracted purposes.

To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “invite a collaborator” feature of our Website, we will transmit the contents of that email and your email address to the recipients.

For any other purposes that we disclose when you provide the information.

With your consent.

We may also disclose your personal information to nonparties:

  • If we sell or purchase any business or assets, we may disclose your personal information to the prospective seller or buyer of that business or assets.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Collab Campfire, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal information held by Collab Campfire, LLC about our Website users.
  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To comply with any agreement we have with you to produce documents or records supporting potential litigation between you and other collaborators or producers when the underlying agreement was documented on our Website.
  • To enforce or apply our Terms of Service, and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Collab Campfire, LLC, our customers, or others. This includes exchanging information with other companies and organizations for cybersecurity, fraud protection, and credit risk reduction.

Consent to Personal Information Transfer

We are based in the United States of America and at present, we expect all of our Users are based in the USA and only accessing the Website from within the USA. We may process, store, and transfer the personal information we collect, in and to a country outside of the USA, with different privacy laws that might or might not be as comprehensive as your own. If you are located outside the United States when you access the Website (which would be a violation of our Terms of Use), your personal information might at times be accessible by persons who are located worldwide including in countries that the European Commission or other geopolitical regions have not determined to provide the same adequate level of data protection in your country, province, territory, or geopolitical region.

By submitting your personal information or engaging with our Website, you hereby consent to this transfer, storing, or processing, including the transfer of your information across international boundaries to jurisdictions anywhere in the world as permitted by law.

Your Choices About How We Use and Disclose Your Information

We strive to provide you with transparency and choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website might not function properly.

Promotional Offers from the Company. If you do not wish to have your Contact Data used by the Company to promote our own or nonparties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (e.g., the registration form) or by sending us an email stating your request to privacy@collabcampfire.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a purchase, service experience, or other transactions.

We do not control nonparties’ collection or use of your information to serve interest-based advertising. But these nonparties may provide you with ways to choose not to have your information collected or used in this way.

State Privacy Laws

Residents of certain jurisdictions, including California, Nevada, Colorado, Connecticut, Virginia, and Utah might have additional personal information rights and choices.

Please refer to the following links for state-specific privacy rights information:

Accessing and Correcting Your Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. You have the right to request access to and to correct the personal information that we hold about you.

You can access, review, and change your personal information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of (if allowed by the law of your jurisdiction) your personal information, you may also send us an email at privacy@collabcampfire.com to request access to, correct, or delete any personal information that you have provided to us. In some circumstances, we cannot delete your personal information except by also deleting your user account. While we will delete your account, we may use technology to ensure you do not start a new account as we have a strict, 1 person, 1 account rule to ensure user fidelity as an effort to keep our user community safer.

We will not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information or data (contracts, footage, Form 2257s, etc.), however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal information that we hold about you or make your requested changes. Applicable law might allow or require us to refuse to provide you with access to some or all the personal information that we hold about you, or we might have destroyed, erased, or made your personal information anonymous under our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you delete your Content Data from the Website, copies of your Content Data might remain viewable in cached and archived pages or because other Website users might have copied or stored them. Our Terms of Service Agreement governs proper access and use of information provided on our Website, including collab data.

Residents of certain jurisdictions, including California, Nevada, Colorado, Connecticut, Virginia, Utah, European Economic Area, and United Kingdom might have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws might provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, please visit California Civil Code § 1798.83 – Shine the Light Law. Users of our Website that are California residents may request certain information regarding our disclosure of personal information to nonparties for their direct marketing purposes. To make that request, please send an email to privacy@collabcampfire.com.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Legal Basis for Processing

We may process your personal data, content, or collab data because you have given us permission to do so (e.g., by sending data through our Website’s contact or signup forms), because the processing is in our legitimate interests and it is not overridden by your rights, or because we need to process your personal data to perform a contract with you or comply with the law.

Data Retention

Under agreement with the Company, we may have a contractual obligation to retain your data (footage, agreements, Form 2257, etc.) for a certain period of time.

Except as otherwise permitted or required by contract, law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use that anonymous and de-identified information for any legitimate business purpose without further notice to you or your consent.

Withdrawing Your Consent

Where you have given your consent to the collection, use, and transfer of your personal information, you might have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, you may contact us at privacy@collabcampfire.com. Please note that if you withdraw your consent, we might not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls. We have added a second layer of encryption for sensitive personally-identifiable information associated with a user’s individual profile before storing. All other data stored in our file storage and database tools is stored with industry standard encryption.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in your profile is visible to other users of the Website and what you say or do within a collab negotiation is visible to fellow collaborators on that shoot.

Unfortunately, the transmission of information through the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

We will post changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at privacy@collabcampfire.com.