The controller of your data
The controller of personal data processed through kinkpass.com is the administrator of the kinkpass.com service. You can reach us about any privacy question or request at [email protected].
Categories of personal data
- Account data, such as your email address, password in hashed form, display name, plan, settings and hard-limit filters
- Creator and studio verification data, such as legal name, date of birth, government ID images, stage names, consent records and 2257 records for each performer, and payout details
- Billing data, such as plan, billing period, renewal dates and payment status; card numbers are entered with our payment processor and are not stored by KinkPass
- Usage data, such as sign-ins, device and browser type, IP address, pages visited and technical logs used for security
- Viewing data, such as which items you watched and for how long, used to split the creator pool by verified watch time and to power your collections, watch later list and feed
- Messages you send to [email protected] and reports you submit
Why we use your data
- To provide your account and the plan you chose, which is necessary to perform our contract with you
- To bill your subscription and prevent payment fraud, which is necessary for the contract and in our legitimate interest
- To verify the age, identity and consent of every performer and keep records required by 18 U.S.C. 2257, which is a legal obligation
- To calculate creator payouts from verified watch time, which is necessary for our contract with creators
- To keep the service secure, detect abuse and enforce our content policy, which is our legitimate interest and in some cases a legal obligation
- To answer your messages and reports, which is our legitimate interest in helping you
We do not sell your personal data, we do not share it for cross-context behavioral advertising, and we do not build advertising profiles.
Who receives your data
We share personal data only with service providers that help us run KinkPass, under contracts that limit their use of it to our instructions, and only to the extent each needs.
- A hosting provider that stores the service and its data
- A payment processor that handles card payments and subscriptions
- An email delivery provider that sends account and billing emails
- An identity verification provider that checks the age and ID of creators and performers
We also disclose data when the law requires it, for example to answer a valid legal request or to report illegal content to the authorities.
How long we keep data
Account data is kept while your account is open and deleted or anonymized within a reasonable period after you close it, unless we must keep it longer. Billing records are kept for as long as tax and accounting laws require. Performer verification and 2257 records are kept for the period required by 28 C.F.R. Part 75, which can extend beyond the life of an account. Security logs are kept for a limited period and then deleted.
Your privacy rights
Depending on where you live, you may have the right to know what personal data we hold about you, to get a copy, to correct it, to delete it, and to opt out of the sale or sharing of personal data or certain profiling. Residents of California, under the CCPA as amended by the CPRA, and residents of other US states with privacy laws have rights of this kind, and we honor them for every member regardless of state. We do not discriminate against anyone for using these rights.
Visitors from the European Union and the United Kingdom also have rights under the GDPR, including access, rectification, erasure, restriction, portability and objection, and the right to complain to a data protection authority. To use any right, write to [email protected] from the email address on your account. We may need to confirm your identity before acting.
Discretion by design
Your plan appears on card statements under a discreet billing descriptor without explicit words. Emails from KinkPass use neutral subject lines. Your viewing history, collections and filters are visible only to you, and creators see aggregated watch time, never the identity of individual members.
How we protect your data
We use encryption in transit, hashed passwords, restricted access to verification records, and logging of administrative access. Verification documents are available only to the staff who review them. No system is perfectly secure, so please use a strong, unique password and keep it private.
No one under 18
KinkPass is only for adults. We do not knowingly collect personal data from anyone under 18. If we learn that an account belongs to a minor, it is closed and its data is deleted, except where the law requires us to keep records.
Changes to this policy
We may update this policy when the service or the law changes. The date at the top shows the latest version, and significant changes are announced to members by email. See also the terms of service and the contact page.