1. Who we are

Madkier Visuals Entertainment Ltd is the data controller for personal data processed through SplitClips. This policy explains what we collect, why, and your rights under UK GDPR and the Data Protection Act 2018.

2. What we collect

• Account data: username, email address, password (encrypted), profile details you choose to add.
• Age assurance data (all users): before you can access explicit content we run an automated facial age-estimation check through our provider, Didit. The facial image is processed by Didit for that purpose and is not stored by us; we keep only the outcome (passed / not passed), the date and the check's reference number. Where the estimate is borderline, Didit may ask for an identity document instead.
• Verification data (Sellers, and Buyers who withdraw earnings): a photo of a government-issued ID, a selfie holding it, and the full name and date of birth as shown on the document. Seller records are retained as required by our 2257 Compliance Statement.
• Transaction data: SplitCoin purchases, sales, tips, withdrawal requests, and wallet balances. We do not store full payment card details — these are handled directly by our payment processor.
• Content: videos, photos, messages (including photos and videos sent in messages), and posts you upload.
• Payout data: the legal name, address and payout account details you give us to receive earnings. We keep a one-way, non-reversible fingerprint of payout accounts to detect banned users returning under a new account.
• Usage data: login times, IP address, device/browser information, pages visited.

3. Why we process it

We process your data to: provide and operate the Platform (contract performance); verify age and identity (legal obligation); prevent fraud and abuse (legitimate interest); and communicate with you about your account (contract performance / legitimate interest).

3A. Messages and monitoring

Messages sent through SplitClips are stored on our systems. They are automatically scanned for indicators of off-platform payment or contact sharing, coercion or threats, arranging to meet in person, and any content involving or referring to minors. Conversations that trigger these checks may be reviewed by our staff, who may read the full conversation for context, for the purposes of enforcing our Terms of Service, protecting users, resolving disputes, and complying with our legal duties (including under the Online Safety Act 2023). Photos and videos sent in messages are stored with the conversation (videos with our video hosting provider, Bunny.net) and may be reviewed in the same way and for the same purposes. Where a warning is issued, a record is kept on the account concerned. We do not read messages for any other purpose, and we do not share their contents with third parties except where required by law or to report suspected criminal activity to the relevant authorities. Our lawful basis for this processing is our legitimate interest in keeping the Platform safe and lawful, and, where relevant, compliance with a legal obligation.

4. Who we share it with

We share data only with the providers we need to run the Platform, each under a contract that limits what they may do with it, and with law enforcement or regulators where legally required. We do not sell your personal data to third parties. Our providers are:

• Didit — age assurance and identity checks.
• Bunny.net (BunnyWay d.o.o., Slovenia) — storage, conversion and delivery of videos, including clips, custom orders and videos sent in messages. Video is stored in the EU.
• Liquid Web — hosting of the Platform and its database (UK data centre).
• 2257Sentry — third-party custodian of records under 18 U.S.C. § 2257 (Seller verification records).
• Our payment processor — to process card payments and payouts; we do not store full card details.
• Bunny Fonts — delivery of the typeface used on the Platform (receives only the standard request data any web server receives).

5. How long we keep it

Account and transaction data is retained for as long as your account is active and for a reasonable period afterward for legal and accounting purposes; sales records are retained indefinitely for tax, dispute and fraud-prevention purposes. Specifically:

• Seller verification records (ID, selfie, name and date of birth) are retained for at least seven years after the Seller's content is last made available, as required under 18 U.S.C. § 2257, including after the account is deleted.
• Payout details (bank or Paxum) are deleted as soon as a withdrawal is paid or rejected; only the non-reversible fingerprint described above is kept.
• Messages and their photos and videos are kept for as long as the conversation exists.
• Playback records — each time an account is authorised to play a paid clip we record the account, the clip, the time, the IP address and the device type. We keep these for 12 months and use them only to investigate unauthorised copying or sharing of Content and payment disputes (legitimate interests: protecting creators' work and preventing fraud).
• Custom-order reports — when a Buyer raises an undelivered Custom Order with us, the report, any withdrawal of it and our resolution are kept with the order for 24 months, so that disputes and payment reversals can be evidenced.
• Dormant accounts: purchased SplitCoins expire after 12 months without a login; earned SplitCoins are released after 24 months; accounts are deleted after 36 months, in each case after warnings by email.
• Banned accounts: the account details, ban reason and verification records are retained after deletion to prevent the person returning under a new account.

6. Your rights

Under UK GDPR, you have the right to: access the personal data we hold about you (Article 15); request correction of inaccurate data (Article 16); request erasure, subject to our legal retention obligations (Article 17); request restriction of processing (Article 18); receive your data in a portable format (Article 20); object to processing based on legitimate interests (Article 21); and not be subject to a decision based solely on automated processing which produces legal or similarly significant effects — our age-estimation check operates with a human-reviewable fallback and is not used to make any other decision about you (Article 22). To exercise any of these rights, contact support@splitclips.co.uk. We will respond within one month, save where an extension is permitted by law.

7. Cookies

We use cookies necessary for the Platform to function: login sessions, cart contents, and a short-lived "return here" cookie that remembers which clip or creator you were heading to when you signed up or topped up your wallet (it lasts up to two days and is deleted as soon as it is used). Where applicable we also use analytics cookies to understand site usage. You can control cookies through your browser settings.

8. International transfers

Video and age-assurance processing takes place in the UK or EU. Some providers are based outside the UK/EEA — Liquid Web and 2257Sentry (United States) — and where data reaches them we rely on their standard contractual safeguards (the UK International Data Transfer Addendum / EU Standard Contractual Clauses) as required by UK GDPR.

9. Children

SplitClips is strictly for users aged 18 and over. We do not knowingly collect data from anyone under 18. If we become aware that we have, we will delete it immediately.

10. Security

We take reasonable technical and organisational measures to protect your data, including encrypted password storage and access controls on sensitive verification records. In the event of a personal data breach likely to result in a risk to your rights, we will notify the Information Commissioner's Office within 72 hours of becoming aware, and will notify you directly without undue delay where the breach is likely to result in a high risk to you.

11. Changes to this policy

We may update this policy from time to time. Material changes will be notified through the Platform.

12. Contact

Madkier Visuals Entertainment Ltd
Ground Floor, Radley House, Richardshaw Road, Leeds, LS28 6LE
support@splitclips.co.uk

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk, or by calling 0303 123 1113.