PeepsFit Privacy Policy

This Policy is available in Portuguese, English and Spanish. If the versions differ, the English version prevails, without affecting the rights that the law of your country guarantees you.

1. Who is responsible for your data

1.1. The data controller is Solugital LLC, a limited liability company organized under the laws of the State of Wyoming, United States, with its address at 9169 W State St #1834, Garden City, Idaho 83714, United States.

1.2. Data Protection Officer ("encarregado") under the Brazilian General Data Protection Law (LGPD): Raphael de Oliveira Silva, by e-mail at [email protected].

1.3. This Policy applies to the peeps.fit website, the app, payments, support (including the Peeps assistant) and PeepsFit's e-mails. Capitalized terms have the meaning defined in the Terms of Use. The website's LGPD and GDPR (the European Union's General Data Protection Regulation) pages complement this Policy; if they say something different, such as a different e-mail address for requests, this Policy prevails.

2. What data we collect

2.1. Sign-up: name, e-mail address, password (stored only in the form of an irreversible code) and the browser language. The username is generated automatically and can be changed. We also record each acceptance of the Terms of Use, of this Policy and, for Creators, of the Creator Agreement: the version, the language, the date and time, the IP address, the browser and the screen on which you accepted.

2.2. Login with Google or Facebook: the name, the e-mail address and the identifier of the account on that service.

2.3. Profile: photo, cover image, name, bio, city or state, country, website, social networks and your settings; and, if you choose to provide them, pronouns, gender and date of birth (the date is required in Creator verification). The date of birth does not appear on the public profile.

2.4. Creators:

• verification: photos of the identity document (front and back), a selfie holding the document, the legal name and the date of birth;
• payout details: account holder, bank, account number, bank codes (such as routing, SWIFT or IBAN), account type and country, stored encrypted;
• tax information, when the law requires it.

2.5. Payments:

• the amount, type, status and Stripe identifiers of the payment;
• billing details for the invoice: name, address, city, state, postal code and country;
• the Wallet statement: each top-up, purchase, earning, withdrawal, credit, refund and reversal, with the date, the amount and the IP address of whoever made the transaction;
• refunds, payment disputes and debt payments.

The card number is entered on Stripe's page and is not kept by us.

2.6. Content and interactions:

• posts, media, stories, reels and comments;
• messages (text, photo, video and audio);
• live stream chat;
• likes, followers, subscriptions, purchases, tips, reports and the stories and reels you viewed.

Live streams are broadcast in real time and are not recorded. Stories expire in 24 hours, except those you save to Highlights.

2.7. Security and usage:

• the IP address of the last login and the date and time of the last activity on the Account;
• the access log: the IP address, the date and the time of accesses to your Account;
• the IP address and the browser of each device confirmed in two-factor authentication, if you use it;
• the browser and the delivery address of push notifications, if you turn them on;
• password and e-mail changes, changes to the payout account and the turning off of two-factor authentication, with the IP address (also notified to you by e-mail);
• the IP address of whoever took each step in the histories of subscriptions, disputes, refunds and closures;
• if your Account is suspended: the reason, the team's internal note and the suspension history;
• cookies, described in clause 15.

2.8. Support:

• the e-mails exchanged with our team;
• what you send through the website's contact form: name, e-mail address, phone number (if you provide it) and the message;
• the messages you write in the website's Peeps assistant and, if it forwards your case to our team, the name and the e-mail address you provide;
• on the Portuguese-language website, the conversations through WhatsApp;
• in calls to our phone number (shown on the English and Spanish versions of the website), your phone number and what you tell us.

2.9. What we do not collect:

• the date of birth at sign-up;
• your precise location;
• card details: neither the number nor the last digits.

3. What we use the data for, and on what legal basis

4. Sensitive data

4.1. Fitness content may reveal health data, such as weight, injuries or diet. PeepsFit does not require you to publish this data; whoever publishes decides what to show. We recommend not exposing more than necessary, especially in public areas.

4.2. Creator verification is done by a person on our team, who compares the selfie with the document, without automated facial recognition.

5. What is public and what Creators see

5.1. The profile is public: name, username, photo, cover image, bio, city or state, website, pronouns, social networks, month and year of joining, number of likes and followers, and badges. Search engines may show the public profile, and old copies may remain in them and in link previews for a while, beyond our control. A private profile is hidden from visitors and from search engines. The profile and content of a suspended Account are taken offline for those who have not paid for them; those who paid can still see what they paid for.

5.2. Paid content is not public: those without access see only a blurred preview of the media; the text of the post or message may be visible.

5.3. A Creator sees, about their Fans, the display name (which, with Google or Facebook login, may be the real name), the username, the photo and the public profile, as well as the purchases, the tips and the messages exchanged with the Creator. A Creator never sees the e-mail, card or address of Fans.

5.4. A Creator may not use Fans' data outside PeepsFit, or for purposes that the Fans have not authorized.

5.5. Our team of administrators has access, through the PeepsFit panel, to Account data, including messages. The team does not read messages routinely: it consults them only when necessary to review a report, fraud, a payment dispute, a security risk or a request from you, or to comply with the law. To provide support, moderate and maintain security, the team may alter or remove messages and content and may enter your Account and act in it, at your request or when necessary for security. Each entry into your Account is recorded.

6. Who we share data with

6.1. We do not sell your personal data. We share it only with the service providers that help us operate PeepsFit, to the extent necessary:

6.2. We may also share data:

• with authorities, when there is a valid order or legal obligation;
• with the payment provider and the bank, to defend a disputed charge (payment and access data);
• with lawyers, accountants and auditors, under a duty of confidentiality;
• in the event of a reorganization, merger or sale of the company, with protection equivalent to that of this Policy.

7. Data processed in other countries

7.1. Solugital is in the United States. When you use PeepsFit, your data is sent directly to us and processed in the United States and in the countries where our service providers are located.

7.2. For transfers to service providers, we use the safeguards provided for in the applicable law, such as the standard contractual clauses that these providers offer for international transfers.

8. How long we keep data

8.1. While the Account exists, we keep the data needed for it to work, including during a suspension. Stories go offline in 24 hours, except those you save to Highlights. Live streams are not recorded. Creator verification documents, even from a refused verification, are kept while the Account exists and, after closure, for the period in clause 8.3.

8.2. When the Account is closed:

• it is anonymized: the username and the e-mail address are replaced;
• the content, media, followers, profile and billing data, confirmed devices and push notification subscriptions are deleted;
• the text messages you sent remain in the conversation of those who received them, without identifying you.

8.3. We keep the following for 5 years after closure, with access restricted to administrators, and longer if there is a dispute, an investigation or a legal obligation:

• verification documents;
• tax information and the registered payout accounts;
• the closure request and its reason;
• the record of your acceptances of the documents;
• an encrypted record of the original name, e-mail address and username.

At the end of the period, this data is deleted, and only a minimal record of the closure remains (the protocol number and the dates).

8.4. Financial records (sales, subscriptions, invoices, withdrawals, including the bank details used in each, receipts and the Wallet statement), the histories of subscriptions, disputes, refunds and suspensions, and reports are kept for as long as necessary to comply with legal, tax and accounting obligations, prevent fraud and defend rights, including after those 5 years.

8.5. An Account with no history of payments, verification or suspension is permanently deleted after the waiting period. The other Accounts are closed as described in this clause.

8.6. The access log (clause 2.7) is kept for 6 months, as required by Brazilian law (the Marco Civil da Internet, Brazil's Internet Civil Rights Framework, art. 15), also after the closure or deletion of the Account, and longer if an authority requests it. The other technical and security records of the system (logs) are kept for up to 6 months, and longer when they are needed to investigate an incident, fraud or a dispute.

8.7. Deleted data may remain in backups for up to 90 days, until the backups are replaced. A copy kept separately to investigate a security incident is kept only as long as the investigation requires.

9. Security

9.1. We use technical and organizational measures proportionate to the risk, such as:

• a secure connection (HTTPS);
• passwords stored only as an irreversible code;
• payout details and the original data of closed Accounts stored encrypted;
• two-factor authentication, mandatory for the team and optional for you;
• expiring media links;
• access to verification documents only for administrators, through 15-minute links;
• a record of each access to the stored data of closed Accounts and of each time the team enters a User's Account.

9.2. No system is completely secure.

10. Incidents

If there is a security incident involving your data, we will assess it, contain it and report it to the authorities and to the affected people when the law requires.

11. Rules applied automatically

11.1. Some rules are applied by the system, without prior human review:

• the block on new purchases by anyone with an open or lost payment dispute, until our team lifts it (it is lifted automatically if the dispute ends in our favor);
• the 15 days during which Creators' earnings stay "pending release";
• withdrawal limits and pauses, and the rule that only sales earnings already released can be withdrawn, with one open request at a time;
• the lock on content already purchased: its media does not change, and the Creator cannot delete it;
• the pause of access when a subscription renewal is declined;
• the blocking of links to prohibited addresses;
• usage limits.

11.2. You can ask for one of these decisions to be reviewed by a person, through the contact in clause 16. The suspension of an Account is never automatic: it is always decided by a person on our team.

12. Artificial intelligence

12.1. The app does not use artificial intelligence on your content. The website's Peeps assistant uses OpenAI to answer questions based on our Help Center. When the assistant forwards a case to our team, your name, your e-mail address, the summary and the conversation reach our support e-mail; on the Portuguese-language website, the case is forwarded through WhatsApp, with the summary. Do not write passwords, card numbers, documents or health data in the assistant.

12.2. We do not use your content to train artificial intelligence models.

13. Your rights

13.1. In Brazil (LGPD), you can request:

• confirmation that we process your data, and access to it;
• correction;
• anonymization, blocking or deletion of unnecessary or excessive data;
• portability;
• information about who we share data with;
• revocation of consent;
• objection to processing;
• review of automated decisions.

You can also file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD), Brazil's National Data Protection Authority.

13.2. In the European Union and the United Kingdom (GDPR), you can request:

• access;
• rectification;
• erasure;
• restriction of processing;
• portability;
• objection;
• review of an automated decision by a person (clause 11);
• withdrawal of consent.

You can also file a complaint with the data protection authority of your country.

13.3. How to make a request:

• Write to [email protected]. We may ask for proof of identity proportionate to the request. Your representative can also make the request, with a power of attorney.
• We will respond within the time limit set by the applicable law. If we cannot fulfill a request, for example because the law requires us to keep financial records, we will explain why.
• Exercising a right never puts you at a disadvantage.

13.4. To close your Account, use the Danger zone (clause 16 of the Terms of Use). To change your cookie choices, use the "Cookie preferences" link in the footer of the website and the app.

14. Minors

PeepsFit is not intended for anyone under 18 (or under the age of majority in the User's country, if higher). By creating an Account, you confirm that you are 18 or older. We may receive some data from a visitor before we know their age. If we identify an Account belonging to a minor, it will be suspended and closed, and the data will be deleted, except what the law requires or allows us to keep. Showing an identifiable minor in any content (posts, live streams, stories, reels and messages) is also prohibited; such content is removed.

15. Cookies

We use necessary cookies for login, security and your preferences, such as language. Only with your consent, given separately for each category, do we use statistics cookies (Google Analytics) and marketing cookies (the Meta Pixel, which measures our ads). Both categories start turned off. Your choice is stored in your browser for 182 days, in the cc_cookie cookie, and applies to the website and the app. You can change it at any time through the "Cookie preferences" link in the footer of the website and the app. Google and Meta also process this data under their own privacy policies. The Cookie Policy provides more details; if it says something different, this Policy prevails.

16. Changes and contact

16.1. Changes to this Policy are published with a new version and a new date. Important changes will be announced at least 15 days in advance, by e-mail or on PeepsFit, and the new version appears on the screen the next time you access PeepsFit. Previous versions are available at peeps.fit/legal/privacy.

16.2. Contact:

• Solugital LLC · 9169 W State St #1834, Garden City, Idaho 83714, United States
• Privacy and LGPD Data Protection Officer (encarregado): [email protected]
• Support: [email protected]