Privacy Policy
Last updated: February 13, 2026
PLEASE READ THIS PRIVACY POLICY CAREFULLY.
This Policy explains how we collect, use, share, and protect your personal information. By using the Co-Splay Platform, you consent to the data practices described in this Policy.
Introduction
This Privacy Policy (the “Policy”) describes how Veil Co-Splay LLC, a Nevada limited liability company (“Co-Splay,” “Company,” “we,” “us,” or “our”), collects, uses, shares, stores, and protects personal information when you access or use www.co-splay.com, www.cos-play.com, our mobile applications, and any related services, features, content, or applications (collectively, the “Platform” or “Services”).
This Policy applies to all users of the Platform, including visitors, registered users, subscribers, fans, creators, agencies, and any other participants. It is incorporated by reference into our Master Terms of Service, Creator Agreement, and Purchaser and Subscriber Terms.
By accessing or using the Platform, creating an account, uploading content, making purchases, or otherwise interacting with our Services, you acknowledge that you have read, understood, and consent to the collection, use, disclosure, and processing of your information as described in this Policy. If you do not agree to this Policy, you must not access or use the Platform.
Section 1: Data Controller Information
1.1 Who Is Responsible for Your Data?
Veil Co-Splay LLC is the data controller responsible for your personal information collected through the Platform.
Veil Co-Splay LLC
9100 Conroy Windermere Road
Suite 200 - PMB 0589
Windermere, FL 34786
United States
Privacy Inquiries: privacy@co-splay.com
General Support: support@co-splay.com
Data Subject Requests: datarights@co-splay.com
1.2 EU/UK Representative
If required by applicable law based on our data processing activities, we will designate a representative for privacy matters in the European Union and/or United Kingdom. For all privacy inquiries, including information about any designated representative, please contact us at privacy@co-splay.com.
1.3 Data Protection Officer
For privacy-related inquiries, you may contact our Privacy Team at privacy@co-splay.com.
Section 2: Information We Collect
We collect a comprehensive range of information to provide, improve, personalize, and secure our Platform. By using the Platform, you consent to the collection of all categories of information described below.
2.1 Information You Provide Directly
(a) Account Registration Information:
- Full legal name
- Display name and username
- Email address
- Password (stored in encrypted form)
- Date of birth
- Profile picture or avatar
- Bio and profile description
- Social media handles and links
- Cosplay aliases and character names
- Location (city, state/province, country)
- Language and communication preferences
(b) Identity Verification Information (Creators and Age-Verified Users):
- Government-issued identification documents (driver's license, passport, state ID, national ID card, military ID)
- Selfie photographs and video for identity verification
- Photographs holding identification documents
- Social Security Number or Tax Identification Number (for U.S. creators)
- Employer Identification Number (for business entities)
- Business registration documents
- Proof of address documents (utility bills, bank statements)
- Date of birth verification
- Citizenship and residency information
(c) Payment and Financial Information:
- Credit card and debit card information (processed by third-party processors)
- Billing name and address
- Bank account information (for creator payouts)
- Routing and account numbers
- PayPal or other e-wallet information
- Transaction history and purchase records
- Subscription and payment history
- Tax forms (W-9, W-8BEN, W-8BEN-E)
- Earnings and payout history
(d) Content and Communications:
- Photos, videos, images, and other media you upload
- Posts, captions, descriptions, and text content
- Messages, chat logs, and direct communications
- Comments, reactions, and engagement data
- Support tickets and customer service communications
- Survey responses and feedback
- Contest and promotion entries
(e) Professional and Business Information (Creators and Agencies):
- Business name and entity type
- Professional biography and credentials
- Portfolio and work samples
- Agency affiliations
- Brand partnerships and sponsorships
- Merchandise and product information
2.2 Information Collected Automatically
When you access or use the Platform, we automatically collect:
(a) Device and Technical Information:
- IP address (current and historical)
- Device type, model, and manufacturer
- Operating system and version
- Browser type and version
- Screen resolution and display information
- Device identifiers (IDFA, GAID, device ID, advertising ID)
- Hardware identifiers
- Mobile network information
- Timezone and locale settings
- Language settings
(b) Usage and Behavioral Data:
- Pages visited and content viewed
- Time spent on pages and content
- Click patterns and navigation paths
- Search queries and browsing history within the Platform
- Features used and interactions
- Frequency and timing of visits
- Session duration and activity patterns
- Scroll depth and engagement metrics
- Content consumption patterns
- Creator subscriptions and follows
- Purchase behavior and patterns
- Abandonment data (incomplete purchases, started but not completed actions)
- Referral source (how you found us)
- Exit pages and bounce rates
(c) Location Information:
- IP-based geolocation (country, region, city)
- GPS location (if you grant permission on mobile devices)
- Timezone
- Location inferred from Wi-Fi networks
- Location history over time
(d) Cookie and Tracking Data:
- First-party cookies
- Third-party cookies
- Pixel tags and web beacons
- Local storage and session storage
- Browser fingerprinting data
- Cross-device tracking identifiers
- Advertising identifiers
2.3 Information from Third Parties
We receive information from third parties, including:
(a) Social Media and Third-Party Login Providers:
- If you log in via social media (Google, Facebook, Twitter, Discord, etc.), we receive information from those platforms, including your public profile, email address, name, profile picture, and friend/follower lists
- Social media activity and engagement data
- Public posts and content from connected social accounts
(b) Payment Processors and Financial Partners:
- Transaction verification and authorization data
- Fraud detection and prevention data
- Chargeback and dispute information
- Payment method verification
- Bank verification data
(c) Identity Verification Services:
- Identity verification results
- Document authentication results
- Biometric verification data
- Fraud and risk scores
- Sanctions and watchlist screening results
(d) Analytics and Advertising Partners:
- Demographic information
- Interest and preference data
- Cross-device and cross-site tracking data
- Advertising interaction data
- Conversion and attribution data
(e) Data Enrichment Services:
- Publicly available information
- Data appended from third-party data providers
- Consumer preference and behavior data
- Demographic and psychographic data
(f) Other Users:
- Information about you contained in other users' content (tags, mentions)
- Reports and complaints filed against you
- Messages sent to you by other users
2.4 Sensitive Personal Information
In some cases, we may collect or receive sensitive personal information, including:
- Government identification numbers (SSN, tax ID)
- Financial account information
- Precise geolocation data
- Biometric data (for identity verification)
- Contents of communications (messages)
We process sensitive personal information only as necessary to provide our Services, comply with legal obligations, and for the other purposes described in this Policy.
Section 3: How We Use Your Information
We use the information we collect for the following purposes. By using the Platform, you consent to all uses described below.
3.1 Platform Operations and Service Delivery
- Create, maintain, and secure your account
- Verify your identity and age
- Process payments, subscriptions, and transactions
- Deliver content and services you purchase or subscribe to
- Process creator payouts and earnings
- Provide customer support and respond to inquiries
- Send transactional communications (receipts, confirmations, notifications)
- Maintain Platform functionality and features
3.2 Personalization and Recommendations
- Personalize your experience on the Platform
- Recommend creators, content, and features based on your interests
- Customize the content you see in feeds and discovery features
- Tailor notifications and communications to your preferences
- Remember your settings and preferences across devices
- Create and maintain your user profile
3.3 Marketing, Advertising, and Promotion
- Send promotional emails, newsletters, and marketing communications
- Display targeted advertisements on and off the Platform
- Measure advertising effectiveness and attribution
- Conduct market research and analysis
- Feature creator content in marketing and promotional materials
- Promote the Platform on social media and other channels
- Conduct surveys, contests, and promotions
- Re-target users who have visited the Platform
3.4 Analytics, Research, and Improvement
- Analyze usage patterns and trends
- Conduct research and data analysis to improve our Services
- Develop new features, products, and services
- Test and evaluate new technologies and approaches
- Create aggregated, anonymized, or de-identified data sets
- Generate analytics reports and business intelligence
- Train and improve artificial intelligence and machine learning models
- Conduct A/B testing and experimentation
3.5 Artificial Intelligence and Machine Learning
We use your information to train, develop, and improve artificial intelligence (AI) and machine learning (ML) systems, including:
- Content moderation and safety systems
- Recommendation and personalization algorithms
- Fraud detection and prevention systems
- Search and discovery systems
- Image and video analysis systems
- Natural language processing systems
- Other AI/ML models that improve our Services
By using the Platform, you consent to the use of your content and data for AI/ML training and development. This includes the use of your uploaded content, engagement data, and interactions to improve automated systems.
3.6 Safety, Security, and Fraud Prevention
- Detect, prevent, and address fraud, abuse, and security incidents
- Enforce our Terms of Service, policies, and community guidelines
- Verify user identity and prevent fake accounts
- Monitor for suspicious activity and unauthorized access
- Protect the safety of our users, employees, and the public
- Investigate violations and take appropriate action
- Block prohibited content and conduct
3.7 Legal and Compliance
- Comply with applicable laws, regulations, and legal processes
- Respond to lawful requests from law enforcement and government agencies
- Fulfill tax reporting and withholding obligations
- Maintain records as required by law
- Establish, exercise, or defend legal claims
- Enforce our agreements and policies
3.8 Business Operations
- Operate and manage our business
- Plan and execute business strategies
- Conduct financial reporting and analysis
- Support mergers, acquisitions, or business transfers
- Communicate with investors and stakeholders
- Manage vendor and partner relationships
3.9 Communications
- Send you service-related notices and announcements
- Respond to your requests and inquiries
- Communicate about your account, transactions, and subscriptions
- Send marketing and promotional communications (with your consent where required)
- Notify you of changes to our policies and terms
Section 6: Data Retention
6.1 Retention Periods
We retain your information for as long as necessary to fulfill the purposes for which it was collected, including:
(a) Active Accounts:
- Account information: As long as your account remains active
- Content: Until you delete it or your account is closed
- Transaction records: For the duration of your account plus seven (7) years
- Communications: For the duration of your account plus three (3) years
(b) After Account Deletion:
- Personal data: Deleted or anonymized within thirty (30) days, except as noted below
- Content: Deleted within thirty (30) days (unless shared/copied by others)
- Tax records: Retained for seven (7) years as required by law
- Transaction records: Retained for seven (7) years as required by law
- Identity verification records: Retained for seven (7) years
- Legal hold data: Retained until hold is lifted
- Backup copies: Deleted within ninety (90) days
(c) Specific Retention Requirements:
- Identity documents: Seven (7) years (as required for compliance)
- Tax forms (W-9, W-8): Seven (7) years
- Financial records: Seven (7) years
- Communications related to disputes: Until dispute resolution plus statute of limitations
- Data subject to legal holds: Until hold is released
6.2 Retention of Anonymized Data
We may retain anonymized or aggregated data indefinitely for research, analytics, and business purposes. Anonymized data cannot be used to identify you.
6.3 Basis for Retention
Our retention periods are based on:
- Legal and regulatory requirements
- Contractual obligations
- Statute of limitations periods
- Business operational needs
- User expectations
Section 7: Data Security
7.1 Security Measures
We implement industry-standard security measures to protect your information, including:
(a) Technical Safeguards:
- TLS/SSL encryption for data in transit
- Encryption at rest for sensitive data
- Secure password hashing (bcrypt or equivalent)
- Firewalls and intrusion detection systems
- Regular security assessments and penetration testing
- Vulnerability scanning and patch management
- Access controls and authentication
- Multi-factor authentication for sensitive systems
(b) Organizational Safeguards:
- Employee security training
- Access controls based on least privilege
- Background checks for employees with data access
- Confidentiality agreements
- Incident response procedures
- Regular security audits
(c) Physical Safeguards:
- Secure data center facilities
- Physical access controls
- Environmental protections
7.2 Payment Security
- We are PCI-DSS compliant for payment card processing
- Payment card data is processed by PCI-compliant third-party processors
- We do not store complete credit card numbers on our servers
7.3 No Guarantee of Security
While we implement robust security measures, no system is completely secure. We cannot guarantee the absolute security of your information, and you provide information at your own risk.
7.4 Security Incidents
In the event of a security incident affecting your personal information, we will:
- Investigate and contain the incident
- Notify affected individuals as required by law
- Take appropriate remedial action
- Cooperate with relevant authorities
Section 8: Your Rights and Choices
8.1 Account Settings
You can access and update your account information through your account settings on the Platform, including:
- Profile information
- Contact preferences
- Privacy settings
- Notification preferences
- Connected accounts
8.2 Marketing Communications
You can opt out of marketing communications by:
- Clicking “unsubscribe” in marketing emails
- Adjusting notification settings in your account
- Contacting us at privacy@co-splay.com
Note: You cannot opt out of transactional communications related to your account and purchases.
8.3 Cookie Preferences
- Our cookie consent banner
- Browser settings
- Mobile device settings
8.4 Mobile Permissions
You can control mobile app permissions (location, camera, photos, notifications) through your device settings.
8.5 Connected Accounts
You can disconnect third-party accounts (social media, etc.) through your account settings.
8.6 Data Subject Rights
Depending on your jurisdiction, you may have certain rights regarding your personal information. See Section 9 for California residents and Section 10 for international users.
8.7 Account Deletion
You can delete your account through:
- Account settings (Settings > Delete Account)
- Contacting support@co-splay.com
Upon account deletion, your data will be processed as described in Section 6.
Section 9: California Privacy Rights (CCPA/CPRA)
This section applies to California residents under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).
9.1 Categories of Personal Information Collected
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Name, email, username, IP address, device IDs | Yes |
| Personal Records | Payment information, address, phone number | Yes |
| Protected Characteristics | Age, gender (if provided) | Yes |
| Commercial Information | Purchase history, subscriptions, transaction data | Yes |
| Biometric Information | Facial recognition for ID verification | Yes (Creators) |
| Internet Activity | Browsing history, search history, interactions | Yes |
| Geolocation Data | IP-based location, GPS (if permitted) | Yes |
| Sensory Data | Photos, videos, audio content | Yes |
| Professional Information | Business information, professional bio | Yes (Creators) |
| Education Information | Not collected | No |
| Inferences | Preferences, characteristics, behavior predictions | Yes |
| Sensitive Personal Information | SSN/Tax ID, precise location, ID documents | Yes (as needed) |
9.2 Purposes for Collection
We collect personal information for the business and commercial purposes described in Section 3, including:
- Providing and improving our Services
- Processing transactions
- Marketing and advertising
- Analytics and research
- Safety and security
- Legal compliance
9.3 Retention Periods
See Section 6 for information about how long we retain your data.
9.4 Sale and Sharing of Personal Information
Under the CCPA/CPRA definitions:
- We do NOT “sell” personal information for monetary consideration
- We MAY “share” personal information for cross-context behavioral advertising with our advertising partners
You may opt out of the “sharing” of your personal information for targeted advertising by:
- Clicking “Do Not Sell or Share My Personal Information” on our website
- Contacting privacy@co-splay.com
- Using the Global Privacy Control (GPC) signal in your browser
9.5 Sensitive Personal Information
We collect and use sensitive personal information (SSN, precise geolocation, ID documents) only as necessary to provide our Services and comply with legal obligations. We do not use sensitive personal information for purposes beyond those permitted under CCPA/CPRA.
9.6 Your California Privacy Rights
As a California resident, you have the following rights:
- Right to Know: You can request disclosure of the categories and specific pieces of personal information we have collected about you.
- Right to Delete: You can request deletion of your personal information, subject to certain exceptions.
- Right to Correct: You can request correction of inaccurate personal information.
- Right to Opt Out of Sale/Sharing: You can opt out of the sale or sharing of your personal information for targeted advertising.
- Right to Limit Use of Sensitive Personal Information: You can limit our use of sensitive personal information to purposes necessary to provide the Services.
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
9.7 Exercising Your Rights
To exercise your California privacy rights:
- Submit a request at datarights@co-splay.com
- Use the “Privacy Rights” section in your account settings
We will verify your identity before processing your request. You may designate an authorized agent to make requests on your behalf.
9.8 Response Timing
We will respond to verifiable requests within forty-five (45) days, with possible extensions as permitted by law.
9.9 Financial Incentives
We do not offer financial incentives for the collection of personal information.
Section 10: International Users
10.1 Data Transfers
Your personal information may be transferred to and processed in the United States and other countries where our service providers are located. These countries may have different data protection laws than your country of residence.
10.2 Transfer Mechanisms
For transfers of personal information from the European Economic Area (EEA), United Kingdom (UK), or Switzerland to the United States, we implement appropriate transfer mechanisms as required by applicable law, which may include:
- EU Standard Contractual Clauses (SCCs)
- UK International Data Transfer Agreement (IDTA)
- Swiss-US Data Privacy Framework (where applicable)
- Adequacy decisions where applicable
10.3 EU/UK User Rights (GDPR/UK GDPR)
If you are located in the EEA or UK, you have the following rights under the General Data Protection Regulation (GDPR) or UK GDPR:
- Right of Access: You can request access to your personal data.
- Right to Rectification: You can request correction of inaccurate data.
- Right to Erasure: You can request deletion of your data (“right to be forgotten”), subject to certain exceptions.
- Right to Restrict Processing: You can request restriction of processing in certain circumstances.
- Right to Data Portability: You can request your data in a structured, machine-readable format.
- Right to Object: You can object to processing based on legitimate interests or for direct marketing.
- Rights Related to Automated Decision-Making: You have rights regarding automated decision-making and profiling.
- Right to Withdraw Consent: Where processing is based on consent, you can withdraw consent at any time.
10.4 Legal Basis for Processing (EU/UK Users)
We process your personal data under the following legal bases:
| Purpose | Legal Basis |
|---|---|
| Account creation and service delivery | Contract performance |
| Payment processing | Contract performance |
| Customer support | Contract performance, Legitimate interests |
| Marketing communications | Consent (where required), Legitimate interests |
| Analytics and improvement | Legitimate interests |
| Safety and security | Legitimate interests, Legal obligation |
| Legal compliance | Legal obligation |
| Advertising | Consent (where required), Legitimate interests |
| AI/ML training | Legitimate interests |
10.5 Legitimate Interests
Where we rely on legitimate interests, our interests include:
- Operating and improving our Platform
- Marketing and growing our business
- Preventing fraud and ensuring security
- Enforcing our Terms and policies
- Conducting analytics and research
10.6 EU/UK Data Protection Authority
You have the right to lodge a complaint with your local data protection authority if you believe we have violated your data protection rights.
10.7 Brazilian Users (LGPD)
If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including access, correction, deletion, portability, and information about sharing. Contact us at privacy@co-splay.com to exercise these rights.
10.8 Canadian Users (PIPEDA)
If you are located in Canada, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), including access and correction. Contact us at privacy@co-splay.com to exercise these rights.
Section 11: Children's Privacy
11.1 Age Restriction
The Platform is strictly intended for users who are eighteen (18) years of age or older. We do not knowingly collect personal information from anyone under eighteen (18).
11.2 No Collection from Minors
We do not:
- Allow users under 18 to create accounts
- Knowingly collect information from users under 18
- Market to individuals under 18
- Allow content featuring minors in any inappropriate context
11.3 COPPA Compliance
Although our Platform is for adults only, we comply with the Children's Online Privacy Protection Act (COPPA) by not collecting personal information from children under 13.
11.4 Discovery of Minor's Information
If we discover that we have collected information from anyone under 18, we will:
- Immediately terminate the account
- Delete all associated content and data
- Report to appropriate authorities if warranted
11.5 Parental Contact
If you are a parent or guardian and believe your child has provided information to us, please contact us immediately at privacy@co-splay.com.
Section 12: Third-Party Links and Services
12.1 Third-Party Websites and Services
The Platform may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to those third-party services.
12.2 Third-Party Responsibility
We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you access.
12.3 Social Media Features
The Platform may include social media features (like, share, connect buttons) that may collect information about your interaction with those features. Your interaction with these features is governed by the privacy policy of the company providing the feature.
12.4 Third-Party Analytics
We use third-party analytics services (Google Analytics, etc.) that have their own privacy policies and may collect information independently.
Section 13: Creator Data Responsibilities
13.1 Creator Access to Subscriber Data
Creators receive certain information about their subscribers, including:
- Usernames and public profile information
- Subscription status and tier
- Purchase history with the creator
- Messages from subscribers
13.2 Creator Data Processing Obligations
Creators who access subscriber data agree to:
- Use subscriber data only for purposes related to their creator activities on the Platform
- Keep subscriber data secure and confidential
- Not sell or share subscriber data with third parties
- Comply with applicable data protection laws
- Delete subscriber data upon request or account termination
13.3 Creator Responsibility
Creators are independent data controllers for certain subscriber data they access. Co-Splay is not responsible for a creator's misuse of subscriber data.
Section 14: Automated Decision-Making
14.1 Use of Automated Systems
We use automated systems for:
- Content moderation (detecting prohibited content)
- Fraud detection and prevention
- Recommendation and personalization
- Account risk scoring
- Age verification
14.2 Human Review
For consequential decisions (account termination, earnings forfeiture), we provide human review upon request.
14.3 Rights Regarding Automated Decisions
Where required by law, you have the right to:
- Obtain information about automated decision-making
- Request human review of automated decisions
- Contest decisions that significantly affect you
Section 15: Changes to This Policy
15.1 Right to Modify
We may modify this Privacy Policy at any time in our sole discretion.
15.2 Notice of Changes
We will notify you of material changes by:
- Posting the updated Policy on the Platform with a new “Last Updated” date
- Sending an email notification to your registered email address
- Displaying an in-app notification
15.3 Acceptance of Changes
Your continued use of the Platform after the posting of revised Policy means that you accept and agree to the changes. If you do not agree to the modified Policy, you must stop using the Platform.
15.4 Review of Policy
You are expected to check this Policy periodically. The most current version is always available at co-splay.com/privacy-policy.
Section 16: Contact Information
For questions, concerns, or complaints about this Privacy Policy or our privacy practices, contact us at:
Veil Co-Splay LLC
9100 Conroy Windermere Road
Suite 200 - PMB 0589
Windermere, FL 34786
United States
Privacy Inquiries: privacy@co-splay.com
Data Rights Requests: datarights@co-splay.com
General Support: support@co-splay.com
Website: www.co-splay.com
ACKNOWLEDGMENT
By using the Co-Splay Platform, you acknowledge that you have read, understood, and consent to the collection, use, sharing, and processing of your information as described in this Privacy Policy.
VEIL CO-SPLAY LLC — A Nevada Limited Liability Company