Privacy Policy

Last updated: September 18th, 2025

1. Introduction

Furtiv.me (“we,” “our,” or “the Platform”) is operated by HETA SARL, a company registered in Paris, France, with its registered office at 4 Square Charles Laurent, 75015 Paris, France.

We are committed to protecting your privacy and ensuring compliance with:

• The General Data Protection Regulation (GDPR – EU 2016/679),
  
• The French Data Protection Act (Loi Informatique & Libertés).
  

This Privacy Policy explains what personal data we collect, the legal bases for processing, how we use it, how long we keep it, and the rights you have over your data.

📍 Data Controller: HETA SARL – privacy@furtiv.me

📍 Data Protection Officer (DPO): A DPO has been designated and can be contacted at dpo@furtiv.me

2. Data We Collect

When you purchase or download content, we may collect:

• Name and surname.
  
• Email address.
  
• Device information: operating system, browser language.
  
• Transaction details: purchase history, amounts paid, payment method.
  

3. Legal Bases for Processing

We process personal data on the following legal grounds (Article 6 GDPR):

• Contract: to provide services, manage accounts, and deliver purchased content.
  
• Legal obligation: to comply with tax, accounting, and anti-money laundering (AML) rules.
  
• Legitimate interest: to ensure platform security, fraud prevention, and service improvement.
  
• Consent: for optional services (e.g., marketing communications, cookies).
  

4. Purpose of Data Processing

Personal data may also be processed for the purposes of platform security, content safety and moderation, abuse detection, fraud and chargeback prevention, and enforcement of platform rules, including compliance with payment processor and card network requirements.

We use your data for the following purposes:

• Account creation, verification of age and identity.
  
• Management of transactions, payments, and payouts.
  
• Delivery of services and access to purchased content.
  
• Fraud prevention, risk control, and enforcement of Terms of Service.
  
• Monitoring use of the Platform to improve security and user experience.
  
• Compliance with legal and regulatory obligations.
  
• Access to and purchase or download of any content available on the Platform is strictly restricted to individuals who are at least eighteen (18) years of age. By accessing, purchasing, or downloading content, users expressly confirm that they are of legal age and legally permitted to view adult content in their jurisdiction.
  
• more details here : https://www.yoti.com/terms/age-verification/
  

5. Data Retention

• Account data is kept for as long as your account is active or for 2 years after your last activity.
  
• Transactional data may be kept longer to comply with tax and accounting laws.
  
• Cookies are stored between 0 and 179 days, depending on their type.
  
• Once data is no longer needed, it will be deleted, anonymized, or archived, except where legal obligations require longer retention.
  

6. Data Transfers

Some personal data may be transferred outside the European Economic Area (EEA), for example to technical service providers in the United States.

In such cases, Furtiv.me ensures appropriate safeguards, including:

• European Commission Standard Contractual Clauses (SCCs),
  
• Verification of providers’ compliance with recognized frameworks (e.g., ISO 27001, SOC 2).
  

7. Sub-processors & Third Parties

Furtiv.me may use third-party service providers (payment processors, hosting, KYC/AML verification, analytics).

• All subcontractors are bound by Article 28 GDPR-compliant contracts, ensuring they act only under our instructions.
  
• A list of key processors can be provided upon request.
  

8. Your Rights

As a data subject, you have the following rights under the GDPR:

• Access: request a copy of your personal data.
  
• Rectification: correct inaccurate or incomplete data.
  
• Erasure: request deletion of your data (right to be forgotten).
  
• Restriction: limit processing of your data in certain cases.
  
• Portability: receive your data in a structured, machine-readable format.
  
• Objection: oppose processing of your data for legitimate reasons.
  
• Consent withdrawal: withdraw consent at any time (without affecting past lawful processing).
  
• Post-mortem instructions: decide how your data should be handled after your death.
  

📧 To exercise your rights, contact: privacy@furtiv.me.

📍 You may also lodge a complaint with the CNIL (Commission Nationale de l’Informatique et des Libertés).

9. Security

We implement technical, organizational, and physical measures to protect your personal data against loss, misuse, unauthorized access, disclosure, alteration, or destruction.

• Access to sensitive data is restricted to authorized personnel.
  
• All transfers are encrypted (TLS).
  
• Data is stored in secure EU servers.
  
• Regular audits and penetration testing are performed.
  

10. Data Breach Notification

In case of a personal data breach:

• Furtiv.me will notify the CNIL within 72 hours (Article 33 GDPR).
  
• If the breach poses a high risk to users’ rights and freedoms, we will also notify the affected users without undue delay (Article 34 GDPR).
  

11. Record of Processing Activities

Furtiv.me maintains a GDPR Article 30-compliant Record of Processing Activities (ROPA) to ensure accountability and traceability.

12. Changes to This Policy

We may update this Privacy Policy from time to time. In case of significant changes, you will be notified at least 15 days in advance by email or via a notice on the Platform.

📍 Data Controller:

HETA SARL

4 Square Charles Laurent

75015 Paris – France

Email: privacy@furtiv.me

📍 Data Protection Officer (DPO):

dpo@furtiv.me

This Privacy Policy is available in English and French to ensure accessibility for EU/EEA users.

Chargeback & Fraud Mitigation Policy

1. Purpose

This policy defines how Furtiv.me manages chargebacks and fraudulent transactions. The objectives are to:

• Protect Users (Creators and Downloaders) from unauthorized payment activity.
  
• Minimize financial losses related to fraud and chargebacks.
  
• Ensure compliance with applicable consumer protection and payment regulations.
  
• Maintain trust in the platform by acting with transparency and fairness.
  

2. Scope

This policy applies to:

• Downloaders (customers purchasing digital content on Furtiv.me).
  
• Creators (content providers on Furtiv.me).
  
• Furtiv.me staff involved in payments, compliance, and support.
  

3. Definitions

• Chargeback: A payment reversal initiated by the cardholder’s bank.
  
• Fraudulent Transaction: A payment made without the consent of the cardholder or using stolen financial information.
  
• Friendly Fraud: When a legitimate purchaser disputes a transaction without valid grounds.
  
• Refund: A repayment initiated by Furtiv.me after internal review of a claim.
  

4. Fraud Prevention Measures

Furtiv.me implements proactive measures to detect and prevent fraud:

• Mandatory identity and age verification for all Creators (KYC process).
  
• Monitoring of suspicious transaction patterns (e.g., unusually high purchases, repeated failed attempts).
  
• Use of secure payment processors with anti-fraud detection tools and compliance with Visa/Mastercard rules.
  
• Logging of all user access and purchase activities for investigation purposes.
  

5. Chargeback Handling Procedures

5.1 Notification

• When Furtiv.me receives notice of a chargeback from a payment processor or bank, the account concerned (Downloader and/or Creator) will be notified by email.
  

5.2 Evidence Collection

• Furtiv.me may collect transaction logs, IP addresses, proof of file downloads, and communication records as evidence.
  
• Creators may be requested to provide supporting materials (proof of delivery or user interaction).
  

5.3 Resolution

• If the chargeback is confirmed as fraudulent (unauthorized card use), Furtiv.me will refund the rightful cardholder.
  
• If the chargeback is deemed to be “friendly fraud,” Furtiv.me reserves the right to dispute the chargeback with the bank using collected evidence.
  

5.4 Financial Responsibility

• In case of proven fraud: Furtiv.me absorbs the loss and refunds the cardholder.
  
• In case of friendly fraud: Furtiv.me may deduct the transaction amount (and associated fees) from the Creator’s pending earnings.
  
• Furtiv.me reserves the right to suspend or terminate accounts repeatedly involved in chargebacks.
  

6. User Responsibilities

6.1 Downloaders

• Must ensure that their payment details are correct and used with consent.
  
• Must not initiate chargebacks without valid grounds.
  
• In case of fraud, Downloaders must provide proof of a police report to Furtiv.me support.
  

6.2 Creators

• Must comply with Furtiv.me’s verification procedures.
  
• Must deliver content as described to minimize disputes.
  
• Must cooperate in investigations of disputed transactions.
  

7. Sanctions for Abuse

• Any Downloader engaging in repeated or abusive chargebacks may have their account permanently suspended.
  
• Any Creator whose account is linked to fraudulent activities may have their funds withheld and account terminated.
  

8. Transparency & Communication

• Furtiv.me will keep Users informed of the status of their dispute or refund claim.
  
• All final decisions will be communicated via email.
  
• Communications related to chargebacks or fraud cases can be handled in English or French.
  

9. Data Retention

• All transaction and investigation records will be stored securely for at least 5 years for compliance and legal purposes.
  
• A dedicated Payments & Compliance team maintains an internal register of all chargeback and fraud cases with timestamps and outcomes.
  
• Cases involving stolen payment instruments, money laundering, or organized fraud are escalated to law enforcement authorities, banks, and relevant payment partners as required by law.
  

10. Policy Review

This policy will be reviewed annually to adapt to regulatory requirements, payment provider rules, and evolving fraud patterns.

Return & Refund Policy

1. Purpose

This Return & Refund Policy sets out the rules governing the rights of Downloaders to request a refund when purchasing digital content on Furtiv.me.

Because content on Furtiv.me is delivered digitally and immediately accessible after purchase, special conditions apply.

2. No General Right of Withdrawal

• In accordance with Article L.221-28, 13° of the French Consumer Code, Downloaders do not benefit from the statutory right of withdrawal for digital content supplied without a tangible medium once access has begun.
  
• By purchasing content on Furtiv.me, the Downloader expressly agrees to:
  

• The immediate availability of the content.
  
• The loss of their withdrawal right once access is granted.
  

3. Refunds in Case of Fraudulent Payment

• If a Downloader’s payment method has been used fraudulently (without their authorization) to purchase content, Furtiv.me may issue a refund.
  
• To request a refund on this basis, the Downloader must:
  

1. Contact support@furtiv.me.
   
2. Provide evidence of a complaint filed with the competent police authorities.
   

• Without such evidence, use of the payment method is presumed to have been authorized by the Downloader.
  
• Escalation: Cases of fraud involving stolen cards or identity theft are reported to the relevant payment partners, banks, and law enforcement authorities in compliance with DSP2 and Visa/Mastercard requirements.
  

4. Content Dissatisfaction

• Refunds will not be granted if a Downloader is dissatisfied with the content (e.g., expectations not met, different style or format than imagined).
  
• Creators are responsible for accurately describing their content prior to sale.
  
• Downloaders are strongly encouraged to review descriptions and previews carefully before making a purchase.
  

5. Exceptions

Refunds may be considered, at Furtiv.me’s sole discretion, in cases of:

• Proven technical error (e.g., duplicate charge).
  
• Failure of the platform to provide access to purchased content.
  

6. How to Request a Refund

To request a refund under this policy, Downloaders must contact support@furtiv.me with the following details:

• Name and registered account email.
  
• Date and reference of the transaction.
  
• Reason for the refund request, with supporting evidence if applicable.
  

Requests are handled by the Payments & Compliance team, and every case is recorded in a secure internal register with a case reference number and timestamps.

7. Final Decision

• Furtiv.me will review refund requests in good faith and respond within 5 business days.
  
• Decisions are final and communicated by email (in English or French).
  
• If a refund is granted, it will be processed using the same payment method as the original purchase.
  

8. Policy Review

This Return & Refund Policy will be reviewed annually to ensure compliance with:

• Applicable consumer protection laws.
  
• Digital content industry standards.
  
• Feedback from users and regulatory guidance.