This Marketing Policy sets forth iFansy's official standards for promoting and representing its services, platform, and brand identity. It establishes clear expectations for ethical conduct, legal compliance, and responsible messaging in all promotional activities directed toward prospective Users, Creative Users (Creators), and the general public.

This Policy forms part of the broader iFansy legal framework and should be read in conjunction with the [iFansy Terms & Conditions], [Acceptable Use Policy], and other applicable policies. In the event of any conflict between this Policy and the iFansy Terms & Conditions, the provisions of this Policy shall prevail for the specific subject matter it governs.

Definitions

"Marketing Materials" refer to any advertisement, announcement, email, social media post, campaign asset, promotional video, or similar content produced by or on behalf of iFansy to market the Platform or its services.

"Affiliate or Referrer" means any User who promotes iFansy under an official partnership programme, including through the [Referral & Affiliate Policy] or other authorised promotional initiatives.

1. ETHICAL MARKETING AND LEGAL COMPLIANCE

1.1 Legal and Regulatory Commitment

iFansy is committed to conducting all marketing and promotional activities in accordance with applicable laws, advertising regulations, and consumer protection standards in the jurisdictions where such activities are directed. While iFansy makes best efforts to ensure compliance, it does not assume liability for the actions of third parties or affiliates acting outside the scope of authorised marketing materials and platform guidance.

1.2 Prohibited Marketing Practices

The following practices are strictly prohibited in all Marketing Materials, campaigns, or promotional communications:

• False, misleading, or exaggerated claims regarding earnings, performance, or services;
• Deceptive or manipulative tactics, including fabricated statistics or testimonials;
• Unsubstantiated guarantees or promises of success;
• Impersonation of iFansy, its representatives, or its verified Creators;
• Use of unauthorised logos, branding, or likenesses.

1.3 Accuracy and Verifiability

All marketing claims must be truthful, clearly substantiated, and accurately reflect the actual features, functionality, and scope of services provided by iFansy. Claims that cannot be supported by objective evidence may not be published.

2. TRANSPARENCY AND DISCLOSURE

2.1 Mandatory Disclosures

All Marketing Materials must clearly and accurately communicate, in a manner that is not misleading:

• The nature and purpose of the iFansy Platform;
• Any associated fees, subscriptions, or payment obligations;
• Direct access to key governing policies, including the [Privacy Policy], [Creator Terms], and [Acceptable Use Policy].

2.2 Sponsored and Affiliate Content

Where marketing content is promotional in nature—including content posted by influencers, affiliates, or Users participating in referral schemes—appropriate disclosures must be used (e.g., "#ad," "sponsored," or equivalent). These disclosures must comply with applicable advertising rules and regional laws, including:

• UK Advertising Standards Authority (ASA) Guidance;
• U.S. Federal Trade Commission (FTC) Endorsement Guidelines;
• Any other national or regional disclosure requirements applicable to the jurisdiction in which the promotion occurs.

2.3 Third-Party Responsibility

All Users, Affiliates, and Referrers promoting iFansy are individually responsible for ensuring their marketing practices comply with this Policy, the [Referral & Affiliate Policy], and all applicable advertising standards. iFansy disclaims all liability for any unauthorised, unlawful, or misleading representations made by third parties or Users acting outside the scope of authorised guidance.

2.4 Monitoring and Enforcement

iFansy reserves the right to audit, suspend, or revoke any User's or Affiliate's promotional privileges if it determines that marketing efforts are non-compliant, deceptive, or harmful to the integrity of the Platform.

3. RESPECT, DIVERSITY, AND REPRESENTATION

3.1 Inclusive Marketing Standards

iFansy strictly prohibits the use of discriminatory, derogatory, dehumanising, or exploitative imagery, language, or implications in any form of marketing or promotional activity.

3.2 Commitment to Representation and Fairness

All marketing campaigns must reflect iFansy's values of respect, inclusivity, and fair representation. Marketing content must not:

• Reinforce or perpetuate harmful stereotypes;
• Marginalise or exclude individuals or groups based on gender, race, ethnicity, nationality, religion, disability, sexual orientation, age, or socio-economic status;
• Promote unrealistic, harmful, or medically unsafe body ideals or behaviours.

3.3 Creative Responsibility

All individuals or entities involved in the production, distribution, or publication of iFansy marketing content—including third-party agencies, affiliates, and influencers—must comply with these standards and ensure that messaging aligns with iFansy's ethical brand values.

3.4 Violations and Remedial Action

iFansy reserves the right to remove or suspend any Marketing Materials, campaigns, or promotional privileges that violate this section. Repeated or serious breaches may result in account termination, contract cancellation, or referral to appropriate authorities.

4. PRIVACY AND CONSENT

4.1 Lawful Basis for Data Use

iFansy will not collect, use, or process any personal data for marketing purposes without a valid legal basis, as defined in the [Privacy Policy] and applicable data protection laws, including but not limited to the Personal Data (Privacy) Ordinance (Hong Kong Cap. 486), GDPR, and other relevant regional privacy frameworks.

4.2 Consent for Use of Creator Content

iFansy will not feature or publish any Creative User's content, likeness, name, branding, or media in public-facing Marketing Materials without one of the following:

• The Creator's prior, express written consent; or
• A valid licence agreement that explicitly permits such use for promotional purposes.

4.3 Opt-Out Rights

Users have the right to opt out of receiving direct marketing communications from iFansy. Opt-out mechanisms are provided through:

• Platform notification settings; and
• Unsubscribe links embedded in promotional emails.

4.4 Respecting Data Subject Rights

All data processing related to marketing activities shall observe the rights of data subjects, including the right to access, rectify, or erase their personal data, as further outlined in the [Privacy Policy].

5. COMMUNITY AND PLATFORM INTEGRITY

5.1 Prohibited Content and Conduct

All marketing activities must reflect iFansy's commitment to lawful, responsible, and ethical promotion. The following are strictly prohibited in any form of marketing, whether conducted by iFansy or third parties:

• Promotion of content, products, or services that violate the [Acceptable Use Policy];
• Advertising of illegal, fraudulent, deceptive, or exploitative schemes;
• Encouragement of off-platform transactions, including escorting, meetups, or other non-permitted third-party arrangements;
• Use of marketing channels to mislead, pressure, or otherwise endanger Users or the Platform community.

5.2 Platform Trust and Brand Representation

All promotional efforts must uphold the integrity, reputation, and safety of the iFansy brand. Marketing materials must not create false expectations, undermine user trust, or misrepresent the scope of services provided by iFansy.

5.3 Enforcement and Liability

iFansy reserves the right to investigate and take enforcement action against any User, Affiliate, or third party engaged in marketing practices that violate this Policy or applicable law. Actions may include removal of marketing privileges, account suspension, legal referral, or termination under [Terms & Conditions – Section 18].

iFansy is committed to upholding a safe, respectful, and transparent environment for all Users. This Complaints Policy outlines the procedures by which complaints concerning the Platform, User behaviour, uploaded Content, or moderation outcomes are submitted, investigated, and resolved.

This Policy forms part of iFansy's overarching legal framework and must be read in conjunction with the [iFansy Terms & Conditions], [Acceptable Use Policy], and other relevant policies. In the event of any conflict between this Policy and the Terms & Conditions, the provisions of this Policy shall govern solely with respect to the subject matter it addresses.

Definitions

"Complaint" refers to a formal report submitted to iFansy regarding specific Content, User conduct, moderation actions, or other Platform-related matters that are alleged to violate applicable iFansy policies.

"Appeal" refers to a request made by a User for iFansy to review and reconsider a prior enforcement action or decision rendered in response to a Complaint.

1. WHO MAY SUBMIT A COMPLAINT

1.1 GENERAL ELIGIBILITY

Any individual—whether a registered User of iFansy or a non-User—may submit a formal Complaint regarding activity occurring on the iFansy Platform.

1.2 USER AGREEMENT

All registered Users agree, as a condition of their use of the Platform, to abide by this Complaints Policy and to refrain from submitting false, abusive, or malicious Complaints. Misuse of the complaints process may result in enforcement actions under the [Terms & Conditions – Section 18 (Account Suspension and Termination)].

2. HOW TO SUBMIT A COMPLAINT

2.1 SUBMISSION CHANNELS

Complaints may be submitted through any of the following official methods:

• By emailing: support@ifansy.com;
• Via the live support function at help.ifansy.com;
• Through the in-platform "Report" feature available on User profiles, Content, messages, or media.

2.2 REQUIRED INFORMATION

To ensure efficient processing and resolution, Complaints should include the following:

• Full name and a valid contact email address;
• iFansy username or handle (if applicable);
• Identification of the User, Content, or incident involved;
• A clear description of the issue or alleged violation;
• Supporting materials, such as screenshots, URLs, recordings, or transcripts where relevant.

3. INVESTIGATION PROCESS

3.1 Case-by-Case Assessment

Each Complaint received by iFansy is reviewed and logged individually within the platform's internal moderation system. Complaints are assessed objectively, based on the facts and supporting evidence provided.

3.2 Standard Review Timeframe

iFansy aims to review and begin investigating all valid Complaints within 7 calendar days from the date of receipt. Delays may occur in complex or high-risk cases, but efforts will be made to maintain timely resolution.

3.3 Investigative Actions

During the investigation process, iFansy may take one or more of the following steps:

• Request additional information or evidence from the complainant;
• Notify and seek a response from the User who is the subject of the Complaint;
• Escalate the matter to a legal, compliance, or safety team if it involves criminal or high-risk content.

3.4 Fairness and Good Faith

All investigations are conducted in good faith and with respect for due process. iFansy is committed to treating all parties fairly and to reaching a resolution that reflects platform rules, community safety standards, and applicable law.

4. RESOLUTION

4.1 Enforcement Outcomes

If a Complaint is found to be valid following investigation, iFansy may take one or more enforcement actions, including but not limited to:

• Issuing a formal warning to the User in violation;
• Removing the offending Content;
• Temporarily suspending the User's account;
• Permanently terminating the account, in accordance with [iFansy Terms & Conditions – Section 18 (Account Suspension and Termination)].

4.2 Documentation of Outcome

Regardless of whether a Complaint is upheld or dismissed, iFansy will retain a formal record of the resolution. These records assist in monitoring repeat behaviour and improving platform safety processes.

4.3 Privacy and Disclosure Limitations

iFansy is not obligated to disclose detailed investigative findings or specific enforcement actions to the complainant, unless such disclosure is required by law or regulatory obligation. All actions are taken in accordance with the [Privacy Policy] and applicable data protection laws.

5. APPEALS

5.1 Right to Appeal

If a User account is subject to enforcement action resulting from a Complaint—such as content removal, suspension, or termination—that User has the right to submit an Appeal to iFansy. Appeals must be submitted within fourteen (14) calendar days of the enforcement notice.

5.2 Appeal Submission Requirements

Appeals must be directed to support@ifansy.com and should clearly include:

• The specific enforcement action being appealed;
• Any new evidence, context, or clarification not presented in the original Complaint investigation;
• A concise explanation detailing why the enforcement action should be reconsidered.

5.3 Appeal Review and Outcome

iFansy will assess Appeals in good faith and in accordance with applicable platform policies. While most Appeals are reviewed within a reasonable timeframe, Users will be notified if extended evaluation is required. Appeals submitted after the 14-day window may still be reviewed at iFansy's discretion, but are not guaranteed a formal response.

6. SPECIAL CASES

6.1 Criminal Conduct and Urgent Harm

In situations involving criminal activity, threats to personal safety, harassment, abuse, or exploitation, Users are strongly advised to report the matter directly to appropriate law enforcement authorities in their jurisdiction. Submitting a Complaint to iFansy does not replace formal legal reporting.

6.2 Intellectual Property Violations

If a Complaint concerns copyright infringement, content theft, or other intellectual property issues, Users must follow the procedures outlined in the [DMCA & Intellectual Property Policy]. iFansy will not process such claims under this general Complaints Policy.

7. MISUSE OF THIS POLICY

7.1 False or Malicious Complaints

Knowingly submitting false, misleading, abusive, or bad-faith Complaints is a violation of this Policy and may lead to enforcement action, including:

• Account warnings or restrictions;
• Temporary or permanent suspension;
• Termination under [iFansy Terms & Conditions – Section 18].

7.2 Abuse by Non-Users

Non-Users who repeatedly misuse the complaints process may be blocked from submitting further reports or interacting with iFansy support services.

This Privacy Policy explains how iFansy, operated by iFansy Limited, collects, uses, shares, and safeguards your personal data when you use our Platform and Services. We are committed to protecting your privacy and ensuring full compliance with applicable data protection laws, including but not limited to the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong), the UK General Data Protection Regulation (UK GDPR), and other relevant international privacy frameworks.

This Policy forms part of the broader iFansy legal framework and should be read in conjunction with the [iFansy Terms & Conditions], [Acceptable Use Policy], and other applicable policies. If there is any conflict between this Policy and the Terms & Conditions, the provisions of this Privacy Policy shall prevail only with respect to the subject matter it governs.

Unless otherwise stated, capitalised terms used in this Policy shall carry the same meanings as defined in the [iFansy Terms & Conditions].

iFansy Limited is the data controller of your personal data for all activities conducted through the iFansy Platform. For data protection matters, you may contact us at: privacy@ifansy.com

1. TYPES OF PERSONAL DATA WE COLLECT

We collect and process different types of personal data depending on how you interact with the iFansy Platform. This includes information you provide directly, data collected automatically, and information received from third parties.

1.1 Data You Provide Directly

• Identity Data – such as your full name, date of birth, nationality, or identification number.
• Contact Data – such as your email address, phone number, and mailing address.
• Payment Data – including billing address, credit/debit card information, bank details, or transaction identifiers.
• Verification Documents – submitted by Creators for identity and age verification (e.g., photo ID, liveness scans, or biometric data where applicable).
• User Communications – including messages sent to customer support, complaint submissions, or moderation queries.

1.2 Data We Collect Automatically

• Usage Data – such as login timestamps, content views, clicks, messages, and time spent on pages.
• Technical Data – including your IP address, browser type, device operating system, screen resolution, and mobile device identifiers.
• Location Data – derived from your IP address or device-based geolocation (if permitted).
• Session Data – such as navigation behavior, session duration, interaction patterns, and performance logs.

1.3 Data from Third Parties

We may receive additional personal data from third-party sources, including:

• Referral or Affiliate Partners – such as username, referral codes, or sign-up metadata.
• Identity Verification Providers – used to verify user age, authenticity, and detect fraud.
• Analytics and Advertising Partners – such as platform usage statistics, audience segmentation data, and cookie-matching results.

1.4 Data Combination and Enrichment

We may combine data from different sources to:

• Improve service functionality and user experience;
• Detect, investigate, or prevent fraudulent or abusive behavior;
• Tailor features, recommendations, and security protocols.

2. PURPOSES FOR PROCESSING YOUR PERSONAL DATA

We process your personal data for the following purposes in accordance with applicable legal bases:

We ensure that all processing of personal data is limited to what is necessary, proportionate, and aligned with your rights under this Privacy Policy and applicable data protection laws.

3. COOKIES AND TRACKING TECHNOLOGIES

We use Cookies and similar tracking technologies to operate, secure, enhance, and personalise your experience on the Platform.

These technologies help us:

• Recognise returning Users;
• Understand usage patterns and user behaviour;
• Deliver relevant content and advertising;
• Improve platform functionality and performance.

For full details on the types of Cookies we use, the purposes for which they are deployed, and how you can manage or withdraw your consent, please refer to our [Cookie Policy].

7. YOUR RIGHTS AS A DATA SUBJECT

7.1 Overview of Rights

As a data subject, you have the following rights under applicable data protection laws, including the Personal Data (Privacy) Ordinance (Cap. 486) in Hong Kong, and where applicable, the UK GDPR and EU GDPR:

• Right to Access – You may request a copy of the personal data we hold about you.
• Right to Rectification – You may request corrections to inaccurate or incomplete data.
• Right to Erasure – You may request deletion of your data, subject to applicable legal grounds.
• Right to Restrict Processing – You may request that we limit how we process your data.
• Right to Data Portability – Where applicable, you may request to receive your data in a structured, machine-readable format.
• Right to Object – You may object to certain types of processing, including direct marketing.
• Right to Withdraw Consent – If processing is based on consent, you may withdraw it at any time.
• Right to Lodge a Complaint – You may file a complaint with a supervisory authority.

7.2 How to Exercise Your Rights

To exercise any of the above rights, please contact us at: support@ifansy.com We may request additional verification to confirm your identity before processing your request. iFansy will respond in accordance with applicable legal timeframes.

7.3 Supervisory Authorities

If you are based in a jurisdiction with a designated data protection authority, you may also lodge a complaint directly with them. For example:

• Hong Kong: Office of the Privacy Commissioner for Personal Data (PCPD) – https://www.pcpd.org.hk
• United Kingdom: Information Commissioner's Office (ICO) – https://ico.org.uk
• European Union: Refer to your national data protection authority.

8. AGE RESTRICTIONS AND MINOR PROTECTION

8.1 Age Restriction

The iFansy Platform is strictly intended for individuals who are 18 years of age or older. Users under the age of 18 are prohibited from accessing or using the Platform, in accordance with iFansy's [Terms & Conditions] and applicable child protection laws.

8.2 No Collection of Data from Minors

iFansy does not knowingly collect, store, or process personal data from individuals under the age of 18. If we become aware that a minor has registered an account or submitted personal data, we will take appropriate steps to terminate the account and delete the data in accordance with our [Privacy Policy] and legal obligations.

8.3 Reporting Concerns

If you believe a User under the age of 18 is accessing the Platform or providing personal data, please report the matter immediately to: support@ifansy.com.

At iFansy, we are committed to protecting your privacy and being transparent about how we use Cookies and similar tracking technologies on our website and digital services. This Cookie Policy describes what Cookies are, how and why we use them, the categories of Cookies we deploy, and how you can manage your Cookie preferences.

This Policy forms part of the broader [Privacy Policy] and other applicable [iFansy Policies]. In the event of any inconsistency between this Policy and the [iFansy Terms & Conditions], the provisions of this Policy shall govern solely in relation to the subject matter it addresses.

Unless otherwise specified, capitalised terms used in this Policy shall have the meanings defined in the [iFansy Terms & Conditions].

DEFINITIONS

"Cookies" means small text files stored on your device that allow us to recognise your browser, retain user preferences, and track usage for analytics or advertising purposes.

"Session Cookies" means temporary cookies that are deleted automatically when you close your browser.

"Persistent Cookies" means cookies that remain on your device for a specified duration or until manually deleted by the user.

"Third-Party Cookies" means cookies placed by external services or providers that perform functions such as analytics, advertising, or customer support.

1. TYPES OF COOKIES WE USE

iFansy uses different categories of Cookies to operate and improve the Platform. These Cookies may be placed by iFansy directly or by authorised third-party service providers acting on our behalf.

4. MANAGING COOKIES

Most web browsers allow you to control how cookies are used on your device. You may choose to block all cookies, allow only certain types, or receive alerts when cookies are set.

Please note: Disabling certain types of cookies—particularly those that are strictly necessary—may impair website functionality or limit your experience on the iFansy Platform.

4.1 Browser Cookie Settings

You can manage your cookie preferences through the settings of the following popular browsers:

• Google Chrome: Chrome Cookie Settings
• Mozilla Firefox: Firefox Cookie Settings
• Microsoft Edge: Edge Cookie Settings
• Safari: Safari Cookie Settings

4.2 Data Controller

iFansy Limited (a company incorporated in Hong Kong under Company No. 76667656) is the controller of your personal data processed via cookies on the iFansy Platform. We are committed to protecting your privacy and complying with applicable data protection laws, including the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486).

At iFansy, operated by iFansy Limited, we are committed to maintaining a platform that is safe, ethical, and free from all forms of modern slavery, forced labor, and human trafficking. This Statement outlines the principles, preventative measures, and internal procedures we adopt to identify and address potential risks related to slavery and trafficking in connection with our operations, users, and supply chains.

1. COMMITMENT TO ETHICAL PRACTICES

iFansy Limited strictly prohibits any form of modern slavery, servitude, forced labor, or human trafficking in connection with the iFansy platform. We are dedicated to:

• Ensuring that no forced or trafficked labor is used in any part of our business or digital supply chain.
• Upholding all applicable anti-slavery and human trafficking legislation, including but not limited to the UK Modern Slavery Act 2015 and Hong Kong's Crimes Ordinance (Cap. 200).
• Promoting transparency and accountability across all levels of our business operations and supplier relationships.

2. GOVERNANCE AND POLICY INTEGRATION

To support our anti-slavery objectives, iFansy integrates the following policies and standards into our corporate framework:

• Code of Ethics and Conduct: Requires employees, contractors, and partners to adhere to lawful, respectful, and ethical standards.
• Supplier Due Diligence Policy: Mandates compliance checks for contractors and digital service providers to ensure alignment with anti-trafficking obligations.
• Whistleblower Protection Mechanism: Encourages staff and users to report suspected abuse confidentially without fear of retaliation.
• User Agreement and Verification: Requires identity and age verification for Creators to prevent exploitation or coerced content creation.

These policies are periodically reviewed and updated to remain consistent with evolving legal obligations and best practices.

3. RISK MANAGEMENT IN DIGITAL OPERATIONS

As a digital platform that facilitates content monetization, iFansy recognises specific risks associated with online labor exploitation and non-consensual content. Accordingly, we have implemented the following controls:

• KYC and Age Verification: All Creators undergo identity checks and age validation to prevent coerced or underage content posting.
• Content Moderation & Flagging Tools: AI-assisted and manual review systems are used to detect signs of exploitation, trafficking, or abuse.
• User Reporting Mechanisms: All users can report suspected violations or abusive content, which are investigated according to our [Content Moderation & Protection Policy].
• Collaborations with Enforcement and NGOs: Where appropriate, we cooperate with legal authorities and anti-trafficking organizations when risks of exploitation are reported.

4. TRAINING AND AWARENESS

We provide training to relevant staff members, especially those in content moderation, compliance, and creator support roles. Training covers:

• Recognizing signs of modern slavery, grooming, and coercion in digital environments;
• Reporting obligations and escalation procedures;
• Handling sensitive disclosures with care and discretion.

5. REPORTING AND ACCOUNTABILITY

Any suspected violation of this Statement or applicable anti-slavery laws should be reported immediately to support@ifansy.com. We will:

• Investigate reports promptly and thoroughly;
• Take appropriate enforcement actions, including content removal, account termination, and law enforcement referrals;
• Maintain internal records of reported cases and outcomes in line with our [Privacy Policy].

This Disclosure Statement is made by iFansy Limited, the legal operator of the iFansy Platform, in accordance with our commitment to responsible content hosting and applicable legal transparency practices. Although we are not based in the United States, we voluntarily aim to comply with the requirements of 18 U.S.C. §2257, §2257A, and 28 C.F.R. §75 to the extent possible under Hong Kong law and international standards.

1. COMPLIANT CONTENT

• All models, actors, actresses, and other persons who appear in any visual depiction of actual or simulated sexually explicit conduct on iFansy were over the age of eighteen (18) years at the time the content was produced.
• Records required by 18 U.S.C. §2257 and associated regulations are maintained in accordance with our internal verification procedures and are available for lawful inspection.

2. EXEMPT VISUAL CONTENT

Visual depictions appearing on iFansy that do not fall within the scope of 18 U.S.C. §2257 include, but are not limited to:

• Content not involving sexually explicit conduct as defined under 18 U.S.C. §2256(2)(A)(i)-(v);
• Content produced prior to July 3, 1995;
• Content for which iFansy does not act as a "primary" or "secondary" producer, as defined under 28 C.F.R. §75.1(c).

3. RECORDS CUSTODIAN AND COMPANY DETAILS

The title of this platform is: iFansy.

The Records Custodian for 2257-compliant content is:

All records will be made available to authorized regulatory bodies upon lawful request.