Privacy Notice

Last Updated:  19 May 2025

Mingle Minds AI Limited (“Mingle Minds”, “we”, “us”, “our”) cares about your privacy and protecting the Personal Data that we process. This Privacy Notice explains how we collect, use, disclose, and handle your personal data while you are accessing the website at www.everfans.com, and/or any affiliated website to which you may be redirected from the website (the “Website”), as well as your rights under applicable data protection law. Mingle Minds is the Controller for data processing implemented through the Website.

Anyone under the age of 18 (or the age of majority in their jurisdiction) may not use the Website. NAME is intended for use only by adults, and by using the Website, you represent that you are an adult.

Mingle Minds is duly incorporated in the Republic of Malta, having its address at 56 Central Business Centre, Triq Is-Soll, Santa Venera SVR 1833, Malta, and registered with the Malta Business Registry under the number C108196.

By using the Website, you agree that you have read and understood our Privacy Notice.

1. Introduction

All capitalized terms not otherwise defined in this Privacy Notice have the same meanings as in our Terms of Service or in the General Data Protection Regulation (GDPR).

In order to provide you with the Services, we need to collect and process certain personal data. “Personal data” is subject to this Privacy Notice and includes any information relating to, describing, identifying, or reasonably capable of being associated a particular person or household. We may also collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as deidentified, aggregated or anonymized information. This type of data is not personal data, and our use of such data is not subject to this Policy.

2. Categories of Personal Data; Purposes of Processing

As we are committed to respect your privacy, such Services will always be provided in accordance with the most relevant legal basis.

Purpose of the Processing	Categories of Personal Data	Legal basis
Account creation Managing your registration to our Services.	Creators Account handle/nickname/screenname Country of residence Email address Encrypted password Basic profile information such as profile picture, bio (to the extent these contain personal data) Phone number Personal data collected directly by our third-party age/identity verification provider (“third-party provider”), which we may have access to, including:  A copy of your government identity document provided to our third-party provider; A short .gif taken from a “selfie” provided to our third-party provider; Results of the third-party provider’s age/identity verification process (whether you passed, and if not why); Metadata associated with the third-party provider’s . Fans Email address Encrypted password Nick name/screenname Gender First and last name (as disclosed by you or third-party authentication systems, e.g., if you create your account via Google single sign-on); Creation date and time and signup provider (e.g., Twitter; Google; Discord; Email) (generated based on the options you select);	Consent; necessity for the performance of a contract; compliance with legal obligations.
Account management	Currency (based on detected country); Country and/or city (detected based on IP address and zipcode (if given)); Data regarding activity on your account, e.g., last account update date and time; last sign in date and time; sign in IP address(es); sign-in count (how many times you have signed in)	Our legitimate interest in addressing your queries.
Provision of the Services Use of platform features and AI Tools	Creators: Posts that you have made, comments on posts, chat messages between you and other Users. Your subscriptions, subscribers, and referrals; Customer support queries you have made; Fans: Comments you have made on posts, Messages you have exchanged with Creators; Your account activity and preferences (e.g., creators/pages viewed; interests)	Consent; necessity for the performance of a contract.
Support of the Services Customer support and communication (service emails, technical support, responding to user-initiated contacts etc.).	Email address (user account information as relevant to the request or support issue) Content of email exchange or other contact method (e.g., via “Contact us” form) Device information (mobile/desktop), browser type (e.g., Chrome, Firefox etc.) Cookies (as detected by us).	Our legitimate interest in addressing your queries and technical issues.
Payment processing Processing by payment service providers for security and payment for: Subscriptions; Refunds in appropriate cases.	Creators Pay-out details First and last name (must much the account holder’s first and last name) Address, including zip code, city, state and country Bank name Account number and/or IBAN Currency of the account Swift code / ACH routing number PayPal username or PayPal e-mail Crypto wallet Stable coin or crypto (including network details) Fans Emerchant Pay (EMP) (and any other credit card processing partner, as available in your location and updated from time to time) First and last name; Email address; Card brand; Credit card number; Payment transaction date and time; Type; Amount; Currency; Bin country; IP address; Recurring billing type; Response code (issuer); Type of refund (full or partial)	Necessity for the performance of a contract.
Direct Marketing - Deliver marketing emails to inform you of our latest updates, offers and features through our newsletter; - Enable affiliate marketing program questionnaire.	Email address (as disclosed by you; mandatory registration field); First and last name (as disclosed by you and if you used a specific authentication method, e.g., Google, to create your account); Account number; Website or traffic source URL; and Data linked to the affiliate marketing program questionnaire free fields to introduce potential affiliates and how they plan to promote the Service.	Our legitimate interest in improving our Services (direct marketing by us for similar products and Services) or consent (third party marketing).
Analytics other than through cookies or other tracking technologies Allowing customer surveys, marketing campaigns, market analysis.	Account number; Email address (as disclosed by you; mandatory registration field); Answer provided by the User.	Consent
Safety         - Moderation of the Services (problematic behavior, abuse report, action taken); - Reporting to law enforcement in appropriate cases	Content flagged by our moderation controls and/or reported by Users; Action taken in response to flagged Content; Metadata regarding your Content (time/date sent, originating IP address); Account data and history; In appropriate cases, information required by local authorities and/or information to facilitate the investigation of individuals who use the Services to conduct unlawful activity, including specifically but not limited to Uploading or creating CSAM.	Necessity to comply with legal obligations or, as the case may be, necessity for the performance of a contract (in case of breach of our policies).
Legal & Accounting Record keeping; Invoice recovery; Compliance with court orders; Management of data subject access requests.	Supporting data (as provided by you) such as contact data, payment data or credentials; Information lawfully requested in court orders or other legal process.	Necessity for compliance with legal obligations.
Complying with lawful requests from authorities, court orders and exercising and/or defending our legal rights.	Supporting data (as provided by you) such as contact data, payment data or credentials, and/or any information within the scope of lawful legal requests or processes.	Complying with our legal obligations; our legitimate interest in defending our rights.

3. Marketing

We may send you marketing about our Services, other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you, or in order to update you with information which we believe may be relevant to you (such as commercial news). We may communicate this to you according to the contact channels you provided and your stated preferences, including by telephone, email or other digital channels.

If you do not wish to receive marketing information from us, you can unsubscribe by:

1. clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us; or
2. contacting us using the contact details specified in Section 11 below.

Please note that opting-out of marketing communications will not affect account- or service-related communications.

4. Third Party Marketing

We will get your express opt-in Consent before we share your Personal Data with any company outside Mingle Minds for marketing purposes.

You can ask us or third parties to stop sending you direct marketing messages by electronic means at any time by logging into the Services or third parties’ websites and adjusting your marketing preferences, or by following the opt-out links on any marketing message sent to you by such third parties.

5. Sharing your Personal Data

We may share your information with:

1. service providers to deliver the Services as follows:

• payment service providers (based in EU for European users); and
• hosting service providers (based in the US); and
• email marketing tools providers (based in the US); and
• affiliate partner tools (based in the EU).

2. professional advisers where necessary to obtain advice or assistance, including lawyers, accountants, IT or public relations advisers;
3. legal and regulatory authorities, as required by applicable laws and regulations; and
4. our employees, as needed for them to carry out their work.

We will not disclose, sell, trade, or otherwise transfer your Personal Data to any third parties without your Consent (where required) or unless otherwise stated in this Privacy Notice.

If Mingle Minds merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your Personal Data may be disclosed to our advisers, any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, Personal Data will always remain subject to this Privacy Notice, as updated in accordance with section 13.

6. Retention Period

We retain your Personal Data for as long as your account is in existence and/or as needed to provide you with the Services, and/or as long as necessary to fulfill the purposes for which we collect it, except if required otherwise by law. However, when you terminate your account, we will still retain your Personal Data for a period of time. Usually, we will store your Personal Data for a period after you cease being a User of our Services, beginning at the date your account is closed.

Retention periods may be changed from time to time based on business or regulatory requirements.

We generally keep:

1. Personal Data relating to your account up to three to five years after your last use of the Services to address potential customer inquiries and/or permit further use of the platform (unless you request deletion earlier), financial and transactional data seven years from their date of issuance (in accordance with our tax obligations);
2. marketing data until you withdraw your Consent or for a period of two years after your last interaction;
3. In accordance with any legally mandated retention periods or in connection with ongoing legal disputes (as applicable).

7. Personal Data of minors

Mingle Minds does not provide Services or collect Personal Data from anyone under 18 years of age or equivalent minimum age depending on jurisdiction. Our Services are intended for use only by adults who are at least 18 years of age, or the age of majority in the jurisdiction in which they reside and/or access the Services. If we learn that we have been misled by an underaged individual, we will take steps to delete the information as soon as possible and block such User. Please also refer to our Underage Policy.

8. Third-party links

The Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the Privacy Notice of every website that can be accessed through the Services.

9. Your Rights Regarding Your Personal Data

Under certain circumstances and subject to certain exemptions, you have the following rights under EU and UK data protection law:

1. Right to access (request a copy of your personal data that we process and check that we are lawfully processing it)
2. Right to rectification (keep your personal data up-to-date and correct)
3. Right to erasure (have your data deleted where there is no legitimate reason for us to continue processing it or you have exercised your right to object (see below). We may not be able to comply with a deletion request where processing your data is necessary to comply with a legal obligation; to establish, defend, or exercise legal claims; or perform our contract; or if your account was deactivated for violation of our Policies.)
4. Right to restrict processing (limit how we use your data)
5. Right to data portability (request the transfer of your data to another party)
6. Right to object (stop certain types of processing)
7. Right to withdraw consent (you may withdraw your consent to our processing your data at any time and free of charge. Withdrawing consent does not affect the lawfulness of processing up until the withdrawal.)
8. where our processing is based on your consent)
9. Right to lodge a complaint (with your local supervisory authority (a list of European Union national data protection authorities can be found here, and the United Kingdom’s Information Commissioner Office’s contact details may be found here).

We do not conduct or process personal data subject to solely automated decision-making within the meaning of the GDPR.

To exercise any of your rights under EU/UK data protection law, please contact us as explained in the “Contact us” section below.

10. Right to obtain a copy of Personal Data safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Data is transferred outside of the European Union, the United Kingdom or Switzerland, as applicable, redacted of any terms unrelated to data protection.

11. Contacting us, Complaints

You have a right to lodge a complaint with your local supervisory authority (see also Section 9 above). If you have concerns about how we are Processing your Personal Data, we ask that you please attempt to resolve any issues with us first. If you have any questions, concerns, or complaints regarding this Privacy Notice, or if you wish to exercise your rights related to your Personal Data, you can reach us at the following contact details.

Privacy Team

Email:  [email protected] 

Mailing Address: Mingle Minds AI Limited, 56 Central Business Centre

  Triq Is-Soll, Santa Venera SVR 1833, Malta

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

13. Changes to the Privacy Notice

We may revise this Privacy Notice from time to time to take account of our changes of practices or of new applicable data protection law. If we modify our Privacy Notice, we will post the revised version on the Services with an updated revision date. Where such changes are substantial, we will also notify you by other means prior to the changes taking effect, such as by sending you an email notification or through the Service. By continuing to use our Services thirty days after such revisions are in effect, you will be deemed to accept and agree to the revisions and to abide by them.

---