Privacy policy
What we collect, why, who sees it, how long we keep it, and your rights. Last updated [date].
Draft. This policy must be reviewed by a lawyer for each country BOOA operates in before launch.
Who we are
BOOA of Management (“BOOA”, “we”) is [legal company name, registration number, registered address]. We are responsible for the personal information described here. Contact us about privacy at [privacy email address].
What we collect
When you apply as a creator
Your answers to the application questions, your first name, email address, preferred contact method and handle, and any page link you choose to share.
When we work together
Information needed to manage your page: your earnings statements, account settings, content plans, your voice guide and boundaries list, messages sent on your behalf, and the records needed to verify your age and the age and consent of anyone in your content.
When you apply for a job or refer a creator
The details you enter in those forms.
When you visit this website
Basic technical information such as pages viewed and approximate location, collected by our website platform for statistics and security, and form submissions screened for spam. [List any analytics or advertising tools added later.]
Sensitive information
Because of the work we do, some information we hold may reveal details about your sex life. We treat it as sensitive, collect only what we need, ask for your explicit consent where the law requires it, and limit it to the people who need it to manage your page.
Why we use it
- To review your application and reply to you (based on your consent).
- To provide management services under our contract with you.
- To meet legal duties, such as age verification, record keeping and tax.
- To keep our website and services secure (our legitimate interests).
We never sell your personal information, and we never share it for advertising.
Who sees it
Only BOOA staff who need it for their role, and service providers who help us run the business under contracts that protect your information, including our website host [and email, storage, verification and accounting providers]. Some providers and team members may be outside your country; where that happens, we use legal safeguards for the transfer. [Name the safeguards, e.g. standard contractual clauses.]
How long we keep it
- Applications that don’t lead to working together: deleted after [90 days].
- Creator records: for the length of our contract plus [X years] for accounting and legal claims.
- Age and consent records: as long as the law requires.
Your rights
Depending on where you live, you can ask to see, correct, delete or move your information, object to how we use it, withdraw consent at any time, and limit how we use sensitive information. California residents have the right to know, delete, correct and limit the use of sensitive personal information, and we do not sell or share personal information. To make a request, email [privacy email address]. You can also complain to your data protection authority, such as the UK Information Commissioner’s Office.
Security
We use access controls, encryption where available, and the least access each person needs. If a breach affects you, we’ll tell you as the law requires.
Adults only
Our services and this website are for adults aged 18 and over. We do not knowingly collect information from anyone younger.
Changes
If we change this policy, we’ll update the date at the top and, for significant changes, tell creators directly.