Privacy Policy
Echelon Labs LLC is the controller of the personal data described here. This policy says what we hold, why, who else sees it, and how to make us delete it.
What we collect
| Data | Why | Basis |
|---|---|---|
| Fanvue account id, email, and handle, when you use Log in with Fanvue | To sign you in and attach your characters to an account. That login does not connect a character or send messages | Contract |
| Characters: name, age, city, described appearance, voice | To generate her and keep her consistent | Contract |
| Generated images and the prompts behind them | To show you your work, train her model, and publish at your instruction | Contract |
| Chat messages between a character and fans | To let her reply in context and remember a fan | Contract |
| Fanvue access and refresh tokens, creator id and handle | To post and reply on the account you connected | Contract |
| Fanvue earnings figures and fan spend totals | To show your dashboard numbers | Contract |
| Three cookies (see Cookie Policy), including the 18+ and terms confirmation | To keep content closed until you confirm, and to know whose characters are whose | Strictly necessary |
| Content reports: your email, where the content is, and what you say is wrong | To find and remove illegal or unsupported content and reply to you | Legitimate interests / legal obligation |
| Server logs: IP, timestamp, path, errors | Security, abuse investigation, debugging | Legitimate interests |
| Blocked-prompt records | To enforce the age gate and evidence enforcement | Legal obligation / legitimate interests |
We do not ask for your date of birth, and we do not scan an identity document. Before any content is shown you have to actively confirm you are 18 or older and agree to the terms. That confirmation is a cookie, not an identity record. We do not knowingly collect anything from anyone under 18.
Where your prompts and images go
Generation is split deliberately, and it matters for privacy:
- A third-party image provider receives the clothed casting prompts, and the reference image when you refine a face. It never receives explicit prompts.
- A third-party model-training provider receives a set of clothed stills in order to train your character's face model. It never receives explicit prompts.
- Explicit images are generated on hardware we operate and are not sent to any third-party image provider.
- A third-party language-model provider receives fan messages and character context in order to write her replies. Where configured, this runs on hardware we operate instead.
- Fanvue receives the images, captions and messages you publish, on the account you connected. Log in with Fanvue also confirms who you are.
We name categories rather than companies here because providers change. You are entitled to know who they are: ask [email protected] and we will give you the current list in writing, which is what you will need for a DPIA, a client's due diligence, or a subject access request.
Those providers process data on their own terms, and some are outside the UK/EEA. Transfers rely on the UK IDTA or EU standard contractual clauses as applicable.
How long we keep it
- Characters, images, chats: until you delete them or close your account.
- Trained character models: deleted from our GPUs when the character is deleted.
- Fanvue tokens: until you disconnect, or the character is deleted.
- Server logs: 90 days.
- Billing records: as long as tax law requires, typically six years.
- Records of enforcement against a closed account: up to two years, to stop the account being remade.
- Content reports: up to two years, so a removed item is not put back and we can show what we did.
- Blocked-prompt records: up to two years. The category, time, surface and a hash are kept. The wording is kept only as a short excerpt, and it is not kept at all for a minor-related block or for hate speech.
Your rights
If the UK GDPR or EU GDPR applies to you, you may ask for a copy of your data, correction, deletion, restriction, portability, and you may object to processing based on legitimate interests. Write to [email protected]. We answer within one month. You may complain to the UK Information Commissioner's Office or your local supervisory authority.
Deleting a character is immediate and irreversible: images, model, chat history and tokens all go. We cannot recover her afterwards.
Security
Traffic is encrypted in transit. Fanvue tokens are stored server-side and never exposed to the browser. Session cookies are signed, HttpOnly and — over HTTPS — Secure. Access to production data is limited to people who need it to run the service.
Automated decisions
Prompts are screened automatically against the age gate described in the Content Standards, and a blocked prompt is refused without a human first reviewing it. You can contest an outcome by writing to [email protected].
Changes
We will post changes here and, if they are material, email the address on your account.