Privacy Policy

Last updated: October 25, 2025

1. Data Controller

The data controller is PayUnlock (proprietorship, Spain). Statutory provider identification is available in our Legal Notice. Contact: info@payunlock.me.

This Policy complies with EU GDPR and applicable Spanish data protection law. References to UK GDPR apply where relevant.

2. Personal Data We Process

For Creators (Uploaders):

  • Identification: name, date of birth, address, email, phone
  • Credentials: username and password (hash)
  • Connection data: IP, user agent, language, OS, session timestamps
  • Transactional data: amounts received, dates, number of files sold, withdrawals
  • Uploaded content: photos, videos, titles, thumbnails
  • ID documents and, where applicable, selfie for age/identity verification
  • Alerts and sanctions for illicit content or violations

For Buyers (Downloaders):

  • Basic identification: name, email
  • Device and connection data: IP, language, OS
  • Purchase operations: date, file purchased, amount

Payment and identity verification data are collected and stored by our providers (e.g., Stripe). PayUnlock does not access full card numbers or sensitive payment data.

3. Purposes and Legal Bases

  • Account creation and management (performance of contract)
  • Login, authentication and support (performance of contract)
  • Age and identity verification (legitimate interests and legal obligation)
  • File exchange and sales (performance of contract)
  • Payment processing and payouts (performance of contract) via Stripe
  • Fraud prevention and compliance (legitimate interests and legal obligation)
  • Content moderation and filtering for illegal content (legitimate interests)
  • Improving the Platform and statistics (legitimate interests and consent for cookies)
  • Service communications (performance of contract)

4. Recipients and Processors

We may share data with the following categories of recipients under data processing agreements:

  • Financial services: Stripe for payments and verification (KYC/AML)
  • Hosting and infrastructure: cloud and CDN providers
  • Analytics: analytics tools (e.g., Google Analytics)
  • Automated moderation: illicit content detection services
  • Support and communications: transactional email and support tools
  • Advisory and compliance: accounting, legal, and audit

We do not sell personal data. Manifestly illegal content may be reported to competent authorities.

5. Retention Periods

  • Account: until account deletion or 2 years from last activity
  • Files: 3 months from upload (unless removed earlier or illegal)
  • Buyer email: as needed to deliver the file or receipt
  • Connection logs: 6 months
  • Support: as needed to resolve the request
  • ID documents for KYC verification: retained only during the verification process and deleted immediately upon successful verification or rejection. For compliance and audit purposes, we may retain verification outcomes (approved/rejected status and timestamp) without the underlying documents
  • Accounting/tax: statutory periods (typically 4–7 years)
  • Cookies: per their nature; see Cookie Policy

6. International Transfers

Some processors may be located outside the EEA (e.g., U.S.). Where applicable, we require appropriate safeguards (e.g., EU Standard Contractual Clauses), technical/organizational measures, and transfer impact assessments.

7. Cookies and Similar Technologies

We use necessary cookies for operation, security/fraud cookies, and—subject to your consent—analytics cookies. Manage your preferences in our Cookie Policy and your browser.

8. Your Rights

Under GDPR, you may exercise: access, rectification, erasure, objection, restriction, portability, and instructions regarding post-mortem data.

To exercise rights, contact info@payunlock.me. We may request proof of identity.

You may also lodge a complaint with the AEPD (Spain) or your local supervisory authority.

9. Identity Verification (KYC)

To ensure platform safety, prevent fraud, and comply with legal obligations, we require creators to verify their identity before uploading content. This process involves:

  • Document submission: Government-issued ID (passport, national ID, or driver's license)
  • Verification status: pending, approved, or rejected
  • Processing: Documents are encrypted during transmission and processed securely
  • Deletion: Upon verification completion (approval or rejection), documents are permanently deleted from our systems
  • Outcome retention: Only the verification outcome (approved/rejected status and date) is retained for compliance purposes, without storing the actual documents

Legal bases for KYC processing: legitimate interests (platform safety, fraud prevention) and legal obligations (anti-money laundering, age verification requirements).

You may request information about your verification status at any time by contacting info@payunlock.me.

10. Security Measures

We apply appropriate technical and organizational measures: encryption in transit and at rest, access controls, secure document handling for KYC, logging, segmentation, and data minimization.

KYC documents are handled with enhanced security measures including encrypted storage during processing and immediate deletion post-verification.

11. Changes to This Policy

We may update this Policy due to regulatory or Platform changes. We will notify material changes with reasonable advance notice (typically 15 days) by email or notice on the Platform.

12. Contact

For privacy matters, contact info@payunlock.me. Statutory provider identification is available in our Legal Notice.

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