Privacy Policy

Effective Date: April 9, 2025

APHI LLC (“Heyheyy,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with the practices described in this Privacy Policy.

This policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit or use the Heyheyy platform (our “Website” or “Platform”), including any data you may provide when you sign up, buy or sell digital content, post content, or use interactive services. This policy applies to the personal data collected through our Platform, regardless of where you are located.

This Platform may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services, and we encourage you to read their privacy policies carefully.

Please read this policy carefully. By engaging with our Platform, you accept and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Continuing to engage with our Platform after any revisions means that you accept and consent to those changes.

1. Data We May Collect About You

“Personal data” (or “personal information”) means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Depending on whether you are a seller (creator) or buyer, we collect and use various types of data from and about you, grouped as follows:

• Identity Data: Legal name, username, government-issued photo ID (e.g., driver’s license or passport), date of birth, gender, selfie photo, and any voice or image in content you upload.
• Contact Data: Postal address, email address, and telephone numbers.
• Location Data: City and state/province, if you voluntarily provide them.
• Financial Data: Bank or payment account details (note that we typically do not collect or store full payment card details, as transactions happen via third-party processors).
• Transaction Data: Details of payments and other content or services bought or sold (including tips), to the extent such data is shared with us by you or the payment processor.
• Technical Data: Internet protocol (IP) address, ISP name, browser type/version, time zone settings, operating system, platform, and other technology details for devices used to access our Platform.
• Device Data: Device type, unique device identifiers (e.g., IMEI, MAC address), mobile network info, operating system, browser type, IP address, and time zone setting.
• Content Data: Photos, videos, audio, text (e.g., comments, hashtags), metadata, emojis, GIFs, memes, and other material you upload or create.
• Profile Data: Username, password, account settings, interests, preferences, feedback, survey responses, and any special or sensitive information (e.g., related to sexuality) that you voluntarily provide.
• Usage Data: Information about how you use our Platform, such as pages viewed or navigation paths.
• Marketing and Communications Data: Your preferences for marketing communications, including how you want to be contacted.

We also collect, use, and share Aggregated Data (statistical or demographic data) for any purpose. Aggregated Data does not directly identify you unless it’s combined with personal data.

We do not generally collect Special Categories of Personal Data (e.g., race, religious beliefs) unless you choose to provide them. We do not collect information about criminal convictions/offenses unless required by law or necessary for verification.

If You Fail to Provide Personal Data

Where we need personal data to comply with a legal or contractual requirement and you fail to provide it, we may not be able to perform our contractual obligations (e.g., enabling certain Platform features). We will inform you if this arises.

2. How We Collect Data About You

We use various methods to collect data from and about you:

1. Direct Interactions: You may give us data by filling in forms or corresponding with us (e.g., email). This includes data provided when you sign up, create a profile, buy/sell content, request marketing, enter contests, or report problems.
2. Automated Technologies/Interactions: As you interact with our Platform, we may automatically collect Technical/Device Data through cookies, server logs, and other similar technologies. We may also collect data about your online activities over time and across third-party sites (behavioral tracking).
3. Third Parties or Publicly Available Sources: We may receive personal data about you from analytics providers, payment processors, or identity verification services. We do not store your full payment card details; these are handled by third-party providers.
4. User Contributions: You may provide Content Data to be displayed publicly or shared with others. You submit such data at your own risk. We cannot guarantee that unauthorized persons will not view it.

Cookies and Automatic Data Collection Technologies

Our Platform uses cookies (small files placed on your device) or similar technologies to enhance user experience, store preferences, and analyze usage. You may refuse cookies in your browser settings, but this may affect certain Platform functionalities.

We may also use web beacons (clear gifs, pixel tags) to help count users or compile statistics on how our Platform is used.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on our Platform are served by third parties (advertisers, analytics providers, etc.). These parties may use cookies or similar technologies to collect data about you for interest-based advertising. We do not control these tracking technologies; contact them directly if you have questions or concerns.

3. How We Use Your Personal Data

We use your personal data to:

• Verify your identity, age, and eligibility for adult features.
• Provide, operate, and improve our Platform.
• Fulfill contractual obligations (e.g., delivering requested services or content).
• Handle payments, tips, and other transactions if data is shared with us by payment processors.
• Respond to support requests or legal obligations.
• Personalize your experience and recommend content.
• Ensure Platform security, detect and prevent fraud or illegal activity, and comply with laws.
• Send you marketing or other communications (unless you opt out).
• Analyze usage patterns or troubleshoot issues.
• Enforce our Terms of Service or other agreements.

We may also use your personal data to contact you about third-party products or services that may interest you. If you do not wish us to use your data in this way, email [email protected] or adjust your user preferences (see Section 6).

We may use non-personal or aggregated data for any business purpose without restrictions.

4. Disclosure Of Your Personal Data

We may share your personal data with:

• Corporate Affiliates: Subsidiaries, affiliates, or holding companies helping operate Heyheyy.
• Service Providers/Partners: For identity verification, analytics, hosting, payment processing, email delivery, or support. They must keep the data confidential and use it only for contracted purposes.
• Parties You Direct Us To Share Data With: For example, if you publicly post content or link your account to external services.
• Legal/Business Transfers: In the event of mergers, acquisitions, or sales of assets, your data may be transferred to the buyer or successor.
• Compliance/Harm Prevention: To comply with laws, respond to court orders, or protect the rights, property, or safety of our business, employees, customers, or others.

We may share non-personal or aggregated data for any purpose without restriction.

5. Consent to Personal Data Transfer

We are located in the United States. Your personal data may be processed or stored outside your country of residence, in jurisdictions that may have different data protection laws.

By providing personal data or using our Platform, you consent to these transfers. Where required by law, we will take steps (such as standard contractual clauses) to ensure adequate protection for your data.

• Canadian Residents: Your data may be accessible to foreign law enforcement or other authorities under legal orders.
• EEA/UK Residents: We implement safeguards to ensure your data is protected when transferred outside these areas.

6. Your Personal Data Use Choices

You have options regarding how we use your personal data:

1. Promotional Communications: If you do not wish to receive marketing communications from us, opt out via your account settings or email [email protected]. You will still receive service-related notices (e.g., account, transaction).
2. Cookies and Tracking: You can block cookies in your browser settings, but some Platform features may not function properly if you do.

Some third parties may collect data about you for targeted advertising. You should consult their privacy policies or opt-out mechanisms directly.

7. Accessing and Correcting Your Personal Data

You can review and edit most of your personal data by logging into your account and updating your profile. To request deletion or withdraw consent, email [email protected].

We may decline requests that violate any law or legal requirement, infringe others’ rights, or are unreasonably repetitive. We may retain copies of your data in backups or archives for legitimate business purposes or as required by law.

8. Data Security

We have implemented measures to protect your personal data from accidental loss and unauthorized access, use, or disclosure. However, the internet is not entirely secure, and we cannot guarantee your data’s complete security during transmission. Protect your login credentials and notify us if you suspect unauthorized access.

9. Data Retention

We retain personal data as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting obligations. Afterward, we may either delete or anonymize the data.

10. Withdrawing Your Consent

If you have given consent to certain data processing, you can withdraw it at any time by emailing [email protected]. Withdrawing consent may limit your ability to access certain Platform features.

11. Children’s Online Privacy

Our Platform is not directed to minors under 18, and we do not knowingly collect personal data from them. If you believe we have collected data from a minor under 18, please email [email protected], and we will remove it.

12. Do Not Track Policy

We do not respond to Do Not Track (DNT) signals because there is no industry-standard approach for DNT. Learn more at allaboutdnt.com.

13. Your California Rights

California residents may have additional privacy rights. Contact us at [email protected] for details.

California Civil Code § 1798.83 allows users to request information about our disclosure of personal data to third parties for direct marketing. Submit such requests to [email protected].

14. Your Nevada Rights

Nevada residents can opt out of certain personal data “sales” under state law. Currently, we do not sell data in a manner that triggers this. You may still submit a request to [email protected].

15. Your EEA/UK Privacy Rights

If you reside in the EEA, Switzerland, or the UK, you have the right to:

• Request Access to your personal data (Data Subject Access Request).
• Request Correction of inaccurate data.
• Request Erasure under certain conditions.
• Object to Processing, especially where we rely on legitimate interests.
• Request Restriction of processing in specific circumstances.
• Request Transfer of your data to you or a third party in a structured format.
• Withdraw Consent at any time where processing is based on consent.

To exercise these rights, email [email protected]. We may require additional info to verify your identity.

16. Changes to Our Privacy Policy

It is our policy to post any changes on this page. If we make material changes, we may also notify you via email or a notice on our Platform. The “Effective Date” at the top reflects the latest revision date. By continuing to use our Platform after changes are posted, you agree to the updated policy.

17. Contact Information and Challenging Compliance

If you have questions or comments about this Privacy Policy, contact:

APHI LLC
Email: [email protected]

If you believe we have not resolved your privacy concerns, you may have the right to contact a data protection authority. We will address your concerns as quickly as possible.

Thank you for choosing Heyheyy. We value your trust and are committed to protecting your personal data.