Attractr Privacy Policy

Effective Date: April 30, 2025

1. Welcome to Attractr!

Attractr ("we," "us," "our") is a platform connecting audiences, creators, and production companies in the performing arts community. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our platform and services (collectively, the "Services"). This Policy is part of our Terms of Use.

We are committed to protecting your privacy and handling your personal information responsibly and in accordance with applicable privacy laws, including Quebec's Act respecting the protection of personal information in the private sector (Law 25) and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

2. Our Privacy Officer

We have appointed a Privacy Officer who is responsible for overseeing our compliance with this Privacy Policy and applicable privacy laws. If you have any questions about this policy or our privacy practices, or if you wish to exercise your privacy rights, please contact our Privacy Officer:

  • Title: Data Protection Officer
  • Email: [email protected]
  • Mailing Address: 4060 boul Saint-Laurent #703, Montreal, Quebec, Canada, H2W 1Y9

3. Information We Collect

We collect personal information to provide and improve our Services. The types of information we collect depend on your interaction with Attractr:

a) Information You Provide Directly:

This includes details you enter when creating an account, setting up a profile, making purchases, or otherwise interacting with our Services. Required information varies based on your role (audience member, creator, production company admin) and generally includes:

  • First and last name
  • Email address
  • Date of birth (for age verification)
  • Phone number
  • Password
  • Region and location

You may optionally provide additional profile information like social media links, languages spoken, and a bio.

Social Sign-Up: If you sign up using Facebook or Google, we request access to your user ID, name, email, and profile picture from those services. You manage these permissions within your Facebook or Google account settings. Please review the privacy policies of Facebook and Google for their data handling practices.

Audience Members:

When subscribing or making purchases, you provide payment information (e.g., credit card details) directly to our secure payment partners (e.g., Stripe). Attractr stores only limited, tokenized payment details (like card expiry and postal code) for security. We also collect information about creators you support, memberships purchased, benefits received, and, if physical perks are offered, necessary shipping information (address, phone number).

Creators and Production Companies:

To set up a creator/production page, you provide details about your work and offerings. For payouts, you'll link an account with our payment partners (e.g., Stripe), which involves sharing personal data for identity verification. We may also request information for tax compliance (contact details, business/tax ID, citizenship, bank details).

b) Information Collected Automatically:

When you use our Services (website, apps, emails), we automatically collect technical and usage information:

  • IP address and approximate location derived from it
  • Browser type, device type, operating system
  • Language preferences
  • Referring web pages
  • Mobile carrier information (if applicable)
  • Search terms used on Attractr
  • Pages visited, interaction details (clicks, time spent)
  • Media engagement metrics (view time, session length)
  • Information collected via cookies and similar technologies (See Section 6: Cookies and Tracking Technologies).

This data helps us understand usage patterns, improve user experience, personalize content, and ensure security.

c) Messages and Comments:

We collect and store the content, timestamps, and associated activity data (e.g., views, interactions) of messages and comments sent, received, or tagged within the Attractr platform.

d) User Research, Surveys & Events:

We may invite you to participate in user research (interviews, usability tests) or surveys to improve Attractr. Participation is voluntary. We may also collect contact information and feedback at online or in-person events.

e) Information from Connected Third-Party Accounts:

If you connect social media accounts (e.g., Twitter, Facebook, YouTube, Instagram, TikTok) to your Attractr profile, we may collect and store profile info, follower counts, and engagement metrics as permitted by you via the third-party platform's authorization process. You can revoke these permissions at any time in the respective platform's settings.

f) Promotions:

Personal information collected during promotional campaigns run by Attractr on third-party platforms will be handled according to this Privacy Policy.

4. How We Use Your Information

We use your personal information for specific purposes, relying on appropriate legal bases (like your consent, contractual necessity, legitimate interests, or legal obligations):

  • Providing and Managing Services: To operate Attractr, verify identity, enable account access, process subscriptions and payments, deliver benefits (including merchandise), and provide customer support.
  • Communication: To send important service notifications, updates, security alerts, and support messages.
  • Personalization and Improvement: To personalize your experience, recommend creators or content, analyze usage trends, conduct research, and develop new features.
  • Marketing and Events: To market Attractr products and services (where consent is obtained, if required) and organize events. You can opt-out of marketing communications.
  • Safety, Security, and Compliance: To prevent fraud and abuse, enforce our Terms of Use, comply with legal and regulatory obligations (including tax reporting), respond to legal requests, and protect the rights and safety of Attractr, our users, and the public.
  • Accessibility: To accommodate users with disabilities if notified.

5. How We Share Your Information

Attractr does not sell your personal information. We share it only in the following circumstances:

With Creators and Production Companies:

If you subscribe to or engage with a creator/production company, we share necessary information with them to fulfill their offerings and manage their community, including:

  • Your full name, email address, and profile information.
  • Shipping address (if physical benefits are selected).
  • Phone number (if needed for engagement or event notifications, with your consent).
  • Membership details (tier, duration, etc., excluding full payment data).
  • Engagement analytics (views, interaction duration). Creators may use third-party services for benefit delivery; review their privacy policies.

Within Live Rooms/Communities:

Information like your profile details, creator credits, subscription status, badges, and interactions (comments, likes) may be visible to other members of a creator's community/Live Room, subject to access permissions.

Publicly:

Certain information may be public:

  • Aggregated/Anonymized Data: Non-identifiable usage statistics in reports or press releases.
  • User Profiles & Activity: Depending on your settings and role, your public profile (name, bio, social links), supported creators, reviews, ratings, comments, and likes may be visible. Creator pages include public details about offerings, member counts, etc.

With Service Providers:

We share information with third-party companies performing services on our behalf (e.g., hosting, security, payment processing, analytics, customer support). They are contractually obligated to protect the data and use it only for the purposes we specify.

For Legal Reasons:

We may disclose information if required by law, regulation, legal process (like a subpoena or court order), or governmental request. We may also share information to protect the rights, property, or safety of Attractr, our users, or others, and to detect or prevent fraud or security issues. We will notify users of such requests where legally permissible.

Business Transactions:

If Attractr is involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction, subject to the commitments in this Privacy Policy.

With Your Consent:

We may share information for other purposes if we have obtained your explicit consent.

With Connected Third-Party Services:

When you link external accounts, information is shared according to the permissions you grant.

With Team Members (Creators/Productions):

Creators can grant permissions to team members who may access page settings and associated data based on their assigned roles.

6. Cookies and Tracking Technologies

We use cookies and similar technologies (pixels, web beacons) to operate and improve the Services, understand usage, personalize content, and for security purposes.

Types of Cookies:

We use essential cookies (necessary for site function), performance/analytics cookies (to understand usage), functional cookies (to remember choices), and potentially marketing/targeting cookies.

Your Consent:

For non-essential cookies and tracking technologies, we will obtain your explicit consent before they are activated. Essential cookies do not require consent but are necessary for the platform to function.

Managing Cookies:

You can manage your cookie preferences through [Link to Your Cookie Settings/Management Tool - e.g., a banner or settings page]. You can also adjust settings in your browser, but disabling essential cookies may affect site functionality.

Third-Party Cookies:

Some third parties (e.g., analytics providers, social media widgets) may place cookies through our Services. Their use is governed by their own privacy policies. Links to common third-party policies (Facebook, Google, TikTok, etc.) are provided where relevant on our platform.

7. Your Privacy Rights (Quebec and Canada)

As Attractr is headquartered in Montreal, Quebec, Canada, we adhere to PIPEDA and Quebec's Law 25. Residents of Quebec and Canada have specific rights regarding their personal information:

  • Right to Access: You have the right to request access to the personal information we hold about you and receive details about how it's used and shared.
  • Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information.
  • Right to Withdraw Consent: Where we rely on consent, you have the right to withdraw it at any time (though this won't affect past processing).
  • Right to Erasure (De-indexing/Cease Dissemination): You have the right to request the deletion of your personal information or request that we cease disseminating it or de-index hyperlinks associated with your name under certain conditions (e.g., if collection was unlawful or violates a court order).
  • Right to Data Portability: You have the right to request a copy of the personal information you provided to us in a structured, commonly used, machine-readable format.
  • Right to be Informed: You have the right to be informed about our data practices, including data collection, usage, sharing, retention, and security measures, as outlined in this policy.
  • Right Regarding Automated Decision-Making: If we use your personal information to make decisions based solely on automated processing, you have the right to be informed, to request information about the processing, and to have the decision reviewed.

Exercising Your Rights:

To exercise any of these rights, please contact our Privacy Officer using the details in Section 2. We will respond to your request within 30 days, as required by law.

Verification:

To protect your privacy, we will need to verify your identity before processing your request. This typically involves logging into your account or providing other verifiable information. We reserve the right to deny requests if identity cannot be satisfactorily verified.

8. Data Security and Confidentiality Incidents (Breaches)

We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These include encryption, access controls, and secure storage.

However, no system is perfectly secure. In the event of a "confidentiality incident" (data breach) involving your personal information that presents a risk of serious injury, we will:

  • Take reasonable measures to reduce the risk of injury and prevent new incidents.
  • Notify the Commission d'accès à l'information du Québec (CAI) and any affected individuals as required by Law 25.
  • Maintain a register of all confidentiality incidents.

9. Data Retention and Destruction

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including providing our Services, complying with legal obligations (e.g., tax, accounting), resolving disputes, and enforcing our agreements.

When personal information is no longer needed for these purposes, we will securely destroy or anonymize it according to established procedures and applicable legal requirements. The criteria used to determine retention periods include the nature of the data, the purposes of processing, and relevant legal or operational needs.

10. Privacy Impact Assessments (PIAs)

In accordance with Law 25, Attractr commits to conducting Privacy Impact Assessments (PIAs) before acquiring, developing, or significantly redesigning any information system or electronic service delivery involving sensitive personal information. PIAs are also conducted before transferring personal information outside Quebec to ensure adequate protection.

11. International Data Transfers

Attractr is a global platform headquartered in Canada. By using our Services, your personal information may be transferred to, stored, and processed in Canada and potentially other countries where our service providers operate.

Transfers outside Quebec:

When transferring personal information outside Quebec, we conduct PIAs and ensure appropriate contractual or other safeguards are in place to protect the information, consistent with Quebec law.

EU/UK/Swiss Residents:

If you are in the European Economic Area (EEA), UK, or Switzerland, we process your data based on legal grounds such as contractual necessity, legitimate interests, legal compliance, or consent. When transferring data outside these regions, we rely on appropriate safeguards like Standard Contractual Clauses or adequacy decisions (Canada is recognized by the EU as providing adequate protection).

12. Children's Privacy

Attractr is not directed to children under the age of 13. Users must also be old enough to consent to data processing in their country (in Quebec, this age is generally 14; below this requires parental/guardian consent).

To create a page on Attractr or purchase memberships, users must be at least 18 years old or have permission from a parent or legal guardian. Access to content designated as Adult/18+ is restricted to users verified to be 18 or older. We do not knowingly collect personal information from children under 14 without parental/guardian consent. If we learn we have collected such information improperly, we will delete it.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. If we make significant changes, we will notify you (e.g., via email or a notice on the platform) before the changes take effect. Your continued use of Attractr after the effective date constitutes acceptance of the revised policy.

14. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact our Privacy Officer:

  • Title: Data Protection Officer
  • Email: [email protected]
  • Mailing Address: 4060 boul Saint-Laurent #703, Montreal, Quebec, Canada, H2W 1Y9