Privacy Policy – Pearl Industry Network (PiN)

Effective Date: September 06, 2025

Plain‑English Summary: This Privacy Policy explains what personal information Pearl Industry Network ("PiN," "we," "us") collects, why we collect it, how we use and share it, where we store it, and the choices you have. We are an Alberta‑based, member‑only community for adult content creators and trusted industry allies operating primarily in Canada and the United States.

1) Who We Are & Scope

Controller/Organization: Pearl Industry Network (PiN), Edmonton, Alberta, Canada.
Contact: [email protected] (Privacy Officer)
Scope: This Policy applies to personal information we collect through our website, member portal, directories, messaging, vetting and safety operations, and related services (collectively, the Platform).
Audience: We serve adult creators and industry allies in Canada and the U.S. We do not target the EEA/UK at this time.

2) Key Definitions

Personal Information (PI): Information about an identifiable individual (e.g., name, contact details, profile data, images, IP address).
Sensitive Information: Information that, if misused, could cause significant harm (e.g., government ID, safety/vetting information, sexual life or orientation, payment tokens, precise location).
Member: An approved, vetted user with an active membership.
User Content: Profile information, images, text, and communications you upload or send through the Platform.
Service Provider: A third party processing data for us under contract (e.g., hosting, security, payments, analytics).

3) Categories of Information We Collect

Identification & Contact – name, handle/alias, email, phone, city/province/state, country.
Account & Profile – bio, professional categories, collaboration preferences, images (no minors), links to social profiles.
Vetting & Safety – references, results of reference checks, verification data (e.g., age/identity confirmations), safety flags/notes, enforcement history.
Transaction & Billing – membership plan, billing frequency, last four digits and expiry (via processor), billing address, payment confirmations.
Communications – messages, support tickets, reports/appeals, survey responses.
Technical – device type, browser, OS, IP address, log and diagnostic data, cookie identifiers, approximate location, actions taken on the Platform.
Partner Interactions – bookings, referrals, redemptions/discount eligibility (where applicable).
Public/Third‑Party Sources – public websites/socials you link, references you nominate, anti‑abuse signals, and service‑provider risk signals.

Examples:
• When applying, you provide references and links to your public creator profiles.
• When you message other members, we store the conversation for safety and moderation.
• When you pay membership dues, our processor collects your card details; we receive tokens/confirmations, not full card numbers.

4) Why We Collect Your Information (Purposes)

We use personal information to:

Operate the Platform – create/manage accounts, authenticate users, deliver member‑only features (directories, messaging, collaboration tools).
Vetting & Safety – verify age/identity (18+), contact references, evaluate risks, enforce policies, investigate reports, and deter fraud/abuse.
Networking & Discovery – power member search/discovery, recommendations, and collaboration features.
Payments & Billing – manage subscriptions, process payments, prevent chargebacks.
Trust & Quality – monitor for violations, test and improve features, analytics and performance, security tooling, and incident response.
Communications – send service/transactional notices (account, billing, policy updates) and community updates (opt‑out available for marketing).
Legal/Compliance – meet our legal obligations (privacy, anti‑spam, tax), respond to lawful requests, and protect our rights and members.

Note: We do not engage in interest‑based advertising on the public internet. Our analytics are for internal product and safety improvement.

5) Our Legal Framework (Canada/U.S.)

Canada (PIPEDA & Alberta PIPA): We follow the principles of Accountability, Identifying Purposes, Consent, Limiting Collection, Limiting Use/Disclosure/Retention, Accuracy, Safeguards, Openness, Individual Access, and Challenging Compliance.
Consent: We rely on express consent where required (e.g., joining as a member, marketing emails) and implied consent where appropriate for obvious purposes (e.g., operating your account). You may withdraw consent subject to legal/contractual limits.
U.S. State Laws: We design our practices to be consistent with evolving U.S. state privacy laws (e.g., CA/VA/CO/CT). If and when those laws apply to us, we will honor applicable rights and disclosures.

6) Cookies & Similar Technologies

We use:

Essential cookies to sign you in, keep sessions, and secure the Platform.
Functional/Preference cookies to remember settings.
Analytics/Performance to understand feature usage and improve reliability.

Your choices: You can control cookies through your browser settings. Blocking some cookies may break critical features. Where required, we present consent controls for non‑essential cookies. We do not use third‑party advertising cookies.

We share personal information only as described below:

Within PiN with staff who need access to perform their duties (least‑privilege).
Service Providers under contract (hosting, storage, security, payments, analytics, email/SMS vendors, background/vetting tools). Providers must protect information and may not use it for their own purposes.
Members (Directory & Messaging): Your member profile (fields you choose to publish) is visible to other members. Messaging content is visible to conversation participants and to PiN for trust/safety.
Partners/Allies: When you engage a partner via the Platform, we may share limited information needed to facilitate the engagement (e.g., your name, contact, eligibility for member perks).
Legal/Compliance: To comply with law, enforce our Terms/Policies, protect members and the Platform, and respond to lawful requests.
Business Transactions: In a merger, acquisition, or reorganization, information may be transferred subject to this Policy and applicable law.

We do not sell personal information or share it for cross‑context behavioral advertising. If this changes, we will update this Policy and provide state‑law opt‑outs where applicable.

8) International Transfers (Canada ⇄ U.S.)

We may store and process information in Canada and the United States. When we use service providers outside Canada, we require contractual protections and we disclose that your information may be subject to lawful access by foreign authorities. Where Alberta PIPA requires it, we notify you about out‑of‑Canada transfers and how to obtain further information.

9) Retention

We keep personal information only as long as needed for the purposes described, to meet legal/accounting obligations, and to maintain a safe community. When no longer required, we anonymize or securely delete it.

Illustrative Retention Schedule (subject to change):

Account & Profile Data: active membership + 24 months after closure.
Vetting/Safety Records (including reports & enforcement): up to 7 years after last action for risk management and legal holds.
Billing Records: 7 years (tax/audit).
Log/Telemetry: 12–24 months (security/diagnostics).
Support Tickets: 24 months after resolution unless tied to enforcement.

10) Your Rights & Choices

Depending on where you live and applicable law, you may have the right to:

Access the personal information we hold about you.
Correct inaccurate information.
Withdraw consent (we’ll explain impacts, e.g., loss of membership if essential processing is withdrawn).
Request deletion where permitted (subject to legal holds and safety obligations).
Opt out of marketing communications at any time (unsubscribe links).

How to exercise rights: Email [email protected]. We may ask for verification information. We will respond within timelines required by law.

State‑specific: If U.S. state privacy laws (e.g., California, Virginia, Colorado, Connecticut) apply to us and to you, you may also have rights to know/access, delete, correct, and opt‑out of sale/share/targeted advertising. We currently do not sell/share personal information. If that changes, we will honor applicable opt‑outs, including browser‑level signals (e.g., Global Privacy Control) where required.

11) Security

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including: access controls, encryption in transit, hardened infrastructure, employee confidentiality obligations, and vendor due diligence. No system is 100% secure; we cannot guarantee absolute security.

12) Children & Age Requirements

The Platform is 18+ only. We do not knowingly collect information from anyone under 18. If we learn that a minor has provided personal information, it will immediately be deleted and access will be terminated.

13) Automated Decision‑Making

We use automated tools to assist moderation, fraud prevention, and trust & safety. Final enforcement decisions include human review. We do not make solely automated decisions that produce legal or similarly significant effects without human involvement.

14) Anti‑Spam (Canada – CASL)

If we send commercial electronic messages, we obtain the required consent, identify the sender, and include an unsubscribe mechanism. You can opt out at any time. Service/transactional notices (e.g., receipts, policy updates) may be required and are not marketing.

15) Data Breaches

If a breach of security safeguards creates a real risk of significant harm, we will notify affected individuals and report to the appropriate regulators as required by law (e.g., Canada – PIPEDA; Alberta – PIPA). We also keep internal breach records as required.

16) Links & Third‑Party Services

Our Platform may contain links to third‑party sites or integrate third‑party tools (e.g., payment, scheduling, analytics). Those third parties’ privacy practices are governed by their own policies. Review them carefully before sharing information.

17) Changes to This Policy

We may update this Policy to reflect changes to our practices or legal requirements. We will post the updated Policy with a new Effective Date and, where changes are material, provide additional notice (e.g., email or in‑product).

18) Contact & Complaints

Privacy Officer (PiN): [email protected]
Canada (federal – PIPEDA) complaints: You may contact the Office of the Privacy Commissioner of Canada (OPC).
Alberta PIPA complaints: You may contact the Office of the Information and Privacy Commissioner of Alberta (OIPC).

We encourage you to contact us first so we can work to resolve your concern.

19) Supplemental Disclosures (California, Virginia, Colorado, Connecticut)

Applicability: These disclosures apply if and when the respective law covers PiN and you are a resident of that state.

Categories Collected: See Section 3.
Sources: You, your devices, references you nominate, public sources you link, and service providers.
Purposes: See Section 4.
Disclosures for Business Purposes: To service providers and partners as described in Section 7.
Sale/Share/Targeted Ads: We do not sell or share personal information or engage in targeted advertising off‑platform. If this changes, we will provide a “Do Not Sell or Share My Personal Information” link and honor required browser signals.
State Rights: Access/know, delete, correct, portability; opt out of sale/share/targeted advertising (if applicable); and non‑discrimination for exercising rights.
Appeals (where required): If we deny your state‑law request, you may appeal by replying to our decision email; we will respond within the required timeline.

20) Examples & FAQs (Informative Only)

Q: Why do you keep vetting records for years?
A: To protect members, we maintain safety and enforcement records for a reasonable period (see Section 9) to identify repeat bad actors and comply with legal holds.

Q: Can other members see my email or phone?
A: Only if you choose to publish it in your member profile or share it in messages. Otherwise, it remains private.

Q: How do I stop marketing emails?
A: Click the unsubscribe link in the email or update your preferences in account settings.

Q: Do you use my content for advertising?
A: We may showcase member success stories with consent, but we do not run third‑party ads or sell your data.

Incorporated Policies

This Privacy Policy works together with our Terms of Service, Code of Conduct, Community Guidelines, and Copyright/IP Policy. When in doubt, this Policy governs how we handle personal information.

Privacy Policy