⚠️ DRAFT — FOR REVIEW PURPOSES
Privacy law varies significantly by jurisdiction (GDPR, CCPA, state-level laws). You should consult a legal professional familiar with SaaS and adult compliance regulations to customize it for your specific jurisdiction before relying on it exclusively.
Table of Contents
- Introduction
- Information We Collect
- How We Use Information
- AI Features and Data Use
- How We Share Information
- Data Storage and Security
- Your Privacy Rights
- Cookies and Tracking
- Children's Privacy
- International Data Transfers
- Adult Content Industry Acknowledgment
- Changes to This Privacy Policy
- Contact Us
1 Introduction
My Content Tools, LLC ("Company," "we," "us," or "our") respects your privacy. This Privacy Policy describes how we collect, use, disclose, and protect information when you use mycontenttools.com, My Content Tools (MCT), and Model Release Pro (MRP) (collectively, the "Services").
By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Services.
2 Information We Collect
2.1 Information You Provide Directly
- Account Information: name, email address, business name, billing address, payment information (processed by Lemon Squeezy — we do not store full payment card details)
- Studio Profile: business name, DBA, custodian of records, compliance officer information, mailing address, phone number
- Model and Performer Records: when you use MRP, you input data about models (name, date of birth, government ID information, contact details, payment information, tax identifiers). This data is stored under your studio account.
- Communications: when you contact us via email or support channels
- User-Generated Content: captions, descriptions, AI persona configurations, custom forms, signatures, and other content you create through the Services
2.2 Information Collected Automatically
- Device Information: device type, operating system, browser type, screen resolution
- Usage Data: features used, actions taken within the Services, error logs, performance metrics
- Log Data: IP address, access times, pages viewed
- Cookies and Similar Technologies: session cookies, authentication tokens, preference cookies (see Section 8)
2.3 Information from Third Parties
- Payment Processor (Lemon Squeezy): order confirmation, payment status, subscription details
- Authentication Providers (if used): profile information you authorize them to share
- Platform Integrations: when you connect MCT to platforms like Twitter/X or Google Drive, we receive authentication tokens and the data those platforms expose per your authorization
2.4 Information You Capture on Behalf of Others
When you use MRP to capture model release information, you collect personal information from third parties (performers). You are responsible for:
- Obtaining proper consent from those individuals before capture
- Providing them with required privacy notices under applicable law
- Maintaining the data per your retention obligations
- Honoring any data subject requests from those individuals
We process this data on your behalf as a data processor — you remain the data controller.
3 How We Use Information
We use the information we collect to:
- Provide, maintain, and improve the Services
- Process subscriptions, payments, and billing
- Communicate with you about your account, updates, security alerts, and support
- Send marketing communications (with your consent, where required by law)
- Detect, prevent, and respond to fraud, abuse, and security threats
- Comply with legal obligations
- Analyze usage trends to improve the Services
- Train and improve AI features (see Section 4 — limited and opt-out available)
- Enforce our Terms of Service and other agreements
4 AI Features and Data Use
The Services include AI-powered features (social post generation, fan reply automation, persona builder, description guides, etc.). Important details:
4.1 Local AI Processing
MCT's AI features run primarily through Ollama, a local AI runtime installed on your Mac. Your data never leaves your machine for these features. This is by design and is a core part of our privacy commitment.
4.2 Cloud AI Features (Optional)
Certain premium features may optionally use cloud-based AI providers (xAI/Grok, etc.). When enabled:
- We send only the minimum data required for the feature
- Cloud AI providers are bound by their own privacy policies
- We do not retain copies of prompts or outputs beyond what's necessary
- You can disable cloud AI in Settings at any time
4.3 No AI Training on Your Data
We do not use your data, content, or model records to train AI models — neither our own nor those of third-party providers. Cloud AI calls are made with no-training flags where supported by the provider's API.
4.4 AI Output Disclaimer
AI-generated content may contain errors. You are responsible for reviewing all AI outputs before use or publication.
6 Data Storage and Security
6.1 Where Data Is Stored
- MCT (Desktop): Data is stored locally on your Mac in a SQLite database. Nothing leaves your machine unless you explicitly enable cloud features or integrations.
- MRP (Mobile): Data is stored in Firebase Cloud Storage and Firestore, hosted in Google Cloud data centers (primarily United States).
- Backups: We maintain reasonable backup systems for MRP cloud data. MCT users are responsible for their own backups.
6.2 Security Measures
We implement industry-standard security measures including:
- AES-256 encryption for data at rest in Firebase
- TLS encryption for data in transit
- Firebase App Check to restrict API access to verified app instances
- Tenant-isolated security rules (studio-scoped data access)
- Audit logging of compliance-related actions
- Regular security reviews and updates
However, no system is 100% secure. We cannot guarantee absolute security and are not liable for unauthorized access despite our reasonable efforts.
6.3 Data Retention
- Account Data: retained while your account is active and for a reasonable period after termination
- Subscription Records: retained as required for tax and accounting purposes (typically 7 years)
- Model Release Records: retained per 2257 compliance requirements — you are responsible for determining retention periods
- Logs: retained for security and audit purposes, typically 90 days
- Marketing Data: retained until you opt out
You may request deletion of your data as described in Section 7.
7 Your Privacy Rights
Depending on your location, you may have certain rights regarding your personal information:
7.1 General Rights
- Access: Request a copy of personal data we hold about you
- Correction: Request that we correct inaccurate information
- Deletion: Request deletion of your account and associated data (subject to legal retention requirements)
- Portability: Request a copy of your data in a portable format
- Objection: Object to certain uses of your data
- Restriction: Request that we restrict processing of your data
7.2 California Residents (CCPA/CPRA)
If you are a California resident, you have additional rights:
- Right to know what personal information is collected, used, shared, or sold
- Right to delete personal information held by us
- Right to opt out of the sale of personal information (we do not sell personal information)
- Right to non-discrimination for exercising your privacy rights
- Right to correct inaccurate personal information
To exercise these rights, contact us at privacy@mycontenttools.com.
7.3 European Economic Area (GDPR)
If you are in the EEA, you have rights under the General Data Protection Regulation including those listed in Section 7.1. The legal bases for our processing include:
- Performance of a contract (providing the Services)
- Legitimate interests (improving the Services, fraud prevention)
- Consent (for marketing communications)
- Legal obligation (compliance with applicable laws)
You have the right to lodge a complaint with your local data protection authority.
7.4 How to Exercise Rights
Contact us at privacy@mycontenttools.com with your request. We will respond within applicable legal timeframes (typically 30 days for GDPR, 45 days for CCPA). We may need to verify your identity before processing.
8 Cookies and Tracking
We use cookies and similar technologies for:
- Essential cookies: authentication, session management (required for the Services to function)
- Preference cookies: remembering your settings
- Analytics cookies: understanding how the Services are used (optional, where required by law)
You can control cookies through your browser settings. Disabling essential cookies may break Service functionality.
9 Children's Privacy
The Services are not intended for individuals under eighteen (18) years of age. We do not knowingly collect personal information from minors. If we learn we have collected such information, we will delete it immediately.
If you believe a minor has provided us with personal information, contact us at privacy@mycontenttools.com.
10 International Data Transfers
If you are located outside the United States, your information may be transferred to and processed in the U.S. or other countries where data protection laws may differ from those in your jurisdiction. By using the Services, you consent to such transfers.
For transfers from the EEA, we rely on Standard Contractual Clauses or other approved transfer mechanisms.
11 Adult Content Industry Acknowledgment
Many of our users operate adult content production businesses. We acknowledge the unique privacy considerations of this industry:
- We treat all customer business relationships with the highest level of confidentiality
- We do not publicly disclose customer identities or business associations
- We resist overly broad data requests from third parties to the extent legally permissible
- We maintain payment processing relationships designed to minimize merchant-of-record exposure to your business
That said, we comply with valid legal process and regulatory requirements (including 18 U.S.C. § 2257 inspection rights).
12 Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email and/or in-product notice with at least thirty (30) days' notice before taking effect. The "Last Updated" date at the top reflects the current version.
Your continued use of the Services after changes take effect constitutes acceptance.
13 Contact Us
For privacy-related questions, requests, or concerns:
My Content Tools, LLC
Privacy Officer: privacy@mycontenttools.com
General Support: support@mycontenttools.com
Miami, Florida
For GDPR-related inquiries, we will respond within 30 days. For CCPA-related inquiries, we will respond within 45 days.