Privacy Policy
Supreme Networking LLC, doing business as Promura ("Promura," "we," "us," or "our"), respects your privacy. This Privacy Policy explains what information we collect, how we use it, who we share it with, and the choices you have. It applies to promura.com and any service that links to this Policy (collectively, the "Service").
By using the Service, you confirm you are at least eighteen (18) years old and you agree to the practices described here. If you do not agree, do not use the Service.
1. Who we are
The data controller is Supreme Networking LLC, an Arizona limited liability company doing business as Promura. You can reach us at privacy@promura.com.
2. Information we collect
2.1 Information you provide
- Account information: email address, display name, password (hashed), date of birth, and any profile data you choose to add.
- Identity & age verification: if you apply to be a creator, we collect government-issued photo ID, a selfie holding the ID, and the IRS Form W-9 / W-8BEN required for tax reporting. We retain age-verification records under 18 U.S.C. § 2257 (see our 2257 Compliance Statement).
- Payment information: billing address and the last four digits of your payment method. Full card numbers are handled exclusively by our PCI-DSS compliant payment processors (Stripe and others); we never see them.
- Content you create: photos, videos, captions, messages, comments, tips, and any metadata you attach.
- Communications: emails, chat transcripts, support tickets.
2.2 Information we collect automatically
- Device data: IP address, browser, operating system, device identifiers, and approximate location derived from IP.
- Usage data: pages viewed, features used, search queries, referrer URLs, and timestamps.
- Cookies and similar technologies. See Section 8.
2.3 Information from third parties
- Payment processors confirm whether a transaction succeeded or failed.
- Identity-verification providers confirm the validity of submitted ID documents.
- Anti-fraud services may share signals about suspicious activity.
3. How we use your information
We use your information to:
- Operate, maintain, and improve the Service.
- Verify age, identity, and eligibility for creator participation.
- Process payments, payouts, and tax reporting.
- Personalize content recommendations and surface creators you may enjoy.
- Send transactional emails (e.g., receipts, security alerts) and, where permitted, marketing emails you can unsubscribe from.
- Detect, investigate, and prevent fraud, abuse, harassment, illegal content, and security incidents.
- Respond to legal requests, court orders, and lawful subpoenas.
- Comply with our obligations under U.S. federal and state law and applicable foreign law.
4. Legal bases (EEA / UK users)
If you are in the European Economic Area or the United Kingdom, we process your personal data under one of the following legal bases:
- Contract: to provide the Service you have requested.
- Legitimate interests: to keep the Service safe, prevent fraud, and improve product quality.
- Legal obligation: to comply with tax, anti-money-laundering, and 2257 record-keeping laws.
- Consent: for marketing communications and certain optional cookies. You may withdraw consent at any time.
5. How we share information
We do not sell your personal data. We share information only with:
- Service providers who run our infrastructure, payments, email, video hosting (Bunny), and analytics, under contracts that restrict use to providing the service.
- Creators and other users when you publicly interact with them (e.g., subscribing, tipping, commenting). Profile information visible to other users is limited to your display name, avatar, and badges; your email and payment details are never shared.
- Law enforcement and regulators when required by valid legal process, or when we believe disclosure is necessary to prevent imminent harm.
- Successors in the event of a merger, acquisition, or sale of all or part of our business.
6. International transfers
Promura is operated from the United States. If you access the Service from outside the U.S., your information will be transferred to, stored in, and processed in the United States and other countries where our service providers operate. These countries may have data-protection laws that differ from your country.
7. Data retention
We keep account information for as long as your account is active. After deletion, we retain limited records as required by tax, financial, and 2257 record-keeping law (which can require retention for seven (7) years or longer for certain documents). Anonymized analytics data may be retained indefinitely.
8. Cookies
We use first-party cookies to keep you signed in, remember your preferences, and measure how the Service is used. We use a small number of third-party cookies for fraud prevention and analytics. You can control cookies through your browser settings; disabling all cookies will prevent core features from working.
9. Your rights
Depending on where you live, you may have the right to:
- Access the personal data we hold about you.
- Correct inaccurate data.
- Delete your data, subject to legal retention requirements.
- Export your data in a portable format.
- Object to or restrict certain processing.
- Lodge a complaint with your local data-protection authority.
- For California residents, opt out of any "sale" or "sharing" of personal information as defined under the CCPA / CPRA. We do not sell or share personal information for cross-context behavioral advertising.
To exercise these rights, email privacy@promura.com. We will verify your identity before responding and will respond within the timeframes required by applicable law.
10. Security
We use industry-standard administrative, technical, and physical safeguards to protect your information, including TLS in transit, encryption at rest for sensitive fields, hashed passwords, and rate-limited authentication. No system is perfectly secure, however, and we cannot guarantee absolute security.
11. Children
Promura is for adults only. The Service is not directed to anyone under eighteen (18). We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, contact privacy@promura.com and we will delete it.
12. Changes to this Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, for material changes, post a notice in the Service or email account holders. Your continued use of the Service after the effective date constitutes acceptance of the revised Policy.
13. Contact
Questions about this Policy? Email privacy@promura.com or write to:
Supreme Networking LLC, dba Promura
Attn: Privacy
[Mailing address — update before launch]
[City, State ZIP]