Acceptable Use Policy
Contract between Fan and Creator
Platform to Business Regulation Terms
Referral Program Terms
Complaints Policy
Appeals Policy
UK VAT Policy
Community Guidelines
TERMS OF USE
BY USING OUR WEBSITE YOU AGREE TO THESE TERMS – PLEASE READ THEM CAREFULLY
Introduction: These Terms of Use govern your use of Demuregram and your agreement with us. Here are a few key things to note:
We can modify these Terms of Service at any time.
If you purchase a Subscription, it will automatically renew for additional periods of the same duration unless you cancel it.
Your rights may vary depending on where you are resident when you access Demuregram.
If a dispute arises between you and us, you agree to notify us and agree to mediation before bringing any claim against us.
Interpretation: In the Terms of Service:
We refer to our website as “Demuregram”, including when accessed via the URL www.Demuregram.com;
References to “we”, “our”, “us” are references to Fenix International Limited, the operator of Demuregram;
“Business User”: a User who uses Demuregram for commercial reasons, whether acting on their own behalf or through someone else, including Referring Users;
“Consumer”: all Users who are not Business Users;
“Content”: any material Uploaded to Demuregram by any User, including any photos, videos, audio, livestream material, data, text, metadata, images, interactive features, emojis, GIFs, memes, and any other material whatsoever;
“Contract between Fan and Creator”: the terms which govern each Creator Interaction;
“Creator”: a User who has set up their Demuregram account to post Content for Fans to view;
“Creator Earnings”: the portion of a Fan Payment payable to a Creator pursuant to these Terms of Service after deducting all fees and applying all relevant tax laws;
“Creator Interaction”: an interaction on Demuregram that grants access to a Creator’s Content, including: (i) a Subscription; (ii) a payment for pay-per-view Content; and (iii) any other interaction or payment between a User and a Creator’s account or Content, including direct messages;
“Fan”: a User who has registered for an account and who can access a Creators’ Content via a Creator Interaction;
“Fan Payment”: any payment related to a Creator Interaction;
“Include”, “Includes”, and “Including” also mean “without limitation”;
“Indirect Sales Taxes”: any Tax that is statutorily applied to Fan Payments in any relevant jurisdiction;
“Notice”, “Notify”, and “Notification”: our attempt to share information with you by: sending a message to your Demuregram account, or sending an email to an address you provide, or posting a letter to the physical address you provide, or sending a text message to or calling a phone number you provide;
“Referring User”: a User who participates in the Demuregram Referral Program;
“Subscription”: a Fan’s binding agreement to obtain access for a specific period of time to all content that a Creator makes available to Fans in exchange for authorised automatic renewal payments. This excludes individually priced content;
“Subsidiary”: a legal entity of which Fenix or a Fenix Subsidiary, alone or with other Fenix Subsidiaries, owns, or has the power to vote or control;
“Tax”: all forms of tax and statutory, governmental charges, duties, imposts, contributions, levies, withholdings, or liabilities wherever chargeable in any applicable jurisdiction;
“Terms of Service” (also called “your agreement with us”): the legally binding agreement between you and us which consists of: (i) these Terms of Use; (ii) Acceptable Use Policy; (iii) Referral Program Terms; (iv) Platform to Business Regulation Terms; (v) Complaints Policy; (vi) Appeals Policy; (vii) UK VAT Policy; and (viii) Community Guidelines;
“United Kingdom” and “UK”: the United Kingdom of Great Britain and Northern Ireland;
“Upload”: publish, display, post, type, input, or otherwise share any photos, videos, audio, livestream material, data, text, metadata, images, interactive features, emojis, GIFs, memes, and any other material whatsoever;
“User”: any user of Demuregram, whether a Creator or a Fan or both (also referred to as “you” or “your”).
Who we are and how to contact us: Demuregram is operated by Fenix International Limited. We are a limited company registered in England and Wales, with company registration number 10354575 and we have our registered office address at 9th Floor, 107 Cheapside, London, EC2V 6DN. Our VAT number is 268196365.
To contact us with questions, please email support@Demuregram.com or use our Contact Form. You may also write to us at 9th Floor, 107 Cheapside, London, EC2V 6DN.
We may change the Terms of Service: Where permitted we may change any part of the Terms of Service without Notice:
To reflect changes in applicable laws and regulations; and/or
To address a risk to Demuregram, to us, to Users, or to relevant third parties.
We may also make other changes and will Notify you so you may delete your account before the changes take effect. Once updated you will be bound by the effective Terms of Service if you continue to use Demuregram.
We may change, suspend, or deactivate Demuregram: We may change Demuregram from time to time for any reason. We do not guarantee that Demuregram, or its Content, will always be available or accessible without interruption. We may suspend, withdraw, or restrict the availability of any part of Demuregram.
Registering with Demuregram: By registering with and using Demuregram, you agree to the Terms of Service. If you do not agree, your sole remedy is to not register or stop being an Demuregram User. We may reject an account application for any reason. To use Demuregram you must register and open an account on Demuregram. You must provide a valid email address, a username, and a password or authenticate using an approved third-party. Your password must comply with the Demuregram password requirements.
To register as a User and open a Fan account:
You must be at least 18 years old;
You must be able to be legally bound by a contract with us;
You must be legally permitted to join, view Content, and to use any functionality provided by Demuregram;
You must not be convicted of committing a serious crime; and
You agree to pay (where required) for Creator Interactions in accordance with the Terms of Service and the Contract between Fan and Creator.
If you do not meet the above requirements, you must not access or use Demuregram. You may also be asked to provide additional information prior to account approval.
To open a Creator account, you must also:
Upload a valid form of ID and two photos of you;
Add a bank account, payment details for your bank account, or a payment method;
Select a method (“Payout Option”) for us to transfer Creator Earnings to you;
If you are registered for VAT in the UK, provide your UK VAT number;
Submit additional age or identity verification information any time we ask for it;
Set a monthly subscription price, if any, for your Fans;
Add Content for Users to view when they subscribe to your account and become your Fans; and
Provide any additional information we request, which may vary depending on where you live or your nationality.
Adult material: Some Content on Demuregram contains adult material, and you acknowledge and agree to this when you access Demuregram. We are not responsible for any loss or damage you suffer as a result of how or where you view Content.
Content – general terms:
Your Content is not confidential, and you authorise your Fans to access and view your Content on Demuregram for their own lawful and personal use, and in accordance with any licenses that you grant to your Fans.
You are legally responsible for all Content you Upload. If you are a Creator and someone else assists you with the operation of your Creator account, this does not affect your legal responsibility. Our relationship is with you, and not with any third-party, and you will be legally responsible for ensuring that all Content posted and all use of your account complies with the Terms of Service.
You warrant that, for each item of Content you Upload to Demuregram:
it complies with the Terms of Service and all applicable laws;
you own your Content (and all intellectual property rights in it) or hold all rights necessary, including licenses, to post and monetise the Content on Demuregram or the subsequent use of that Content by Demuregram;
if your Content includes or uses any third-party material, you have secured all rights, licenses, written consents and releases that are necessary for the use of such third-party property in your Content and for the subsequent use of that Content on Demuregram and by us; and
the Content is:
of satisfactory quality, taking account of any description of the Content, the price, and all other relevant circumstances including any statement or representation which you make about the nature of the Content on your account or in any advertising;
reasonably suitable for any purpose which the Fan has made known to you; and
as described by you.
You are liable to and will indemnify us if any warranty in this section of these Terms of Use is untrue. This means you will be responsible for any resulting loss or damage we suffer.
We are not responsible for, do not control, and do not endorse any Content you or any other Demuregram User posts. We have no direct control over what your Content may comprise and are not obligated to pre-screen Content. We reserve the right to pre-screen, monitor, or reuse Content. We reserve the right to remove Content that violates our Terms of Service.
You agree to act as custodian of records for all Content you Upload to Demuregram.
Fan subscriptions and purchases: This section applies to Creator Interactions including Subscription billing and renewals:
Creator Interactions are governed by the Contract between Fan and Creator. We may moderate Content and we facilitate Creator Interactions by providing the Demuregram platform, but we are not a party to the Contract between Fan and Creator or any other contract between a User and a Creator, and we are not responsible for Creator Interactions.
Creators are solely responsible for determining any pricing applicable to Creator Interactions.
All prices appear, and are charged, in USD. Payment providers may charge currency conversion fees.
Fan Payments are exclusive of Indirect Sales Tax, which shall be added at the current rate as applicable to Fan Payments.
When a Creator receives Notice that the Creator Interaction has been confirmed, that Creator must perform their part of the Creator Interaction. Creators agree to indemnify us for any breach of this obligation and are responsible for any loss or damage we suffer as a result of such failure.
Before entering into a Creator Interaction with a particular Creator, Users must add payment information to their account and then click ‘Subscribe’ on the relevant Creator’s account.
Users authorise us and each Subsidiary to supply payment information details to a third-party payment provider for the purpose of processing Fan Payments.
The payment provider will take: (i) periodic payments for Fan Payments which are Subscriptions; and (ii) immediate payments for Fan Payments other than Subscriptions. You authorise and consent to each of these payments being debited using your supplied payment information.
If you provide details of more than one payment method and a Fan Payment from the first method fails, we will use the other payment method for the Fan Payment.
When you select “Subscribe,” you agree to start a Subscription. A Subscription will automatically renew at the current rate (plus Indirect Sales Tax). You authorise us to charge you again after each Subscription, unless: (i) your payment is declined and you have not provided another payment; (ii) the Subscription price has increased; (iii) you switched off the “Auto-Renew” feature on the Creator’s account; or (iv) you close your Demuregram account before the new subscription period begins. By selecting “Subscribe,” you agree to these provisions, and acknowledge that you will not receive further Notice regarding the renewal of that Subscription.
If you cancel a Subscription, you can view the relevant Creator’s Content until the end of the subscription period in which you cancelled, after which no further payments will be taken from you in respect of subscriptions to that Creator’s profile (unless you begin a new Subscription to that Creator’s profile), and you will no longer be able to view the relevant Creator’s Content.
You agree not to make: (i) unjustified requests for a refund; or (ii) unjustified chargeback requests of your payment card provider in relation to any Creator Interaction or tip to a Creator. If we determine that any refund or chargeback request was made by you in bad faith, we may suspend or delete your User account.
You can prepay an amount on Demuregram (“Wallet Credits”) which you can later use for Fan Payments. Purchases on Demuregram cannot be divided – if you attempt a purchase that costs more than the total amount of your remaining Wallet Credits, your payment card will be charged the full amount for that purchase. Wallet Credits are subject to a maximum amount as indicated. Interest will not accrue on Wallet Credits. Wallet Credits are non-refundable, which means that you are not entitled to a refund of any unused Wallet Credits.
Creator payouts:
All Fan Payments will be received and processed by a third-party payment provider we approve.
Our Fee is calculated as 20% of the total Fan Payment and will be deducted from each Fan Payment.
Creator Earnings will only be available for withdrawal when reflected in your Demuregram account.
To withdraw Creator Earnings from your Demuregram account, your account balance must meet the minimum payout amount requirement.
All Fan Payments and Creator Earnings are transacted in USD. Your bank or e-wallet company may charge currency conversion or other fees. We do not control currency exchange rates, banking charges, or e-wallet provider charges. We and any Subsidiary are not responsible for paying such charges.
If a Fan successfully seeks a refund or chargeback from their credit card provider of a Fan Payment, we may deduct an amount equal to the Creator Earnings portion of the refunded or chargedback amount.
Except for Payout Options by direct bank transfer, we do not store the data you disclose when you register your Payout Options with a payment provider.
Tax compliance:
General:
Creators are responsible for their own Tax affairs and neither we nor any Subsidiary: (i) are responsible for advising you on your Tax affairs or liable for any general Tax information provided on Demuregram or by support@Demuregram.com; or (ii) liable for any Creator’s non-payment of Tax.
By using Demuregram as a Creator, you warrant that you have reported, and will report in the future, all payments you receive in connection with your use of Demuregram to the relevant Tax authority in your jurisdiction, as required by law.
If, while you have an Demuregram account, you become Tax non-compliant in relation to your use of Demuregram or if you are named in any litigation, inquiry, or investigation in connection with, or which may lead to, any Tax non- compliance in connection with your use of Demuregram, we reserve the right to close, restrict payouts from, or restrict earnings from your account.
UK VAT and UK established Creators: If you are a Creator registered for UK VAT, you must follow our UK VAT Policy.
EU VAT and EU established Creators: If you are a Creator registered in an EU country, you must adhere to the EU VAT rules that apply.
Compliance responsibility: You alone are responsible for ensuring that you make any necessary Tax fillings and pay any Tax due on your earnings on Demuregram. Failure to comply with your Tax obligations may result in your Demuregram account being closed or suspended.
Our rights and obligations:
We reserve the right to suspend or remove Content that may breach our Terms of Service.
We comply with applicable laws requiring us to use proportionate measures to quickly remove illegal Content when we become aware it is on Demuregram.
When we review Content in accordance with our internal policies, we reserve the right to conduct these reviews with technology tools such as classifiers, and Artificial Intelligence and Machine Learning-enabled tools to detect and remove Content that violates our policies.
We may use recommender systems by, for example, displaying Creator accounts on your home page that other Users who share subscription preferences similar to yours have chosen to follow.
We are not responsible for any loss you claim to have suffered because of any action we take, in accordance with our Terms of Service, to suspend or remove Content.
We may suspend or delete Content and accounts according to our Terms of Service. If we do, we will try to Notify you.
If your account is terminated, we may deal with your Content in accordance with our Privacy Policy . You will not be able to access your Content after your account is terminated.
We may review any suspected or alleged misuse, abuse, or unlawful use of Demuregram and cooperate with law enforcement agencies in such reviews.
We may disclose any information or records in our possession or control about your use of Demuregram to third parties in keeping with our Privacy Policy.
We may change which third-party payment providers process Fan Payments.
Other than Content which is owned by or licensed to Creators, we and/or our licensors own all rights in and to Demuregram and its entire contents.
We are the sole owners of any and all anonymised data relating to your use of Demuregram and we can use that data for any purpose permitted by law.
We may choose how we communicate with you, including by emails and messages posted to your Demuregram account.
What we are not responsible for: We will use reasonable care and skill in providing Demuregram to you, but there are things we are not responsible for, including:
We do not control Content that Users post on Demuregram. We do not choose, endorse, authorise, approve or guarantee the completeness, legitimacy, legality, accuracy, or reliability of any Content Users post on Demuregram. We comply with applicable laws requiring us to use proportionate measures to quickly remove illegal Content when we become aware it is on Demuregram. You may report Content you suspect may be illegal by following our Complaints Policy.
We do not grant you any rights in relation to Content.
Whether your Content is viewed by individuals that recognise your identity.
Any suggestions, comments, reviews, or requests that any User provides, accepts, or receives.
Any promise or guarantee that Creators or Referring Users will generate earnings from Demuregram.
Whether Demuregram is compatible with all devices and operating systems. You are responsible for configuring your information technology, device, and computer programs to access Demuregram.
The availability of the internet, or any issues in your hardware, or software, that may impact your use of or access to Demuregram.
Any lost, stolen, or compromised User accounts, passwords, email accounts, or any resulting unauthorised activities or resulting unauthorised payments or withdrawals of funds.
The circulation of Content recorded in breach of the Terms of Service.
Circumstances in which we may suspend or delete your account and/or Content, pause Fan Payments, and/or withhold Creator Earnings:
We may suspend or delete your account with 30 days’ Notice, at any time, for any reason;
At any time, without warning or Notice and for as long as is necessary to review the relevant facts, we may: (i) suspend or delete your account and/or your Content; (ii) pause Fan Payments which would have been due during the suspension period; (iii) withhold any part of your Creator Earnings; and/or (iv) suspend, refund, or cancel Fan Payments if:
we think you have or may have seriously or repeatedly breached the Terms of Service;
you attempt, or threaten, to breach the Terms of Service in a way which we think has or could have serious consequences for us or another User; and/or
we suspect that all or any part of the Creator Earnings result from unlawful or fraudulent activity, either by you or by the Fan who made the Fan Payment resulting in the Creator Earnings.
If, based on our review of the relevant facts, we determine that any of the above is true, we may: (i) delete your account and/or your Content; (ii) treat any part of your Creator Earnings as forfeited; and/or (iii) refund or cancel Fan Payments. We will Notify you when we take any such action and will provide a statement of reasons why. If we terminate your Fan account for violating the Terms of Service, Fan Payments, including prepaid Subscription payments, will not be refunded.
If you do not dispute our decision within six months of Notification, you waive the right to dispute the decision. You may dispute a Creator Earnings forfeiture decision by following our Complaints Policy and dispute an account termination or Content deactivation decision by following our Appeals Policy. In certain jurisdictions, you may be entitled to bring a claim against us for breach of contract where we remove or restrict access to your Content or the Demuregram platform in breach of our Terms of Service.
If a lien, levy, or other encumbrance is placed on your Creator Earnings, we may withhold any part of your Creator Earnings and may suspend or cancel Fan Payments. We have no duty to make ongoing payments to your creditor(s) and may withhold Creator Earnings until an encumbrance is removed.
We may use any part of your Creator Earnings to set off any harm or loss we suffer as a result of your breach(es) of the Terms of Service.
Intellectual property rights – ownership and licenses:
You confirm that your Content does not infringe or violate the intellectual property rights of any third-party and that you own or have obtained all rights necessary to distribute, copy, display, publicly perform or otherwise use the Content.
You agree to grant us a license to all your Content to perform any act related to the operation of Demuregram and our related products and services, including reproducing, making available or displaying to the public, distributing, creating derivative works, and otherwise using your Content, including for the purpose of improving the features and functionalities of Demuregram and our related products and services.
The license you grant us is perpetual, non-exclusive, worldwide, royalty-free, sublicensable, assignable, and transferable by us.
Except for mandatory provisions of law that apply to you, you waive any moral rights you may have under any applicable law to object to treatment of your Content.
We will never sell your Content to other platforms; however, in the event of a sale of our company or its assets, we may transfer any license you have granted us.
While we do not own your Content, you grant us the right to submit notifications of infringement (including of copyright or trademark) on your behalf to any third-party that is infringing your Content. We are under no obligation to submit such notifications or to police infringements of your Content.
Our DMCA Takedown Policy describes our procedures for responding to reports that infringing content was published on Demuregram. Our Complaints Policy explains how to make a complaint about infringement of intellectual property rights on platforms other than Demuregram.
Co-authored Content:
You are legally responsible for all Content you Upload. You may Upload Content that features someone other than you (“Co-Authored Content”).
You warrant that each individual in Co-Authored Content you Upload is:
a Creator you have tagged using the tool available on Demuregram; or
an individual at least 18 years of age whose proof of identity and whose written, informed consent you have obtained to share the Content on Demuregram.
You and each Co-Author will provide us with necessary documents to confirm you have satisfied the requirements of these Terms of Service.
If you, or anyone appearing in Co-Authored Content, do not provide any information we request, we may restrict or delete the Co-Authored Content or your account, and/or withhold all or any portion of your Creator Earnings.
We are not a party to any agreement that you have to create Co-Authored Content or any resulting dispute. All claims arising from Co-Authored Content shall be made against the Creator(s) who posted or who appear in the Co-Authored Content. You will not make any claims against us, and you release us from any claims against us, arising from Co-Authored Content.
Any individual(s) who appear in the Co-Authored Content may, at any time, withdraw their consent to appear in that Co-Authored Content. Co-Authored Content may be deleted where a participant withdraws consent.
Sharing and linking to and from Demuregram:
Other online platforms may allow Users to connect their Demuregram account and share Content. You remain bound by the Demuregram Terms of Service and that platform’s terms of service when sharing content in this way.
Links to Demuregram:
Do not link to Demuregram in a way that is deceptive or that suggests any form of association, approval, or endorsement on our part.
Any link promoting your Creator account must comply with our Terms of Service and the terms of service where you advertise.
Do not promote your Demuregram account using Google Ads or any similar advertising platform or search engine advertising service.
Links from Demuregram: Links on Demuregram to other web sites are provided for your convenience only. We are not liable for, do not control, approve of, or endorse those linked websites or the information they contain.
Domain Names: You may register or use domain names that contain the Demuregram trademark or a confusingly similar term only if:
The domain name is registered by the Creator;
The domain name redirects to the Creator’s Demuregram account; and
The Creator obtains written permission from Demuregram by contacting support@Demuregram.com and signs a licensing agreement.
If you fail to comply with these provisions or the licensing agreement, we may file a domain dispute or seek other remedies.
Advertising on Demuregram: If you Upload Content to your Creator account which is designed to promote, directly or indirectly, third-party goods or services, in return for payment or other valuable consideration (together “Advertising Content”), then you must ensure that the Advertising Content:
is not illegal, prejudicial, threatening, false, fraudulent, harmful, hateful or in violation of our Acceptable Use Policy or Community Guidelines;
does not advertise cigarettes, other tobacco products, electronic cigarettes, illegal drugs, or any prescription-only medicine;
does not advertise, promote, or facilitate illegal gambling;
does not direct any Advertising Content for alcoholic drinks at minors or encourage excessive consumption of alcohol; and
adheres to the requirements in Section 19 of these Terms of Use.
Transparency requirements:
Advertising Content: Clearly and conspicuously label Advertising Content you Upload to Demuregram by including in the caption of the Advertising Content:
a signifier such as #ad, #paidpromotion or #sponsored; and
the name of the brand advertised and who paid for the Advertising Content.
AI Generated Content: AI Generated content must comply with our Terms of Service and must be clearly and conspicuously captioned as AI Generated Content with a signifier such as #ai, or #AIGenerated.
Account deletion: You may delete your Demuregram account in the ‘User Account’ section of your Demuregram account.
If you are a Fan, we will delete your account within a reasonable time and will not charge any further Subscriptions. After we delete your account, you will not have access to your former account or any Content.
If you are a Creator, your account will remain open until all active Fan Subscriptions expire. We will then pay all unpaid Creator Earnings and delete the account. All subscriptions will be deleted and cannot be renewed. After we delete your account, you will not have access to your former account or its Content. Deleting your Demuregram account will not automatically delete Co-Authored Content posted by another Creator.
After your account is deleted, we may deal with your data in accordance with our Privacy Policy.
Responsibility for alleged loss or damage:
Whether you are a Consumer or Business User we do not limit our liability where it would be unlawful to do so. Consumers may rely on mandatory provisions of law that apply to them and nothing in our Terms of Service affect a Consumer’s rights to rely on mandatory provisions of local law.
If you are a Consumer, you agree that:
We, each Subsidiary, and our employees, owners, representatives, and agents are not liable to you for any loss of profit, loss of business or revenue, business interruption, loss of business opportunity, or loss of anticipated savings arising from or in connection with your use of Demuregram.
If you are a Consumer User and reside in the United States of America, our total liability to you for claims arising out of or related to your agreement with us shall be limited to USD $250 per claim.
If you are a Business User, you agree that:
We, each Subsidiary, and our employees, owners, representatives, and agents:
exclude (to the extent permitted by law) all implied conditions, warranties, representations, or other terms that may apply to Demuregram or any Content. This means that if the Terms of Service do not expressly include a promise or commitment by us, then one cannot be implied by law;
are not responsible for any loss or damage that is not a foreseeable result of our breaching the Terms of Service or our failing to use reasonable care and skill. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time you agreed to the Terms of Service, both we and you knew it might happen;
are not liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising out of or in connection with:
your inability to use Demuregram or any of its services, features or programs; or
your use of or reliance on any data or information (including Content) stored on Demuregram;
are not liable to you for any loss of profits; loss of sales, business, or revenue; business interruption; loss of anticipated savings; loss of business opportunity, goodwill or reputation; loss of data or information (including Content); or indirect or consequential loss or damage;
are not liable to you if your Content is copied, distributed, reposted elsewhere or its copyright is infringed;
are not liable to you for any disclosure of your identity, or any disclosure or publication of your personal information by other Users or third parties without your consent (also known as “doxing”);
are not liable to you for any failure or delay by us in complying with any part of the Terms of Service arising from events outside our reasonable control.
Our total liability to you for any and all claims arising out of or related to your agreement with us, whether in contract, tort (including negligence), breach of statutory duty, or otherwise shall be limited to the greater of:
100% of the total fees paid by you to us in connection with your use of Demuregram; or
USD $5,000.
General: You agree that:
If any aspect of your agreement with us is unenforceable, the rest will remain in effect.
If we fail to enforce any aspect of your agreement with us, it will not be a waiver.
We, each Subsidiary, and our employees, owners, representatives, and agents reserve all rights not expressly granted to you.
No implied licenses or other rights are granted to you in relation to any part of Demuregram, save as expressly set out in the Terms of Service.
Agreeing to our Terms of Service and using Demuregram does not create an agency, partnership, joint venture, franchisor-franchisee, representative, fiduciary, or employee–employer relationship. You do not have authority to bind us or any Subsidiary in any manner.
Your agreement with us does not give rights to any third parties, except that each Subsidiary and our employees, owners, representatives and agents may enforce the exclusions and limitations of liability and the terms relating to disputes in our Terms of Service.
You cannot transfer, assign, or subcontract your rights or obligations under any agreement with us.
Our rights and obligations under your agreement with us can be assigned or transferred by us to others. We may delegate the performance of any of our obligations under your agreement with us to any third-party.
The Terms of Service form the entire agreement between us and you regarding your access to and use of Demuregram, and supersede any and all prior oral or written understandings or agreements between us and you.
If you have a complaint about Demuregram, refer to our Complaints Policy and our Appeals Policy. If you wish to communicate with us about Demuregram or our Terms of Service, please email support@Demuregram.com.
Choice of law and forum for disputes:
For Consumers:
Choice of law: To the greatest extent permitted by the laws of the place where you live, your agreement with us is governed by the laws of England, which will apply to any claim arising out of or in connection with your agreements with us or your use of Demuregram including non-contractual disputes or claims. You may also rely on mandatory rules of the law of the country where you live.
Forum selection: For United Kingdom and European Union residents, the courts of England and Wales or the courts of the country where you live will have jurisdiction over a claim which arises out of or in connection with your agreement with us or your use of Demuregram (including non-contractual disputes or claims). For all others, the courts of England and Wales will have jurisdiction over any claim which arises out of or in connection with your agreement with us or your use of Demuregram (including non-contractual disputes or claims).
For United States residents, a court in Wilmington, Delaware will have jurisdiction over any claim that is exclusively against Fenix Internet LLC, located at 1000 N. West Street, Suite 1200, Wilmington, Delaware, 19801, a wholly-owned subsidiary of Fenix International Limited.
For Business Users:
Choice of law: If you are a Business User, your agreement with us is governed by the laws of England and Wales, which will apply to any dispute arising out of or in connection with your agreement with us or your use of Demuregram including non- contractual disputes or claims without regard to conflict of law provisions.
Forum selection: If you are a Business User, you and we agree that the courts of England and Wales will have jurisdiction over any claim which arises out of or in connection with your agreement with us or your use of Demuregram (including non- contractual disputes or claims).
Limitation period for bringing claims: Except where prohibited by applicable law, any claim or cause of action against us or any Subsidiary must be filed within the earlier of one year after the date on which such claim or cause of action arose or the date on which you learned or should have learned of the facts giving rise to the cause of action, or that claim is expressly waived and cannot be brought.
You agree to notify us prior to bringing any cause of action and, if we request it, to submit any dispute to pre-suit mediation. This provision is a material inducement to allow you to use Demuregram.
If you are a User and commence proceedings against us or any Subsidiary, we reserve the right to terminate your account to minimise the risk of potential harm to Demuregram, to us, and to our community.
Documents which initiate Consumer disputes exclusively against Fenix Internet LLC must be served in accordance with US law. Fenix Internet LLC does not accept service in any other manner. All other documents initiating proceedings must be served in accordance with the laws of England and Wales. We do not accept service in any other manner.
Failure to comply with the requirements of this section is a material breach of the Terms of Service.
Last updated: July 2025
By using Demuregram, you acknowledge that you have read and understand the information in this Policy.
Introduction
What is Personal Data?
Informing us of changes
Applicability of this Policy (18+)
Third-party links
If you do not wish to provide Personal Data
Updates to this Policy
Categories of Personal Data
Our onboarding processes
How / why your Personal Data is used and lawful bases for processing
Obtaining your Personal Data
Sharing your Personal Data
International data transfers
Your rights regarding Personal Data
Exercising your rights
Choices and control over your Personal Data
Retention of Personal Data
Additional U.S. State Privacy Disclosures
Assistance and contact information
Introduction
Fenix International Limited (“we”, “us”, “our”) respects your privacy and we are committed to protecting the Personal Data we process about you. Fenix International Limited is the owner and operator of www.Demuregram.com (“Demuregram”), a social network and content sharing platform which enables: (i) “Creators” to share and monetise their own content (as well as subscribe to, and view, the content of other Creators); and (ii) “Fans” to subscribe to, and view, the content of Creators.
This privacy policy (“Policy”) explains our practices with respect to the Personal Data processed about our Creators and Fans. It also explains our practices with respect to the Personal Data processed about individuals that feature in content uploaded by a Creator (“Content Collaborators”), and where we process Personal Data in the context of our business relationships.
We process your Personal Data when you use Demuregram and for the provision of the services that we offer from time to time via Demuregram (the “Services”). We are a “data controller” of the Personal Data that we process in connection with the Services. This means that we decide the reasons why we process Personal Data about you and how we do so.
If you have any questions about this Policy or our processing of your Personal Data, please see Section 19 (assistance and contact information) for information about how to contact us.
What is Personal Data?
“Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.
In addition, we may collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as deidentified, aggregated or anonymised information. This type of data is not Personal Data and our use of such data is not subject to this Policy.
Informing us of changes
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes at any point during your relationship with us. Updates or corrections can be made through your account settings on Demuregram.
Applicability of this Policy (18+)
This Policy is provided in addition to, but does not form part of, our Terms of Service (which includes our Acceptable Use Policy) that govern your use of Demuregram and the Services.
Our Services are strictly intended for individuals 18 years of age or older. Anyone under 18 years of age is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.
Third-party links
Demuregram may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you.
We are not responsible for, and this Policy does not apply to, the content, security or privacy practices of those other websites, plug-ins or applications. We encourage you to view the privacy and cookie policies / notices of those third parties to find out how your Personal Data may be used.
If you do not wish to provide Personal Data
We need to collect certain Personal Data from you to provide you with access to the Services, or specific features and functionalities of the Services, in accordance with our contract with you (i.e. our Terms of Service). We are also required to process certain Personal Data in accordance with applicable laws. Please note that if you do not wish to provide Personal Data where requested, we may not be able to provide you with access to the Services or specific features and functionalities of the Services.
Updates to this Policy
We may update this Policy from time to time, and any updates will be effective upon our posting of the revised Policy on Demuregram. We will use reasonable efforts to notify you in the event that material updates are made to this Policy, such as sending you a feed notification or a chat message via your account on Demuregram.
Categories of Personal Data
We process, or our third-party providers process on our behalf, different kinds of Personal Data about Creators, Content Collaborators and Fans, which we have grouped together as follows:
Category of Personal Data Description
User Data
Creators and Content Collaborators
full name*
alias, if applicable
residential address
city of birth
country of birth
country of residence*
email address
telephone number
a copy of the government identity document that you provide to us*
a “selfie” of you holding your government identity document*
third-party social media handle / personal website address (used to further verify your age and identity and to help us better understand the content which you are likely to share on Demuregram)
signature on release forms if you feature in a Creator’s content*
Please note: Items marked with * will be requested for Content Collaborators where you are required to provide a release form.
Fans
email address
telephone number
Third-Party Onboarding Data
The following types of Personal Data are collected directly by our third-party providers during onboarding:
Creators and Content Collaborators
a copy of the government identity document that you provide to our third-party providers
a short .gif, taken from a “selfie” that you provide to our third-party providers
the results of the third-party age and identity verification process (pass / fail and reason for failing)
metadata associated with the third-party age and identity verification process (e.g. start and finish time)
Fans
where we conduct third-party age and identity verification of Fans, a copy of the government identity document that you provide to our third-party providers
where we carry out third-party age estimation, or third-party age and identity verification of Fans, a short .gif, taken from a “selfie” that you provide to our third-party providers
the results of the third-party age estimation process or third-party age and identity verification process (pass / fail and reason for failing)
metadata associated with the third-party age estimation process or third-party age and identity verification process (e.g. user start and finish time)
Please see Section 9 (our onboarding processes) for further information. Third-Party Onboarding Data and Technical Data does not include Face Recognition Data, as set out below.
Account Data
Creators
profile name
password
avatars and headers of your Creator account
your subscriptions, subscribers and referrals
posts that you have made to your Creator account
comments on posts made from your Creator account
chat messages between you and other users
customer support queries that you submit to us
Fans
profile name
password
avatars and headers of your Fan account
your subscriptions
comments on posts made from your Fan account
chat messages between you and other users
customer support queries that you submit to us
Financial Data
Creators
payment card details*
billing address
funds added to your wallet
bank account information
pay-out country
corporate or business entity name, country, identification number and identification type
VAT number
tax identification number and issuing country
W-9 form (for US Creators only)
1099-MISC form (for US Creators only)
1099-NEC form (for US Creators only)
Fans
payment card details*
billing address
funds added to your wallet
* Please note: Any payments made to view the content of Creators are processed by our third-party payment providers. We do not receive your full payment card number, payment card expiration date, or the security code. Instead, the payment provider provides us with a “token” that represents your account, your payment card’s expiration date, payment card type and the first six and last four digits of your payment card number.
Transaction Data
Creators
earnings
pay-out requests
payments made to your Creator account
payments made from your Creator account to other Creators
any failed payments
Fans
payments made from your Fan account to Creators
any failed payments
Technical Data
Creators and Fans
Internet or other electronic network activity information, including:
internet protocol (IP) address (and country code)
user agent
Usage Data
Creators and Fans
We use cookies where necessary to allow you to browse the Services and access certain pages of Demuregram. With your consent, we use non-essential cookies to enable us to recognise Referring Users, and Referred Creators, under the Referral Program in our Terms of Service.
More information on our use of cookies can be found in our Cookie Notice.
We currently do not use any cross-site tracking technologies and we do not sell Personal Data collected about you, or share Personal Data collected about you for cross-context behavioural advertising.
Face Recognition Data
Creators, Content Collaborators and Fans where applicable
As described in more detail in Section 9 (our onboarding processes), during onboarding, our third-party providers may use face recognition technology, so they can digitally verify you.
Face Recognition Data is collected by and remains with our third-party provider. We do not ourselves collect, receive, possess, or have access to Face Recognition Data at any time.
Our onboarding processes
CREATORS
We have processes in place that are intended to ensure that Creators on Demuregram: (i) are at least 18 years of age; and (ii) verify their identity. Before you can start a Creator account, we will:
Ask you to provide Creator User Data, as set out at Section 8 (categories of Personal Data).
Check your country of residence. This check is intended to ensure lawful access to Demuregram and the Services.
Ask you to provide Financial Data, as set out at Section 8 (categories of Personal Data). This is necessary so that payments can be made to Creators for content, and so that Creators can access their earnings via Demuregram. Financial Data is also collected as a verification and anti-fraud measure.
Ask you to go through a third-party age and identity verification process, as described below.
Check that you have not previously been banned from using Demuregram and our Services (e.g. for violating our Terms of Service).
CONTENT COLLABORATORS
We have processes in place that are intended to ensure that Content Collaborators on Demuregram: (i) are at least 18 years of age; and (ii) verify their identity. Before you can feature in content uploaded by a Creator we will ask you to go through a third-party age and identity verification process, as described below. You may also be required to provide a release form.
FANS
We have processes in place that are intended to ensure that: (i) all Fans on Demuregram are at least 18 years of age; and (ii) Fans in certain circumstances or locations verify their identity. Before you can start a Fan account, we will:
Ask you to provide Fan User Data, as set out at Section 8 (categories of Personal Data).
Check your country of residence. This check is intended to ensure lawful access to Demuregram and the Services.
Ask you to provide Financial Data, as set out at Section 8 (categories of Personal Data). This is necessary so that Fans can make payments to Creators. Financial Data is also collected as a verification and anti-fraud measure.
Ask you to go through a third-party process to gain further assurances of your age. This may include a third-party age and identity verification process, or third-party age estimation process, as described below. The specific process will depend upon your location, or other circumstances (e.g. if we detect suspicious activity on your account).
THIRD-PARTY AGE AND IDENTITY VERIFICATION
We use third-party providers to conduct age and identity verification.
This process involves our third-party provider collecting a short .gif, taken from a “selfie” and photo from a government identity document (in both cases, that you provide to the third-party provider). The third-party provider then uses Face Recognition Data to match the two images so they can digitally verify your age and identity.
As described at Section 8 (categories of Personal Data), we do not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.
Where permitted by applicable law, we receive from our third-party providers Third-Party Onboarding Data, as set out at Section 8 (categories of Personal Data), to maintain a record of the age and identity verification process.
THIRD-PARTY AGE ESTIMATION
For certain locations, we use third-party providers to conduct age estimation.
This process involves our third-party provider collecting a short .gif “selfie” (that you provide to the third-party provider) and using digital technology to estimate your age, which may involve the use of Face Recognition Data.
As described at Section 8 (categories of Personal Data), we do not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.
If you go through the third-party age estimation process, we will only receive the results of the process (pass / fail and reason for failing), to maintain a record of the age estimation process.
If you fail the third-party age estimation process (e.g. if you are over 18 years of age, but the technology has predicted that you look under a set threshold), you may have the option to go through the third-party age and identity verification process set out above.
MORE INFORMATION ON OUR ONBOARDING PROCESSES
Why does Demuregram use third-party face recognition technology?
The use of face recognition technology by our third-party providers is an important technological measure used in our wider onboarding processes for Creators and Fans. It is intended to ensure safety and security on Demuregram and our compliance with applicable laws.
We use third-party service providers to carry out age and identity verification, who carry out these services on our behalf, as data processors.
How does Face Recognition Data help to prevent fraud?
Face recognition technology reduces the possibility of fraudulent face image spoofing and the uploading of fraudulent government identity documents when individuals go through the onboarding process.
Where our third-party providers have identified possible fraud attempts (such as the use of fake or otherwise manipulated documents) our third-party providers may maintain a record of such attempts, including Face Recognition Data, for the purposes of detecting and preventing unlawful activity, and preventing fraudulent access to Demuregram.
Periodic authentication of your age and identity
During the time that you hold an account with us, we may require you to periodically authenticate your identity. If you have gone through the third-party age identity verification process, where permitted by applicable law our third-party providers may retain Face Recognition Data to enable you to authenticate your identity. Where this is retained, you do not need to provide the third-party provider with your government identity document again when authenticating your identity.
Withdrawing your consent: You may request the withdrawal of your consent to the retention of your Face Recognition Data for the purposes of subsequent authentication (and delete this) by contacting privacy@Demuregram.com. While withdrawing your consent to the retention of your Face Recognition Data will not affect your ability to complete a subsequent authentication process, it may require you to provide the third-party provider with your government identity document again during the authentication process.
How / why your Personal Data is used and lawful bases for processing
We process Personal Data for, or based on, one or more of the following legal bases:
Consent: Your consent is requested only in specific circumstances which includes, for example, the processing of: (i) Face Recognition Data by our third-party providers as part of the age and identity verification process for all Creators (and for Fans in certain circumstances or locations); and (ii) age estimation captures (which may involve the use of Face Recognition Data) by our third-party providers for Fans in certain locations. Please see Section 9 (our onboarding processes) for further information.
Performance of a contract: By using the Services, you have contracted with us through our Terms of Service, and we will process Personal Data to perform that contract (e.g. to fulfil transactions between Fans and Creators and process Creator earnings) and to enforce the terms of that contract.
Legitimate interests: We may process Personal Data if it is in our, or a third-party’s, legitimate interests (as detailed in the table below). This may include, for example, investigating and responding to a report made through our DMCA takedown procedure, to protect a Creator’s intellectual property rights.
Compliance with legal obligations: We may process Personal Data to comply with applicable law, rules and regulations in the locations where we operate (e.g. complying with financial / tax reporting requirements).
Task carried out in the public interest: We may process Personal Data as necessary for a task carried out in the public interest. This may include, for example, reporting illegal activity to relevant law enforcement authorities, other governmental authorities and non-governmental organisations.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
The table below indicates the purposes for which your Personal Data is processed and the legal justification for the processing. Some of the above grounds for processing will overlap and there may be several grounds which justify the processing:
Purpose / activity Lawful basis for processing
Account creation (both Creators and Fans). Performance of a contract
Creator and Content Collaborator age and identity verification and where applicable, subsequent authentication (specifically in relation to the processing of Face Recognition Data).
Please see Section 9 (our onboarding processes) for further information.
Consent
Fan age and identity verification and where applicable, subsequent authentication, in certain circumstances or locations (specifically in relation to the processing of Face Recognition Data).
Please see Section 9 (our onboarding processes) for further information.
Consent
Fan age estimation, in certain locations (specifically in relation to the processing of the age estimation capture, which may involve the use of Face Recognition Data).
Please see Section 9 (our onboarding processes) for further information.
Consent
Fan age verification (without third-party age and identity verification or third-party age estimation). Performance of a contract
Government identity document validity check and maintaining a record of the age and identity verification process. Performance of a contract
Maintaining a record of the age estimation process (for Fans in certain locations). Performance of a contract
Providing the Services, including the hosting of Creator content, the fulfilment of transactions between Fans and Creators and processing Creator earnings. Performance of a contract
Identifying Referring Users and Referred Creators under the Referral Program set out in our Terms of Service. Consent
More information can be found in our
Cookie Notice.
Providing technical support to Fans and Creators. Performance of a contract
Communicating with you about the Services, responding to support requests or, sharing information about the Services (e.g. providing you with updates to our Terms of Service and / or this Policy). Performance of a contract
Ensuring compliance with, and enforcing, our Terms of Service and other usage policies (e.g. our Acceptable Use Policy). Performance of a contract
Moderation and filtration:
text and content uploaded to Demuregram
livestreaming on Demuregram
content sent in chat messages on Demuregram
to monitor and investigate violations of our Terms of Service.
Performance of a contract
Filtration of text sent in direct messages on Demuregram to investigate violations of our Terms of Service. Performance of a contract
Removal from the Services of text and content uploaded by users that is identified as illegal, and suspending or deactivating those user accounts. Compliance with legal obligations
Performance of a contract
Removal from the Services of text and content uploaded by users that is identified as violating our Terms of Service and where appropriate, suspending or deactivating user accounts. Performance of a contract
Maintaining a record of banned users, to prevent further access to Demuregram. Legitimate interests
Reporting illegal activity to relevant law enforcement authorities, other governmental authorities and non-governmental organisations. Compliance with legal obligations
Legitimate interests
Task carried out in the public interest
Providing relevant information to, or responding to requests from / investigations by, relevant law enforcement authorities, other governmental authorities and non-governmental organisations. Compliance with legal obligations
Legitimate interests
Task carried out in the public interest
Preservation and sharing of Personal Data in the context of legal proceedings (e.g. litigation). Legitimate interests
Complying with applicable laws, rules and regulations. Compliance with legal obligations
Legitimate interests
Monitoring transactions and company network, systems, applications, and data, to: (i) detect malicious, deceptive, fraudulent, or illegal activity to protect information security and integrity, and user safety; and (ii) respond to / investigate incidents where appropriate. Legitimate interests
Substantial public interest
As necessary or appropriate to protect the rights and property of our users, us, and other third parties. Legitimate Interests
System maintenance and testing, reporting and hosting of data, to maintain, develop and improve the provision of the Services (e.g. safety, performance and functionality). Legitimate Interests
As necessary in the context of a possible sale, merger, acquisition, business reorganisation or group restructuring exercise. Legitimate Interests
Processing of Personal Data in connection with sponsorships, and our relationship with service providers, professional advisers and other third parties for business purposes (e.g. business contact information and correspondence). Performance of a contract
Legitimate Interests
Obtaining your Personal Data
We collect your Personal Data from the following categories of sources:
Directly from you: When you provide it to us directly to open an account and use the Services, when you update your Personal Data in your account, or by corresponding with us (e.g. User Data, Account Data). We may also process your Personal Data when you interact with us through our social media pages on third-party websites.
Automatically or indirectly from you: For example, through and as a result of your use of the Services (e.g. Transaction Data, Technical Data, Usage Data), if you sign-in to Demuregram via third-party single sign-in, or if you connect a third-party account to your Demuregram account.
From our service providers: For example, where permitted by applicable law, we receive Third-Party Onboarding Data and certain Technical Data from our third-party age and identity verification providers.
Sharing your Personal Data
We share Personal Data with the following categories of third parties:
Our third-party service providers: Such as our IT, payment processing, customer support, content and text moderation, tax automation, and age and identity verification / age estimation service providers. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely the receipt of services to support business functionality).
Our professional advisers: Such as our legal advisors, bankers, auditors, accountants, consultants, and insurers. Our professional advisors will process Personal Data as necessary to provide their services to us. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely the receipt of professional services).
Corporate: Relevant third parties in the event of a possible sale, merger, acquisition, business reorganisation or group restructuring exercise. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our and the relevant third parties’ legitimate interests (namely assessing and putting into effect potential transactions).
Our group companies: For the centralised coordination and management of our business, in accordance with the purposes set out at Section 8 (categories of Personal Data). These recipients will process Personal Data in the same way as set out in this Policy. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely coordinating the global operations of our business).
Relevant authorities, regulators and organisations: Relevant governmental authorities (including law enforcement and tax authorities), regulators, and certain non-governmental organisations (such as the National Center for Missing & Exploited Children (NCMEC)). These recipients will use your Personal Data in the performance of their regulatory, legal or otherwise charitable or not-for-profit role. Depending on the context, the lawful basis we rely on for sharing Personal Data with these recipients may vary. The processing may be necessary to comply with a legal obligation to which we are subject, necessary for our, or a third-party’s, legitimate interests, or may be in the interest of the wider public to do so. This may include, for example, reporting illegal content to / assisting with requests from, authorities, regulators and organisations, to protect the safety of our users and third parties, and complying with our financial / tax reporting requirements (e.g. DAC7, in the European Union).
International data transfers
We share your Personal Data within our group companies and to our third parties, as set out at Section 12 (sharing your Personal Data).
In some circumstances, this will involve transferring your data outside the UK, the EEA and Switzerland. We make those transfers: (i) to countries that have been deemed to provide an adequate level of protection for Personal Data; (ii) using appropriate safeguards; or (iii) where otherwise authorised by applicable law.
Please contact us using the contact details set out at Section 19 (assistance and contact information) if you would like further information on the specific mechanism used by us when transferring your Personal Data outside the UK, the EEA and Switzerland.
Your rights regarding Personal Data
You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights by contacting us using the contact details set out at Section 19 (assistance and contact information).
Under certain circumstances and subject to certain exemptions, you have the right to:
Withdraw your consent to the processing of your Personal Data: Please note that withdrawing your consent will not affect the lawfulness of any processing carried out before you withdraw your consent.
Request to know or access to your Personal Data: You may receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you: You may correct any incomplete or inaccurate Personal Data we hold about you.
Request deletion / erasure of your Personal Data: You may ask us to delete or remove Personal Data where there is no legitimate reason for us continuing to process it. You also may ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below). Please note that we may not always be able to comply with your request of deletion / erasure for specific legal reasons, for example if your account has been deactivated for violations of our Terms of Service. Please see Section 17 (retention of Personal Data) for further information.
Request the restriction of processing of your Personal Data: You may ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of some sections of your Personal Data to another party.
You also have the right to object to processing of your Personal Data where we are relying on a legitimate interest for the processing and there is something about your particular situation which makes you want to object to processing on this ground.
We do not process Personal Data that is subject to solely automated decision-making, where that decision-making is likely to have a legal or similarly significant effect on you.
You also have the right:
To lodge a complaint with a data protection regulator. For example, in the UK, this is the Information Commissioner’s Office (ICO) and in Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC). If you are resident in the EEA, you may wish to contact your local country or state-specific data protection regulator.
Depending on your location in the United States, to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights, or to appeal a decision we have made in connection with your privacy rights request. Further information on appeals is set out at Section 18 (additional U.S. State Privacy Disclosures).
Exercising your rights
If you would like to exercise your rights set out at Section 14 (your rights regarding Personal Data), you may do so by contacting us using the contact details set out at Section 19 (assistance and contact information).
If you submit the request yourself, please ensure that your request contains sufficient information to allow us to confirm your identity and properly understand, evaluate, and respond to it.
In order to verify your identity, we may at times need to request additional Personal Data from you, taking into consideration our relationship with you and the sensitivity of your request. In certain circumstances, we may decline a privacy rights request, particularly where we are unable to verify your identity.
If your request is made by a third-party authorised by you, we will also require proof that the third-party has permission to submit the request on your behalf (such as a signed document or a valid power of attorney evidencing that the third-party has authority to make the request).
Choices and control over your Personal Data
Modifying and deleting your Personal Data: If you have an account with us, you may update your account settings on Demuregram. Please note that changes to your settings may require some time to take effect.
Access to device information: You may control the Services’ access to your Technical Data through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation.
Email notification opt-out: We currently do not send emails for direct marketing purposes. However, we do send email notifications which are related to your account (e.g. for Creators, where you have a new subscriber, you have received a new tip, or somebody has renewed their subscription with you). You may opt-out of receiving certain types of email communications from us by changing your notification preferences on Demuregram. You may also email us using the contact details set out at Section 19 (assistance and contact information). Please include “E-mail notification opt-out” in the email’s subject line and include your name and your account email address in the body of the email.
Please note that you cannot opt-out of certain automated email notifications that are necessary to provide the Services or are otherwise required in accordance with applicable law (e.g. account verification, transactional communications, changes / updates to features of the service, technical and security notices).
Retention of Personal Data
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which it was collected, as set out in this Policy. The Personal Data that we retain and the length of time for which it is retained will be determined on a case-by-case basis, depending on the particular circumstances.
We determine the periods for which we normally retain Personal Data as follows:
Providing our Services: Where we need to use Personal Data to provide you with our Services, or specific parts of our Services, we will retain your Personal Data for the lifetime of your account or as long as necessary to provide you with the relevant feature or functionality of our Services.
Trust and safety: If you have (or we reasonably suspect that you have) violated our Terms of Service, or where we otherwise need to retain information to identify and report illegal activity or protect the safety of our users and third parties, we will retain certain Personal Data for as long as necessary to conduct our investigations, assist with any investigations by law enforcement or non-governmental authorities (e.g. NCMEC), and enforce any removal of offending users or content.
Compliance with applicable laws and regulatory obligations: For example: (i) identity record keeping / maintenance requirements in certain locations and financial / tax reporting requirements, which in some cases is up to 7 years; (ii) if we receive a valid legal request (such as a preservation order or search warrant, related to your account); (iii) complying with regulatory investigations or proceedings. We will delete your Personal Data sooner where a shorter retention period is required by applicable law.
Legal claims: Personal Data will be retained in accordance with applicable statutory limitation periods. In certain circumstances we may need to retain this longer, for example, to defend ourselves in litigation about a claim or complaint related to you.
Additional U.S. State Privacy Disclosures
Where required by law, these additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in the Policy by providing additional information about our Personal Data processing practices relating to individual residents of certain U.S. States. Unless otherwise expressly stated, all terms defined in this Policy retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, Personal Data does not include publicly available information or deidentified, aggregated or anonymised information that is maintained in a form that is not capable of being associated with or linked to you.
No sales for targeted advertising
We do not sell or share Personal Data for the purpose of displaying advertisements that are selected based on Personal Data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising”).
Sensitive information
Although sensitive information may be disclosed for a business purpose as described below, we do not sell or share sensitive information for the purpose of targeted advertising.
The following Personal Data elements we, or our service providers, collect may be classified as “sensitive” under certain privacy laws (“sensitive information”) including:
username and password;
social security number, driver’s licence number, and passport number;
government identifiers (such as driver’s licence numbers);
partial payment card number and the name registered with your payment card; and
Face Recognition Data (biometric information which is collected and processed by our third-party providers).
We use this sensitive information for the purposes set out at Section 10 (how / why your Personal Data is used and lawful bases for processing), to the extent necessary for the operation of our Services, to enter into and perform a contract with you, to comply with legal and regulatory requirements, to protect the safety of our users and third parties or as otherwise permissible for our own internal purposes consistent with applicable laws.
Deidentified information
We may at times receive, or process Personal Data, to create deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by applicable law.
Appeals
If you are a resident of certain U.S. States, you have the right to appeal decisions regarding your privacy requests. All appeal requests should be submitted using the contact details set out at Section 19 (assistance and contact information). If your appeal is denied, you may contact your local Attorney General.
Minors
Our Services are strictly intended for individuals 18 years of age or older. anyone under 18 years of age is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.
CALIFORNIA SPECIFIC DISCLOSURES
The following disclosures only apply to residents of the State of California:
Personal Data collection
California law requires that we provide disclosures to you about what Personal Data we collect by reference to the categories of Personal Data set forth within California law. To address this obligation, we have identified the relevant California Personal Data category for the Personal Data set out in more detail at Section 8 (categories of Personal Data):
Identifiers: such as your name, address, phone number, email address, passport or other government identity information including driver’s licence information, account information, or other similar identifiers.
Customer Records: Such as your driver’s licence number, passport number, partial debit card information, partial credit card information, bank account information or other payment or financial information.
Protected Classification Characteristics: Such as age, date of birth, and gender.
Commercial Information: Such as information about products or services purchased and your use of our Services.
Biometric Information: which is limited to Face Recognition Data, used by our third-party providers for age and identity verification purposes. Face Recognition Data remains with our third-party providers and we do not ourselves collect, receive, possess, or have access to this data.
Internet / Network Information: Such as device information, and log data.
Sensory Information: Such as pictures and videos (content) you upload to Demuregram.
Professional / Employment Information: Such as the business or organisation you are associated with and, where applicable, your title with that business or organisation and information relating to your role with the business or organisation.
Other Personal Data: Such as communication preferences, customer service and communication history, personal data an individual permits us to see when interacting with us through social media, Personal Data an individual provides us in relation to a question or request, and messages you send us through our Services or make available to us on social media.
Inferences: Such as information generated from your use of our Services.
We may disclose all of these categories of Personal Data for a business purpose to service providers or other third parties, as outlined in this Policy.
Disclosure of Personal Data
As set out at Section 12 (sharing your Personal Data), we may disclose the categories of Personal Data identified above to the following categories of third parties for various business purposes: our group and affiliated companies, service providers, our professional advisers, business partners, other businesses as needed to provide our Services, and certain third parties where you have provided consent, where it is in connection with a corporate transaction, or where we are required by law or in connection with other legal process.
Sources of Personal Data
We collect Personal Data directly from you, from your browser or device when you interact with our Services, and from our business partners and affiliates, third parties you direct to share information with us, and other third-party providers. For more information, please see Section 11 (obtaining your Personal Data).
Purpose for collection
We collect Personal Data about you for the purposes set out at Section 10 (how / why your Personal Data is used and lawful bases for processing).
Notice of financial incentives
As discussed above, we currently do not use any cross-site tracking technologies and we do not sell Personal Data collected about you, or share Personal Data collected about you for cross-context behavioural advertising. We do not currently send emails for direct marketing purposes.
We currently offer a Referral Program, whereby existing Creators of Demuregram can use their unique referral code to introduce people who are interested in becoming Creators on Demuregram, and the referring Creator will receive referral payments, based on the referred Creator’s earnings. The Referral Program is subject to our Terms of Service and any such referral payments are calculated, and limited, as described in the Referral Program Terms in our Terms of Service.
Any Personal Data associated with the referring Creator, or the referred Creator, is processed in accordance with this Policy.
We have determined that the value of the Referral Program is reasonably related to the value of the Personal Data we process in connection with the Referral Program (based on our reasonable but sole determination). We estimate the value of the Personal Data we receive and otherwise process in connection with the Referral Program by considering the expense we incur in collecting and processing the Personal Data, as well as the expenses related to facilitating the Referral Program.
You may exercise your rights in relation to your Personal Data as outlined in this Policy, and as applicable, by submitting a ticket through your account or by emailing privacy@Demuregram.com.
NEVADA SPECIFIC DISCLOSURES
Nevada law requires operators of online services to provide a way for Nevada residents to request to opt-out of the sale of Personal Data. Although we do not sell Personal Data, Nevada residents can still submit this type of opt-out request by contacting us using the details set out at Section 19 (assistance and contact information).
Assistance and contact information
We have appointed a Data Protection Officer (“DPO”) whose responsibilities include, together with our team of privacy specialists, responding to questions, requests, and concerns in relation to this Policy and our use of Personal Data.
If you have questions about this Policy, or how we process your Personal Data, please submit a ticket through your account or email us at privacy@Demuregram.com.
We have also appointed an EU Representative who may be reached as follows:
DAPR sp. z o.o.
Poland Company Number 0000688178
Zurawia 47 Street
00-680 Warsaw, Poland
fenix.eurep@dapr.pl
Last updated: July 2025