Privacy Policy

Privacy Policy

True Fan Pass ("we", "us", "our", or the "Platform") respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, protect, disclose, and otherwise process information when you access or use the Platform, create an account, obtain or manage a digital membership pass, interact with organizations, participate in platform activities, make or receive eligible transactions, communicate through supported Platform features, or otherwise use our services.

By using the Platform, you acknowledge that you have had an opportunity to review this Privacy Policy. Where required by applicable law, we will obtain appropriate consent before processing personal information for purposes that require consent.

Information We Collect

We collect information that is reasonably necessary to provide, maintain, secure, and improve the services offered through the Platform. The information we collect depends on how you use the Platform and the features available to you.

Account Information

When you create an account, we may collect information such as your name, email address, username, password credentials, profile information, account preferences, account type, and other information necessary to establish and maintain your account.

Passwords are not intended to be stored in plain text. Authentication credentials are designed to be securely processed using appropriate security controls.

Profile and Membership Information

Depending on the services available on the Platform, we may collect information associated with your digital membership profile, including profile photographs or avatars, membership status, membership tier, digital pass information, organization affiliations, verification status, account preferences, and related membership records.

Organization Information

If you register or operate an organization account, we may collect organization-related information such as organization name, business or organizational contact information, authorized representative information, account configuration information, branding information, membership settings, and other information necessary to administer the organization account.

Verification and Identity Information

Certain services may require verification before access is granted.

Where verification is required, we may collect information reasonably necessary to establish eligibility, authenticate an account, prevent fraud, or satisfy applicable legal or organizational requirements.

The specific information requested may vary depending on the verification process and the services being accessed.

We seek to limit verification information to what is reasonably necessary for the applicable purpose.

Transaction Information

Where the Platform supports transactions, we may collect information relating to deposits, payments, purchases, subscriptions, withdrawals, refunds, transaction status, transaction references, payment confirmations, and other records necessary to process and maintain transaction history.

Payment card information may be processed by authorized third-party payment service providers. Where possible, the Platform is designed to avoid storing sensitive payment card information such as full card numbers or security codes.

Digital Asset and Wallet Information

Where digital asset functionality is available, the Platform may process public blockchain addresses, transaction identifiers, asset information, network information, transaction status, and related records necessary to facilitate or verify transactions.

Public blockchain information may be permanently recorded on the relevant blockchain and may therefore not be capable of being deleted or modified by us.

We will not request your private keys, recovery phrases, seed phrases, or wallet passwords for non-custodial wallets.

Communications

When you contact us, submit a support request, communicate with an organization, or otherwise communicate through supported Platform features, we may collect the information contained in those communications together with relevant account and support information.

Device and Technical Information

When you access the Platform, certain technical information may be automatically collected.

This may include IP address, browser type, operating system, device type, approximate location derived from technical information, language preferences, pages visited, access times, referring pages, session information, diagnostic information, and security-related events.

This information may be used to maintain service reliability, detect suspicious activity, prevent abuse, troubleshoot technical problems, and improve the Platform.

Cookies and Similar Technologies

We may use cookies, local storage, session technologies, pixels, and similar technologies to maintain secure sessions, remember preferences, support functionality, understand how users interact with the Platform, and protect accounts.

Some cookies may be necessary for the operation and security of the Platform.

Where required by applicable law, non-essential cookies or similar technologies will only be used after obtaining the appropriate consent.

You may be able to manage certain cookie preferences through your browser or available Platform controls.

Disabling certain technologies may affect the availability or functionality of some Platform features.

How We Use Your Information

We may use collected information for the following purposes:

• Create and manage user accounts.
• Authenticate users and maintain secure sessions.
• Verify membership and account status.
• Issue, manage, validate, and authenticate digital membership passes.
• Provide access to benefits, features, services, events, or other membership privileges.
• Process authorized transactions and maintain transaction records.
• Provide customer support and respond to inquiries.
• Communicate important service, security, administrative, and account-related information.
• Detect, investigate, and prevent fraud, abuse, unauthorized access, and other prohibited activities.
• Protect the security and integrity of the Platform.
• Monitor and troubleshoot technical problems.
• Maintain accurate records.
• Improve Platform functionality, reliability, performance, and user experience.
• Develop new features and services.
• Comply with applicable legal, regulatory, tax, accounting, and security obligations.
• Enforce our Terms and Conditions and other applicable policies.
• Protect the rights, property, safety, and security of users, organizations, the Platform, and other parties.
• Perform other purposes that are reasonably related to the purposes described in this Privacy Policy.

Legal Bases for Processing

Depending on the jurisdiction in which you are located, we may process personal information on one or more lawful bases, including:

• Your consent.
• The performance of a contract or the provision of services requested by you.
• Compliance with a legal obligation.
• Protection of vital interests where applicable.
• Our legitimate interests, provided those interests are not overridden by your applicable privacy rights.
• Other lawful bases permitted under applicable law.

Where processing is based on consent, you may withdraw consent where permitted by applicable law. Withdrawal of consent does not necessarily affect the lawfulness of processing that occurred before the withdrawal.

Data Separation and Security

We maintain safeguards designed to keep information associated with different organizations, users, and accounts appropriately separated.

Users and organizations are only provided access to information they are authorized to access.

We apply reasonable technical and organizational measures to help prevent unauthorized access, disclosure, alteration, or use of information belonging to other users or organizations.

Data Protection and Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, alteration, disclosure, loss, misuse, or destruction.

Security measures may include encryption in transit, secure authentication mechanisms, access controls, logging, monitoring, rate limiting, security testing, infrastructure protections, database security controls, and restricted administrative access.

No internet-based service can guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us if you believe your account has been compromised.

How We Share Information

We do not sell personal information merely because you use the Platform.

We may disclose information where reasonably necessary to operate the Platform, provide requested services, process transactions, maintain security, comply with law, or protect users and the Platform.

Information may be shared with:

• Payment processors and financial service providers.
• Infrastructure and hosting providers.
• Authentication and security service providers.
• Storage and content delivery providers.
• Email and communications providers.
• Analytics and monitoring providers where applicable.
• Organizations with which you interact or hold a membership, where necessary to provide the applicable service.
• Professional advisers, auditors, insurers, or service providers where reasonably necessary.
• Government authorities, regulators, courts, or law enforcement where legally required or permitted.
• Successors or counterparties in connection with a merger, acquisition, restructuring, financing, sale of assets, or similar corporate transaction.

Service providers receiving personal information are expected to process that information only for authorized purposes and subject to appropriate contractual or security requirements.

Information Shared With Organizations

If you hold a membership, digital pass, or other relationship with an organization using the Platform, certain information may be made available to that organization where necessary to provide membership services, verify eligibility, administer benefits, or manage the relationship.

The information available to an organization may depend on the organization's configuration, the services being provided, and applicable law.

Organizations are responsible for their own processing of information where they determine the purposes and means of that processing.

Public Information

Certain information may be visible to other users or the public when you voluntarily choose to publish it through a Platform feature.

Examples may include a profile name, profile photograph, public membership information, organization affiliation, or other information you intentionally make available.

You should carefully consider what information you choose to publish.

Information that you voluntarily make public may be copied, shared, indexed, or retained by others.

Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing services, maintaining business and transaction records, resolving disputes, enforcing agreements, preventing fraud, maintaining security, and complying with legal obligations.

Different categories of information may be retained for different periods.

When information is no longer required, we may delete, anonymize, aggregate, or otherwise securely dispose of it, subject to applicable legal, regulatory, technical, or legitimate business requirements.

Some transaction or blockchain-related information may need to be retained for longer periods.

Information recorded on public blockchains may not be removable by us.

Your Privacy Rights

Depending on your location and applicable law, you may have rights concerning your personal information.

These rights may include:

• The right to request access to personal information we hold about you.
• The right to request correction of inaccurate information.
• The right to request deletion of information where legally applicable.
• The right to request restriction of certain processing.
• The right to object to certain processing.
• The right to request portability of certain information.
• The right to withdraw consent where processing is based on consent.
• The right to lodge a complaint with an applicable data protection authority.

These rights are not absolute and may be subject to legal exceptions.

We may need to verify your identity before processing certain requests.

Account Deletion

Where account deletion is available, users may request deletion of their account through available Platform controls or by contacting the appropriate support channel.

Deleting an account does not necessarily result in immediate deletion of every record.

Certain information may be retained where required for legal compliance, fraud prevention, dispute resolution, security, accounting, transaction records, or other legitimate purposes.

Children's Privacy

The Platform is not intended for children who are below the minimum age required to use the applicable services under the laws of their jurisdiction.

We do not knowingly collect personal information from children in violation of applicable law.

If you believe that a child has provided personal information to us improperly, please contact us so that we can review the matter and take appropriate action.

International Data Transfers

Depending on where you access or use the Platform, your information may be processed or stored in countries other than your country of residence.

Where applicable, we use appropriate safeguards for international transfers as required by applicable law.

Third-Party Services and Links

The Platform may integrate with or link to third-party websites, applications, payment providers, storage providers, identity or verification services, communications services, or other external services.

Third-party services operate under their own privacy policies and terms.

We are not responsible for the privacy practices of third-party services that we do not control.

You should review the privacy policies of relevant third parties before providing information to them.

Fraud and Security Monitoring

We may process technical, account, transaction, and behavioral information to detect suspicious activity, unauthorized access, fraud, abuse, account takeover attempts, automated attacks, and other security threats.

This may include analyzing login attempts, device information, IP addresses, transaction patterns, account activity, and other security signals.

Security-related processing may occur without separate consent where permitted by applicable law because it is necessary to protect the Platform and its users.

Automated Systems

We may use automated systems to assist with security monitoring, fraud detection, account protection, service reliability, content moderation, or other Platform operations.

Where applicable law provides rights concerning solely automated decision-making or profiling, we will provide the rights and safeguards required by that law.

User-Generated Content

If the Platform allows users to upload photographs, videos, documents, comments, messages, profile information, or other content, we may process and store that content to provide the relevant functionality.

Users are responsible for ensuring that content they upload does not violate applicable law, intellectual property rights, privacy rights, or Platform rules.

We may remove or restrict content where permitted or required under applicable law or our policies.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal requirements, security practices, or business operations.

When we make material changes, we may provide an appropriate notice through the Platform or another reasonable communication method.

The "Last Updated" date and version number displayed on this page indicate when the Privacy Policy was most recently updated.

Where required by applicable law, we may provide additional notice or obtain renewed consent before implementing material changes that require consent.

Contact Us

If you have questions about this Privacy Policy, wish to exercise an applicable privacy right, or have concerns about how your personal information is collected, used, stored, or processed, please contact us using the official contact information provided by True Fan Pass. For privacy-related questions or requests, you may contact our support team at: Email: [email protected] We will review and respond to privacy-related inquiries within the timeframe required by applicable law.