Privacy Policy

Effective Date: September 06, 2025
Updated Date: May 7, 2026

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: privacy@pearlindustrynetwork.com (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, 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).
• Critical Messaging: Mandatory, non-marketing system-generated or automated communications required for account security, service integrity, and operation of the Association’s platforms and underlying systems, including all supporting services within its ecosystem.

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, device fingerprint and 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:

1. Operate the Platform – create/manage accounts, authenticate users, deliver member‑only features (directories, messaging, collaboration tools).
2. Vetting & Safety – verify age/identity (18+), contact references, evaluate risks, enforce policies, investigate reports, and deter fraud/abuse.
3. Networking & Discovery – power member search/discovery, recommendations, and collaboration features.
4. Payments & Billing – manage subscriptions, process payments, prevent chargebacks.
5. Trust & Quality – monitor for violations, test and improve features, analytics and performance, security tooling, and incident response.
6. Communications – send service/transactional notices (account, billing, policy updates) and community updates via email (opt‑out available for marketing).
7. Legal/Compliance – meet our legal obligations (privacy, anti‑spam, tax), respond to lawful requests, and protect our rights and members.
8. Account Security - we use your Email and phone number in order to send 2FA (Two Factor Authentication), High Priority account security notifications, Multi-Factor Authentication to ensure your account remains secure.

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 for any non-critical usage subject to legal/contractual limits.
• Critical Messaging: these messages are sent based on implied and explicit consent tied to an active account and cannot be opted out of while the account remains active.
• 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.

7) How We Share Information

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, or any purposes not explicitly authorized in writing.
• 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 Data Processing (Canada & U.S.)

• Information is stored and processed within North America, primarily in Canada and the United States, and may be transiently handled by distributed infrastructure (such as edge networks) to ensure security, performance, and reliability; information is disclosed to authorities only when legally required under applicable law, and where required by Alberta PIPA, additional details about out-of-Canada processing are available upon request.

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. Below are some examples of how long information is stored for, however these are examples only as local, state and federal law ultimately dictates how long data must be stored for compliance.

Illustrative Retention Schedule (subject to change):

• Account & Profile Data: active membership + 7 Years 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: 6 months (security/diagnostics).
• Support Tickets: 12 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 privacy@pearlindustrynetwork.com. 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 implement layered administrative, technical, and physical safeguards proportionate to the sensitivity of the information, including strong access controls, AES-256 encryption for data at rest and in transit (both internally and externally), hardened infrastructure, strict confidentiality obligations, and ongoing vendor risk assessment; while these measures are designed to provide a high level of protection, no security program can eliminate all risk or guarantee absolute security..

12) Children, Minors, CSAM & Exploitation Policy

The Platform is strictly limited to individuals who are at least eighteen (18) years of age or the age of majority in their jurisdiction, whichever is greater. All users may be subject to identity and age verification, including third-party verification services, at any time before or after account approval.

Pearl Industry Network maintains a strict zero-tolerance policy regarding Child Sexual Abuse Material (“CSAM”), child exploitation, grooming, trafficking, coercion, or any sexualized content, activity, communication, roleplay, depiction, or behavior involving minors or individuals represented, implied, or appearing to be minors. This prohibition applies regardless of whether the material is real, AI-generated, digitally altered, fictionalized, illustrated, animated, simulated, implied, or presented as fantasy content.

Users are strictly prohibited from:

• Uploading, sharing, storing, transmitting, requesting, advertising, promoting, linking to, or discussing CSAM or exploitative material involving minors;
• Attempting to exploit, groom, solicit, lure, manipulate, threaten, or communicate inappropriately with minors;
• Misrepresenting their age or identity to gain access to the Platform;
• Facilitating, organizing, encouraging, or promoting illegal sexual conduct involving minors in any form;
• Using the Platform to engage in trafficking, exploitation, coercion, abuse, extortion, or predatory conduct involving minors or vulnerable individuals.

Pearl Industry Network utilizes automated safety and moderation technologies, including AI-assisted image, video, text, metadata, and behavioural analysis systems, to detect, prevent, and investigate potential violations involving CSAM, exploitation, grooming, trafficking, or other prohibited conduct. By using the Platform, users acknowledge and consent to the use of such automated moderation and safety systems.

While Pearl Industry Network employs commercially reasonable efforts and industry-standard moderation technologies to identify prohibited material and conduct, no automated or manual moderation system can guarantee one hundred percent (100%) detection accuracy or prevention capability. Users acknowledge that false positives and false negatives may occur, and the Platform does not guarantee that all prohibited content or conduct will be identified immediately or before exposure. Pearl Industry Network reserves the right to take precautionary enforcement actions, including temporary restriction, suspension, content removal, escalation for human review, preservation of evidence, and reporting to authorities, where activity is reasonably suspected to violate this policy or applicable law.

Any suspected violation may result in immediate content removal, account suspension or permanent termination, preservation of evidence, and reporting to applicable law enforcement, regulatory authorities, child protection agencies, and reporting organizations, including but not limited to the National Center for Missing & Exploited Children (NCMEC), Cybertip.ca, and other relevant Canadian, United States, or international authorities, as required by applicable law.

Pearl Industry Network reserves the right to monitor, investigate, review, and disclose user information, content, communications, metadata, IP logs, payment information, device identifiers, and related records where reasonably necessary to investigate potential violations, protect user safety, comply with legal obligations, or cooperate with law enforcement investigations.

Users may report suspected CSAM, exploitation, trafficking, grooming, underage activity, or other child safety concerns by contacting abuse@pearlindustrynetwork.com . Reports are treated with priority and may be escalated to law enforcement without notice to the reported user.

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)

We comply with Canada’s Anti-Spam Legislation (CASL) and the U.S. CAN-SPAM Act by obtaining and honoring express and implied consents, clearly identifying senders, and including unsubscribe mechanisms. Under CASL, implied consent may apply for specified periods (e.g., up to two years after the last transaction or six months after an inquiry for Canadian commercial contacts) and express consent remains valid until withdrawn; under U.S. law, recipients must be given the ability to opt-out and opt-out requests are honored per legal timelines.

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): privacy@pearlindustrynetwork.com
• Media, Ethical, Moral or Illegal activity: abuse@pearlindustrynetwork.com
• 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) 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.

Last Updated: September 2025