Privacy Policy

1. Who We Are

This Privacy Policy explains how FANDLE INC. ("Fandle," "S2fan," "we," "us," "our"), a Delaware corporation, collects, uses, and shares personal data through the S2fan website and its linked forms. FANDLE INC. operates as a "Pure Marketplace" (Venue) connecting independent artists with fans, and is the data controller for the purposes of this Policy.

Registered address: 111B S Governors Ave Ste 40082, Dover, DE 19904-6903-117, USA
Privacy contact: hello@fandle.me
General support: hello@fandle.me

2. What Data We Collect

We do not currently collect payment card numbers directly — at launch, payment data will be collected and stored by our payment processor (see Section 4), not by Fandle Inc. directly.

3. How We Use Your Data

• To manage the pre-registration waitlist and notify you about launch, betas, or changes to your pre-registration perk.
• To review and respond to feedback submissions and incorporate them into the product roadmap.
• To evaluate job applications, communicate with applicants, and, where you consent, retain your application for future roles.
• To operate, secure, and improve the Site, and once launched, the marketplace (listings, orders, pickup/shipping, payments, buyer protection, and dispute resolution).
• To detect and prevent fraud, abuse, and violations of our Terms of Service, including our content policy on prohibited content.
• To comply with legal obligations, including tax reporting for Seller payouts once the marketplace is live (e.g., U.S. 1099 reporting where applicable).

We do not use Your Content to train AI. FANDLE INC. will not use artwork, shop descriptions, or other creator content you upload to train, develop, or fine-tune our own generative AI models. We use technical measures to discourage unauthorized third-party scraping of content hosted on the platform.

4. Third-Party Processors

We share personal data with service providers who process it on our behalf, under contractual confidentiality and data-protection obligations:

• Tally.so — hosts our pre-registration, feedback, and job application forms and initially collects the data you submit through them.
• Payment processing (future): Stripe, and where applicable PayPal, Klarna, KakaoPay, NaverPay, and Toss, expected to process and hold Buyer and Seller payment and payout data once the marketplace launches. Seller identity/KYC verification (including government-issued IDs and tax forms) is collected directly by Stripe's hosted onboarding flow — Fandle does not store this sensitive data on its own servers, only the resulting verification status.
• Infrastructure: Amazon Web Services (AWS) hosts our data.
• Support: Zendesk and Tidio for customer support ticketing and chat.
• Analytics: Google Analytics, Amplitude, and Firebase for site and app performance analytics; Microsoft Clarity for session-replay/heatmap analysis (note: Microsoft Clarity may use anonymized behavioral data to train its own third-party models — this is separate from Fandle's own no-AI-training policy on your creative content, see Section 3).
• Marketing: Meta (Facebook/Instagram), TikTok, Bing, and Mailchimp for advertising and lifecycle marketing.

We do not sell your personal data to third parties for their own marketing purposes.

5. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, our legal bases for processing your data are:

• Consent — for pre-registration, feedback, and marketing communications, which you can withdraw at any time.
• Legitimate interests — for site security, fraud prevention, and evaluating job applications.
• Contract performance — once the marketplace launches, to provide shop, checkout, and order fulfillment services you request.
• Legal obligation — for tax and financial reporting once payments are live.

6. Data Retention

• Pre-registration data: retained until launch plus a reasonable period after, or until you ask us to delete it, whichever is earlier.
• Feedback submissions: retained as long as useful for product development, or until you ask us to delete it.
• Job applications: retained for the hiring process and, where you consent, for consideration for future roles; otherwise deleted within a reasonable period after the role is filled or closed.
• Marketplace transaction data (future): retained as required for tax, accounting, and dispute-resolution purposes, which may exceed account closure.

7. Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you.
• Correct inaccurate data.
• Delete your data ("right to be forgotten"), subject to legal retention requirements (e.g., tax records once payments are live).
• Object to or restrict certain processing.
• Withdraw consent at any time, without affecting processing that occurred before withdrawal.
• Request a copy of your data in a portable format.

To exercise any of these rights, contact us at hello@fandle.me. We will respond within the time required by applicable law.

8. International Transfers

S2fan is intended to serve a global community of fan creators and buyers ("worldwide" shipping is referenced on the Site). Your data may be transferred to and processed in the United States and other countries where our service providers operate. Where required, we rely on appropriate safeguards (such as Standard Contractual Clauses) for transfers out of the EEA/UK/Switzerland.

9. Children's Privacy

FANDLE INC. enforces a strict age policy to comply with the U.S. Children's Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR):

• Under 13: access is strictly prohibited. We do not knowingly collect personal information from this age group, and any account identified as belonging to a user under 13 will be terminated immediately.
• Ages 13–17: may only use the Service through an account owned and managed by a parent or legal guardian, with that adult's explicit permission and direct supervision. The adult account holder is responsible for all activity and financial transactions on the account.
• 18 and older: may hold an independent account.

If you are a parent or guardian and believe your child under 13 has provided personal information to us without your consent, contact our Privacy Office immediately at hello@fandle.me. We will promptly investigate and remove such information from our servers.

Because minors 13–17 may use the Service under supervision, S2fan does not permit adult or sexual content on the platform at all — see the Content Policy in our Terms of Service.

10. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal data. No system is completely secure, and we cannot guarantee absolute security of information transmitted to or from the Site.

11. Cookies & Similar Technologies

The Site may use cookies or local storage (for example, to remember a theme preference) and standard analytics technologies to understand how visitors use the Site. You can control cookies through your browser settings; disabling them may affect Site functionality.

12. U.S. State Privacy Rights (CCPA/CPRA and similar)

If you are a California resident, or a resident of another U.S. state with a comprehensive privacy law, you may have rights to know what personal data we collect, request deletion, request correction, and opt out of the sale or "sharing" of personal data (as those terms are defined by applicable law). We do not sell personal data. To exercise these rights, contact us at hello@fandle.me. We will not discriminate against you for exercising these rights.

13. Changes to This Policy

We may update this Policy as S2fan evolves, in particular when marketplace and payment functionality goes live. We will post the updated Policy on the Site with a new "Last updated" date, and for material changes affecting how we use previously collected data, we will provide notice and, where required, seek your consent.

14. Contact

Questions about this Policy or your data: hello@fandle.me