Privacy Policy

1.1 Controller
The controller responsible for the processing of personal data under applicable privacy laws, including — where applicable — the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act as amended by the CPRA (CCPA/CPRA), is:

Flixsell LLC (FLIXSELL LIMITED LIABILITY COMPANY), a limited liability company organized under the laws of the State of Wyoming, USA, business address: 30 N Gould St Ste N, Sheridan, Wyoming 82801, USA. Registration authority: Secretary of State, State of Wyoming. Represented by: Justin Leon Schwan, Managing Member. Email: support@flixsell.com.

1.2 Scope
This Privacy Policy applies to:

• the FlixSell platform at flixsell.com and related applications (App Store, Google Play, web application);
• the Creator area at app.flixsell.com;
• the official Partner Program at partners.flixsell.com;
• all related services, download pages, support, and communication channels of FlixSell.

1.3 Data Minimization
Personal data means any information relating to an identified or identifiable natural person. We follow the principle of data minimization and collect only as much personal data as is reasonably necessary.

1.4 Applicable Law
Because the controller is established in the United States (Wyoming), our processing is governed by applicable U.S. federal and state law. Where we offer services to individuals in the EU/EEA or monitor their behavior, the GDPR also applies. Where the CCPA/CPRA or other U.S. state privacy laws apply, their additional rights and obligations apply as well.

1.5 Whose Data We Process
Uploader / Creator (Seller): account, identity/age-verification, and payout data. Downloader / Buyer: age verification, purchase, and payment data. Persons depicted in content: identity and consent documentation. Partner (Affiliate): partner account data, tracking, commission, and payout data, as well as communications data in connection with the Partner Program.

3.1 Legal Bases
Where the GDPR applies: performance of a contract (Art. 6(1)(b)), consent (Art. 6(1)(a)), legal obligation (Art. 6(1)(c)), or legitimate interests (Art. 6(1)(f)). Under U.S. law we process data to provide the services, for compliance, fraud and abuse prevention, and on the basis of consent or other lawful grounds. We engage processors under appropriate contracts.

3.2 Platform (flixsell.com)
Depending on use, we may process: email and login credentials; device type, IP address, usage and log data; time zone and country of origin; uploaded media and content; bank and transaction data; identity and age-verification data; consent documentation for depicted persons.

3.3 Creator Area (app.flixsell.com)
In the protected Creator Area, Creator and Buyer data are processed as needed to manage sales, payouts, support, and compliance. A Creator’s KYC and identity data are specially protected and are never sold to third parties or used for advertising purposes by third parties.

3.4 Partner Program (partners.flixsell.com)
Additionally or specifically for Partners we process: partner account and contact data; tracking IDs, referral links, and cookie attributions; commission and payout data; bank and tax information (e.g., W-9 / W-8BEN); support communications; identity-verification details.

3.5 Email Communications with Buyers
By purchasing a product through FlixSell, the Buyer accepts that they may be contacted by email. This includes in particular:

• system and transactional emails from FlixSell (e.g., purchase confirmation, download instructions);
• reminder emails after an abandoned purchase (cart/checkout abandonment);
• promotional messages from FlixSell;
• promotional messages from Creators on FlixSell (e.g., via the “broadcast email” feature), to the extent permitted by law.

Where the GDPR applies, the legal basis is, depending on the case, performance of a contract, legitimate interests, or consent. Where a right to object or opt out is provided by law, the Buyer may exercise it.

3.6 Usage Data / Log Files
When you visit the website or app, we collect technical information (IP address, time, device, browser, and where applicable the referrer). This is used for statistics, security, and abuse prevention and is not unnecessarily linked with other personal data.

4.1 Special Categories
The Platform is intended for adults and may include erotic or sexual content. Information about a person’s sex life may constitute a special category of personal data (Art. 9 GDPR) or sensitive data under U.S. law. Where we process such data, we do so on the basis of explicit consent or another legal basis and apply enhanced safeguards.

4.2 Age Verification
To confirm that Uploaders, depicted persons, and Downloaders are adults (18+), we and/or verification providers may process government-issued ID documents, date of birth, and verification results. ID documents are processed with restricted access and retained only as long as necessary.

4.3 Consent Documentation
Identity and consent records for depicted persons may be processed and retained for compliance, audit, and legal defense purposes.

5.1 Payment Service Providers
Payment data are transmitted to external payment service providers acting as independent controllers and/or processors (including, where applicable, Stripe and providers specialized in adult content).

5.2 Partner Payouts
Commissions and payouts to Partners are processed by Flixsell LLC. For this purpose we process the data required for bank transfer, self-billing, and tax reporting.

6.1 Platform
We use cookies and similar technologies for session management, security, consent storage, and — with consent where required — analytics and marketing. Functional cookies may include, among others, flixsell_age_confirmed (18+ confirmation, up to 365 days).

6.2 Partner Tracking
In the Partner Program we use tracking cookies or comparable technologies with a duration of 30 days to attribute registrations and revenue of referred Creators to the Partner. Details are set out in the Partner Terms.

6.3 Management
Cookies can be controlled via browser settings and, where offered, a cookie banner or preference center. Blocking strictly necessary cookies may impair login, checkout, or tracking.

6.4 Consent (Cookie Banner)
On flixsell.com, app.flixsell.com and partners.flixsell.com we ask you on your first visit whether we may use optional cookies and similar technologies for statistics and marketing. Your choice applies to all three websites. Without your consent, no scripts from Google or other analytics and advertising providers are loaded. We store your choice for 180 days in a cookie (fs_consent). You can change or withdraw it at any time via the “Cookie settings” link in the footer; the lawfulness of processing carried out until then remains unaffected. The legal basis is your consent (Art. 6(1)(a) GDPR; where applicable Section 25(1) of the German TDDDG); storing your choice itself is based on our legitimate interest in respecting your decision (Art. 6(1)(f) GDPR).

6.5 Google Analytics (Statistics)
If you agree to the “Statistics” category, we use Google Analytics 4 provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (for users outside the EEA: Google LLC, USA). Processed data include, among others, pages viewed, time on site, referring page, device and browser information, approximate location, and a pseudonymous identifier (cookies _ga and _ga_ plus our measurement ID, lifetime up to two years). Google Analytics 4 does not store IP addresses. We use the data to understand, in aggregate, how our website is used and to improve it. Event data are retained by Google for no longer than 14 months. Transfers to the USA rely on the safeguards described in Section 10.

6.6 Marketing (Google Ads, Meta, Snapchat)
If you agree to the “Marketing” category, we may load marketing and conversion tags of Google Ads (Google Ireland Limited), Meta (Meta Platforms Ireland Limited) and Snapchat (Snap Inc. or Snap Group Limited) through Google Tag Manager. We use them to measure the success of our advertising (for example a visit to the website or the start of a registration) and to show ads to people who are interested in FlixSell. Identifiers (for example cookies such as _gcl_au, _fbp or _scid) and event data are transmitted to the respective provider, which processes them under its own privacy terms. Without your consent to this category these tags are not loaded. We use Google Consent Mode: your choice is passed on to Google services and respected by them.

7.1 Sale and Disclosure of Customer Data
It is strictly prohibited to sell, rent, exchange, or otherwise use for commercial or unauthorized purposes any customer data (including data of Buyers, Creators, Partners, or other Users) obtained in connection with FlixSell, the Creator Area, or the Partner Program. Creators’ KYC and identity data are specially protected and are never shared by FlixSell with third parties. A breach of the prohibition on data disclosure by Users or Partners may have civil and criminal consequences and will result in immediate suspension and reporting to competent authorities where legally required.

7.2 Private Chats and Communications
Publishing, forwarding, or otherwise disclosing private chats, messages, or other confidential communications with customers, Creators, Partners, or FlixSell support is prohibited unless required by law or expressly authorized in writing by FlixSell. Violations may result in account suspension, commission freeze, and further legal action.

7.3 Consequences
FlixSell reserves the right to take all available contractual and legal measures for breaches of Section 7, including content deletion, suspension, withholding of balances, and claims for damages.

8.1 Principle
Personal data are retained only as long as necessary for the purpose of collection and thereafter only as long as required by law (tax, accounting, and compliance law).

8.2 Age and Consent Records
Age-verification evidence and consent/identity documentation are retained for at least seven (7) years or the period required by law and are then deleted or anonymized.

8.3 Partner Data
Partner account, commission, and payout data are retained for the duration of participation and the legally required periods thereafter. After irreversible account deletion, positive balances expire; data may continue to be stored for disputes, tax, and legal defense.

9.1 Measures
Data on our systems are protected by appropriate technical and organizational measures against loss, destruction, unauthorized access, alteration, and disclosure.

9.2 Breaches
In the event of a personal data breach that is likely to result in a risk to the rights of data subjects, we will notify the competent supervisory authority and, where required, the affected individuals in accordance with applicable law.

10.1 Processing in the USA
We are established in the United States and process data primarily there. Transfers from the EU/EEA, the United Kingdom, or Switzerland are based on appropriate safeguards (in particular the EU Standard Contractual Clauses, where applicable with UK Addendum / Swiss addendum) and, where relevant, providers certified under the EU-U.S. Data Privacy Framework.

11.1 Analytics and Technology
On flixsell.com, app.flixsell.com and partners.flixsell.com we use Google Analytics and Google Tag Manager with your consent (see the Cookies and Tracking section). Where used, services may also include Google Web Fonts, social login (Google, Meta, Apple), and Google Firebase — each under the providers’ privacy terms and, where legally required, with consent.

11.2 Payment and Verification Providers
External payment and age-verification providers process data under their own terms as controllers and/or processors.

11.3 Error Monitoring (Sentry)
To detect and fix technical errors and to maintain the stability and security of the Platform, we use the error-monitoring service Sentry (Functional Software, Inc., 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA) as a processor on flixsell.com, app.flixsell.com, partners.flixsell.com, and in our internal administration area. When an error occurs, technical information about the error is transmitted to Sentry, in particular the error message and location in the code, time, application version, browser or device type, and the page URL without parameters. Cookies, credentials, form and request contents, user identifiers, or session recordings are not transmitted; email addresses in error messages are redacted before transmission. Data are stored in the EU (Germany region) and typically retained for up to 90 days. Where the GDPR applies, the legal basis is our legitimate interest in stable and secure operation (Art. 6(1)(f) GDPR). Where data may be transferred to the USA (e.g., for support access), we rely on the safeguards under Section 10.1.

11.4 Technical Service Providers (Hosting, Security, Email)
For operation, security, and communications of the Platform we use the following providers. They process data on our behalf under processor agreements. Where data may be transferred to the USA, we rely on the safeguards under Section 10.1. Where the GDPR applies, the legal basis is performance of a contract (Art. 6(1)(b)) or our legitimate interest in secure and stable operation (Art. 6(1)(f)).

• Vercel Inc. (USA) — hosting and delivery. Our websites and applications are served via Vercel. Technically necessary data are processed, in particular IP address, requested page, time, and browser information. Application servers run in the EU (Frankfurt); content may be cached via a global delivery network.
• Supabase (database and authentication). Account and platform data (e.g., email address, password in encrypted form, products, orders, payout and verification data) are stored in a database with Supabase. The database is located in the EU (Frankfurt). Supabase also handles authentication (including optional two-factor authentication).
• Cloudflare, Inc. (USA) — file storage and bot protection. Uploaded files (e.g., product files, profile images, report attachments, and Creator ID/verification documents) are stored with Cloudflare (R2); access is limited to authorized persons and provided via time-limited links. We also use “Cloudflare Turnstile” on registration, login, and report forms to distinguish humans from automated access. This processes, among other things, IP address and technical browser information.
• Brevo (Sendinblue SAS, France) — email delivery. System and transactional emails (e.g., email confirmation, purchase confirmation, download instructions) and — where permitted — broadcast emails are sent via Brevo. Recipient email address, message content, and delivery data are processed.
• ZeroBounce (USA) — email address validation. Upon registration, the provided email address may be checked with ZeroBounce for deliverability to prevent invalid addresses and abuse.
• Whop — payment processing. Purchases are processed via the payment provider Whop. Payment data (e.g., card data) are entered by the Buyer directly with the payment provider and are not stored by us. Further information is set out in the payment provider’s privacy notice (see also Section 5.1).

12.1 Access, Rectification, Erasure, Restriction
Access to information about processing; rectification of inaccurate data; erasure where retention obligations do not apply; restriction of processing in the cases provided by law.

12.2 Data Portability and Objection
Where the GDPR applies: the right to data portability and the right to object to processing based on legitimate interests and to direct marketing.

12.3 Withdrawal of Consent
Where processing is based on consent, you may withdraw it at any time with effect for the future.

12.4 CCPA/CPRA (California)
Where applicable: access, deletion, correction, opt-out of sale/sharing, and non-discrimination. Requests to support@flixsell.com.

12.5 Complaint
You may lodge a complaint with the FTC, the Attorney General of your state, or — in the EU/EEA — your local supervisory authority.

13.1 Adults Only
The Platform and Partner Program are strictly limited to adults (18+). We do not knowingly collect data from minors and do not direct the service at children under 13 (COPPA). If we learn of such data, we delete it without undue delay.

14.1 Updates
We may update this Privacy Policy. The current version is published with a date on flixsell.com and partners.flixsell.com.

15.1 Privacy Requests
Flixsell LLC, 30 N Gould St Ste N, Sheridan, Wyoming 82801, USA; email: support@flixsell.com. Represented by Justin Leon Schwan, Managing Member.

Content reports and abuse: report@flixsell.com.