Frshpose Privacy Policy

Effective Date: 21 November 2025

Frsh Labs Limited ("we", "us", "our" or "Frshpose") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Frshpose website, mobile applications, and related services (collectively, the "Platform").

We are the data controller for personal data processed through the Platform. Frsh Labs Limited is a company registered in England and Wales with company number [INSERT COMPANY NUMBER] and registered office at 128 City Road, London, EC1V 2NX.

If you have any questions about this Privacy Policy or our data practices, please contact us at frshpose@gmail.com or using the details in the "Contact Us" section below.

1. Information We Collect

We collect the following categories of personal data:

1.1 Information You Provide Directly

  • Account information: name, email address, username, password, profile picture, and any biography or other details you add.
  • Creator-specific information: payment details (e.g., PayPal or bank account information for payouts), tax information (where required), and identity verification documents if needed for high-volume creators.
  • Transaction information: records of Pose Packs you purchase or sell.
  • Communications: messages you send to us (e.g., support requests) or reviews/ratings you leave.
  • Any other information you voluntarily provide (e.g., when participating in surveys or promotions).

1.2 Information Collected Automatically

  • Usage data: IP address, browser type, device information, operating system, referring URLs, pages viewed, time spent on pages, and clickstream data.
  • Cookies and similar technologies: We use essential, functional, and analytics cookies (see section 7).
  • Log data: Server logs including access times and error reports.

1.3 Information Related to AI Services

  • When you upload Pose Packs, we process the content (including any images or metadata) using automated AI tools for validation and moderation purposes (e.g., to detect prohibited content or low quality).
  • Inputs and outputs from AI-generated Pose Packs (if you create or purchase them) may be temporarily processed and stored for quality control and improvement of our AI systems.

Note: We do not knowingly collect personal data from children under 18. The Platform is intended for users aged 18 and over.

2. How We Use Your Information

We use your personal data for the following purposes and legal bases under UK GDPR:

Purpose Legal Basis
To create and manage your account Performance of contract
To process purchases, provide access to Pose Packs, and handle payouts to Creators Performance of contract
To moderate and validate uploaded content (including using AI tools) Legitimate interests (maintaining Platform safety and quality)
To detect and prevent fraud, abuse, or security risks Legitimate interests (Platform security) and legal obligations
To provide customer support Performance of contract and legitimate interests
To send transactional emails (e.g., purchase confirmations, payout notifications) Performance of contract
To improve the Platform and develop new features (including training AI moderation tools on anonymised data where possible) Legitimate interests (service improvement)
Analytics and performance monitoring Legitimate interests (understanding usage)
Marketing communications (only with your consent) Consent
Compliance with legal obligations (e.g., tax reporting, law enforcement requests) Legal obligation

3. Sharing Your Information

We share personal data only in limited circumstances:

  • Service Providers: Payment processors (e.g., Stripe, PayPal), cloud hosting providers, analytics tools (e.g., Google Analytics), and AI moderation service providers. These providers are contractually required to protect your data.
  • Creators and Buyers: Limited profile information (e.g., username, profile picture) is visible publicly on the Platform. Transaction details are shared only between the relevant Buyer and Creator.
  • Legal Requirements: If required by law, court order, or regulatory authority.
  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction.

We do not sell your personal data.

4. International Data Transfers

Frsh Labs Limited is based in the United Kingdom. Some of our service providers may process data outside the UK/EEA (e.g., in the United States). Where we transfer personal data to countries without an adequacy decision, we use UK International Data Transfer Agreements (IDTA) or the EU Standard Contractual Clauses, along with supplementary measures where required.

5. Data Retention

We keep your personal data only as long as necessary:

  • Account data: Until you delete your account + 180 days (for legal/tax purposes).
  • Transaction records: Up to 7 years (for tax and accounting compliance).
  • Uploaded Pose Packs and access licences: For the duration of the listing + 180 days after removal.
  • AI validation logs: Up to 90 days (unless needed longer for dispute resolution).

After these periods, data is securely deleted or anonymised.

6. Your Rights

Under UK GDPR you have the right to:

  • Access your personal data
  • Rectify inaccurate data
  • Erase your data ("right to be forgotten")
  • Restrict processing
  • Object to processing (including for marketing)
  • Data portability
  • Withdraw consent (where processing is based on consent)
  • Lodge a complaint with the UK Information Commissioner's Office (ico.org.uk)

To exercise these rights, contact us at frshpose@gmail.com. We will respond within one month.

7. Cookies and Tracking Technologies

We use cookies and similar technologies:

  • Essential cookies: Required for login, security, and basic functionality.
  • Functional cookies: Remember your preferences.
  • Analytics cookies: Help us understand how the Platform is used.

You can manage cookies via your browser settings or our cookie banner. Rejecting non-essential cookies may affect Platform functionality.

8. Security

We implement appropriate technical and organisational measures (e.g., encryption, access controls, regular security audits) to protect your data. However, no online service can be 100% secure.

9. Changes to This Privacy Policy

We may update this Policy from time to time. Material changes will be notified by email or a prominent notice on the Platform. Your continued use after changes constitutes acceptance.

10. Contact Us

Data Protection Contact

frshpose@gmail.com

Frsh Labs Limited
128 City Road, London, EC1V 2NX
United Kingdom

For complaints: Information Commissioner's Office (ico.org.uk/make-a-complaint).

Thank you for trusting Frshpose with your personal data.

Frsh Labs Limited
Company Registration Number: [INSERT]
Registered in England and Wales