Privacy Policy

Last updated: 08 November 2026

1. Data controller

2. Scope

This Policy explains how HORIZON MEDIA SERVICES LTD processes personal data in connection with VipAffair.

3. Account data

We may process:

• name and email address;
• user identifiers;
• protected authentication credentials;
• role and account status;
• settings and preferences;
• authentication and session information;
• protected Vault PIN information.

4. Creator information

We may process information required for:

• registration and Creator profiles;
• onboarding and verification;
• KYC where applicable;
• content monetisation;
• payments and payouts;
• individual commercial terms;
• moderation and compliance;
• support.

5. Transaction information

We may process:

• Order and Transaction IDs;
• amount and currency;
• payment status;
• the relevant Creator and product;
• the effective price;
• the applicable revenue allocation;
• an applicable commercial agreement;
• refund, dispute and chargeback information;
• payment-provider references.

VipAffair does not operate monetary Fan Credits, prepaid monetary wallets or top-ups.

6. Fan Vault and Creator Storage

We may process:

• the selected storage plan;
• applicable storage limits;
• used and remaining storage;
• storage subscriptions;
• custom storage requests over 20 GB;
• associated assets;
• information required to secure and administer storage.

7. Content and access data

We may process:

• uploaded content and metadata;
• asset identifiers;
• content-origin classifications;
• AI disclosure information where applicable;
• moderation decisions;
• authorised-access records;
• protection and traceability information.

8. Messaging

We may process data necessary to provide, secure and administer VipAffair messaging services.

9. Customer support

We may process:

• email address;
• WhatsApp number or identifier when WhatsApp support is used;
• the content of a support request;
• ticket and account information;
• support history.

10. Security information

We may process:

• IP addresses;
• sessions and Request IDs;
• authentication events;
• audit trails;
• security events;
• fraud-prevention information;
• technical information required to detect unlawful or unauthorised use.

11. Purposes

Personal data may be used to:

• create and authenticate accounts;
• provide VipAffair;
• administer Fans and Creators;
• administer Vault and storage services;
• process orders and transactions;
• authorise access;
• protect digital content;
• provide messaging and support;
• administer payouts;
• apply documented Creator commercial terms;
• moderate content;
• prevent fraud and protect security;
• manage disputes and chargebacks;
• maintain audit records;
• comply with legal obligations;
• establish, exercise or defend legal rights.

12. Lawful bases

Contract

Processing may be necessary to provide a service requested by the user or perform a contract.

Legal obligation

Processing may be necessary to comply with an applicable legal obligation.

Legitimate interests

Where appropriate and proportionate, processing may support security, fraud prevention, infrastructure protection, user and Creator protection, dispute management and defence of Company rights.

Consent

Consent may be used where required by law or the relevant activity.

13. Payment provider

Real payments will be processed by the payment provider actually approved and integrated.

Necessary data may be shared for:

• payment processing and authentication;
• fraud prevention;
• refunds and chargebacks;
• reconciliation;
• Creator payouts.

This Policy will be updated with relevant provider information before real payment activation.

14. Recipients

Where necessary and legally permitted, data may be shared with categories including:

• hosting and infrastructure providers;
• payment providers;
• email providers;
• KYC or identity-verification providers;
• technical and security providers;
• fraud-prevention services;
• professional advisers;
• competent authorities where legally required.

15. Sale of personal data

VipAffair does not sell its user database as a standalone product.

16. International transfers

Where personal data is transferred outside the United Kingdom, HORIZON MEDIA SERVICES LTD will use the mechanisms and safeguards required by applicable UK data-protection law.

17. Retention

Accounts

Account data is retained during the user relationship and afterwards where necessary for legal obligations, disputes, security and protection of rights.

Transactions

Transaction records are retained where necessary for accounting, tax, fraud prevention, disputes, chargebacks and legal obligations.

Security and audit

Security and audit records are retained in accordance with applicable security, compliance and legal requirements.

Support

Support information is retained for case management and related legal, security and defence needs.

Content

Content-related data is retained as necessary to provide, protect and moderate the service and afterwards where a valid legal reason applies.

18. Security

Technical and organisational measures may include authentication, authorisation, role separation, session protection, Vault PIN, access control, logging, audit, monitoring and content protections.

No information system can guarantee zero risk.

19. Cookies and similar technologies

VipAffair may use cookies or similar technologies necessary for authentication, security, sessions, carts and service functionality.

Non-essential technologies will be used in accordance with applicable information and consent requirements.

20. Marketing

Marketing communications will be sent where permitted by law and supported by an appropriate lawful basis. A suitable opt-out method will be provided where applicable.

21. Individual rights

Depending on applicable law and circumstances, individuals may have rights relating to:

• access;
• rectification;
• erasure;
• restriction;
• objection;
• data portability;
• withdrawal of consent where applicable;
• safeguards concerning certain automated decision-making;
• complaint to a supervisory authority.

22. Exercising privacy rights

Requests may be submitted to: clientservice@vipaffair.live .

VipAffair may take reasonable steps to verify the identity of a requester.

23. UK supervisory authority

Where applicable, an individual may complain to the Information Commissioner’s Office.

24. Automated decision-making

If VipAffair introduces solely automated decision-making subject to specific legal requirements, this Policy will be updated.

25. Policy changes

This Policy may be updated for legal, technical, operational, organisational or commercial reasons. Material new uses of data will be communicated where required.

26. Contact