Privacy Policy

Last updated: [05-28-2025]

Network Capital, LLC (the “Company” or “We”) respect your privacy and commit to protecting it through our compliance with the practices described in this policy.

This policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you use our website, applications, and services (collectively, the “Service”). This policy applies to the personal data collected through our Service, regardless of the country where you are located.

We will only process your personal data in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

The Service may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit or service you enable.

Please read this policy carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Service, you accept and consent to the practices described in this policy. This policy may change on one or more occasions (see Changes to Our Privacy Policy). Your continued engagement with our Service after any such revisions indicates that you accept and consent to them, so please check the policy periodically for updates.

Data We May Collect About You

We collect and use different types of data from and about you including:

  • Personal data that we could reasonably use to directly or indirectly identify you (“personal data”), such as:
    • Your name, email address, phone number, and billing and account information (if applicable).
    • Your Internet Protocol (IP) address, device identifiers, and connection information.
    • Transaction history, including purchases, subscriptions, and payments made through the Service.
    • Any input you provide to the Service, including prompts, conversations with Creator Digital Beings, messages, and uploaded content (e.g., files, images, audio).
  • Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific feature of our Service.
  • Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Service, and usage details.
  • Non-personal details about your Service interactions, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Service (including date and time), content engagement (e.g., viewed or interacted-with Creator Digital Beings), the features you use and the actions you take, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.
  • When you interact with our Service through third-party messaging platforms (e.g., Telegram, WhatsApp, SMS), your messages are routed through phone numbers owned and controlled by us. This means we directly receive and process all interactions. While we log metadata (e.g., timestamps, message status) to facilitate Service functionality, users should be aware that third-party messaging platforms may also retain their own copies of messages in accordance with their respective privacy policies.

If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

How We Collect Data About You

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us information about you when you:
    • Create an account or update your profile.
    • Subscribe to our Service, make a purchase, or send gifts (tips).
    • Use artificial intelligence functions, including interacting with Creator Digital Beings, submitting prompts, or uploading content (e.g., files, images, audio).
    • Contact us for support, report a problem, or otherwise communicate with us.
  • Automated technologies or interactions. As you interact with our Service, we may automatically collect technical data about your equipment, browsing actions, and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and Automatic Data Collection Technologies).
  • Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment, and delivery services, messaging platforms (e.g., WhatsApp, Telegram), analytics providers, and search information providers.
  • User contributions. You also may provide information for us to publish or display (“post”) on public areas of the Service or transmit to other Service users or third parties (collectively, “User Content”). You submit User Content for posting and transmission to others at your own risk. Although you may set certain privacy settings for User Content by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Service users with whom you choose to share your User Content. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Content.

Cookies and Automatic Data Collection Technologies

Our Service uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Service users. This helps us deliver a better and more personalized service when you browse our Service. It also allows us to improve our Service by enabling us to:

  • Estimate audience size and usage trends to improve Service functionality.
  • Store preferences for personalization where applicable.
  • Enhance artificial intelligence interactions, including remembering past engagements with Creator Digital Beings (where applicable).
  • Recognize Users when they return to our web-based features for seamless access.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Service may become inaccessible, and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

Pages of our Service may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or to compile other similar statistics such as recording content popularity or verifying system and server integrity.

How We Use Your Personal Data

We use your personal data to provide and improve our Service, communicate with you, and support our business operations. Examples of how we may use the personal data we collect include to:

  • Provide and personalize our Service, including delivering artificial intelligence-generated interactions through Telegram, WhatsApp, and other messaging platforms.
  • Fulfill your requests, such as processing purchases, subscriptions, and gifts (tips).
  • Enforce our rights and comply with legal obligations, including billing, collections, fraud prevention, and regulatory compliance.
  • Improve artificial intelligence interactions and user experience, such as training artificial intelligence models to enhance functionality.
  • Notify you about changes to our Service, policies, or account-related matters.
  • Optimize Service performance, including troubleshooting, research, data analysis, testing, and statistical review.
  • Protect the security and integrity of the Service, including detecting and preventing misuse, unauthorized access, or harmful behavior.
  • Enable participation in interactive or social features, where applicable.

We will only process your personal data for the purposes for which we collected it or for compatible purposes. If we need to process your personal data for a purpose that is not compatible, we will notify you and obtain consent where legally required. We may process your personal data without your knowledge or consent where required by applicable law.

Artificial intelligence-generated responses and user interactions may be processed for operational purposes, security, and artificial intelligence improvement. However, full chat logs are not retained indefinitely, and personally identifiable data is never used for artificial intelligence training unless explicitly consented to by the user. Only anonymized, de-identified data may be used to refine artificial intelligence performance.

We use artificial intelligence models to generate responses and improve interactions. However, users will not be subject to decisions based solely on automated processing (including profiling) without their prior consent. Users may opt out of artificial intelligence personalization features where applicable.

We may use non-personal data (such as aggregated or anonymized data) for any business purpose.

Disclosure of Your Personal Data

We may share your personal data with:

  • Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
  • Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business, including providers of hosting services, customer service vendors, cloud services, content delivery services, support and safety monitoring services, email communication software, web analytics services, payment and transaction processors, and other information technology providers. These third-party service providers may be located outside of your home jurisdiction. We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
  • To fulfill the purpose for which you provide it.
  • For any other purposes that we disclose in writing when you provide the data.
  • With your consent.

We may also disclose your personal data to third parties:

  • If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of that business or those assets.
  • To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce or apply our Terms of Service and other agreements.
  • To protect the rights, property, or safety of our business, our employees, our customers, or others.

We may share non-personal data without restriction.

Consent to Personal Data Transfer

We are based in the United States. To provide our services, we may process, store, and transfer your personal data to countries outside your own, including the United States, where privacy laws may differ and may not provide the same level of protection. However, we apply the safeguards described in this policy to your personal data regardless of where it is processed.

Where required, we rely on appropriate legal mechanisms to ensure the lawful transfer of personal data outside of the European Economic Area (EEA), Switzerland, and the United Kingdom (UK). These include the Standard Contractual Clauses (“SCCs”) approved by the European Commission under Article 46(2)(c) of the GDPR and the UK Data Transfer Addendum.

If you access or use our services from outside the United States, you acknowledge that your personal data may be transferred, processed, and stored in the United States or other jurisdictions in accordance with this privacy policy.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider (1) applicable legal requirements, (2) the amount, nature, and sensitivity of the personal data, (3) the potential risk of harm from unauthorized use or disclosure of your personal data, (4) the purposes we process your personal data for, and (5) whether we can achieve those purposes through other means.

We may retain user interactions, including artificial intelligence-generated responses, for operational, compliance, and artificial intelligence training purposes. However, full chat histories are not stored indefinitely. Some conversation data may be anonymized and used to enhance artificial intelligence performance, but personal data will not be linked to training datasets without explicit user consent.

Under some circumstances, we may anonymize your personal data so it can no longer be associated with you. We reserve the right to use that anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Your Personal Data Use Choices

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Service may become inaccessible or not function properly. For more information about tracking technologies, please see Cookies and Automatic Data Collection Technologies.

We own and control all phone numbers associated with Creator Digital Beings, meaning that all interactions pass through our systems. However, when using third-party messaging platforms (e.g., Telegram, WhatsApp, SMS), these services may independently collect and store user interactions beyond our control. By using these platforms to interact with the Service, you acknowledge that their data processing practices are governed by their respective privacy policies, and we are not responsible for their independent data retention or usage.

Our Service may, on one or more occasions, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

Accessing and Correcting Your Personal Data

You can access, review, and change your personal data by logging into the Service and visiting your account profile page.

You may also send us an email at [email protected] to request access to, correct, or delete personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy.

If you delete your User Content, including artificial intelligence chat interactions, uploaded files, or other inputs, copies may still exist in temporary system caches or server logs used for operational stability and compliance. Additionally, stored records may be retained where required for legal, security, or fraud prevention purposes. Certain inputs may also persist in artificial intelligence training models to enhance the functionality of the Service.

Because interactions primarily occur through third-party messaging platforms such as Telegram and WhatsApp, you acknowledge that those platforms may retain copies of messages, conversations, or media in accordance with their respective privacy policies. We do not control their data retention practices. Our Terms of Service govern proper access and use of information provided on the Service, including artificial intelligence-generated interactions and User Content.

Jurisdiction Specific Rights and Disclosures

US State Privacy Rights and Disclosures

Some US state consumer privacy laws require specific disclosures about the categories of personal data we collect and how we use and disclose that information. You can read more about the personal data we collect and where we collect it from in “Data We May Collect About You” and “How We Collect Data About You” above, how we use personal data in “How We Use Your Personal Data” above, and how long we retain personal data in “Data Retention” above.

US state consumer privacy laws may provide their residents with additional rights regarding our use of their personal data.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

  • Confirm whether we process their personal data.
  • Access and delete certain personal data.
  • Correct inaccuracies in their personal data, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
  • Data portability.
  • Opt-out of personal data processing for:
    • targeted advertising (excluding Iowa);
    • sales; or
    • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights might vary by state.

We do not “sell” personal data or “share” personal data for cross-contextual behavioral advertising, and we do not process personal data for “targeted advertising” purposes (as those terms are defined under state privacy laws). We also do not process sensitive personal data for the purposes of inferring characteristics about a consumer.

Exercising Your Rights. To exercise any of these rights, please email us at [email protected].

Verification. To protect your personal data from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete personal data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional personal data for verification. If we cannot verify your identity, we will not be able to honor your request.

Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us. Authorized agent requests can be submitted to [email protected].

Appeals. To appeal a decision regarding a consumer rights request, please send us an email at [email protected] within 30 days after the decision was rendered with a detailed explanation of why you believe the decision was incorrect or unsatisfactory and any additional information or evidence that supports your appeal. On receipt of your appeal, we will acknowledge its receipt within ten business days. The appeal will be reviewed by a senior member of our data protection or compliance team who was not involved in the initial decision. We may contact you for further information or clarification if necessary. We will provide a written response to your appeal within 30 days of receipt. If additional time is required to review your appeal, we will notify you of the extension and the reasons for it. If your appeal is upheld, we will take the necessary steps to rectify the issue and inform you of the actions taken. If your appeal is denied, we will provide a detailed explanation of the reasons for the denial and inform you of any further options available, such as contacting the relevant state authorities or data protection agencies.

Nevada. Nevada provides its residents with a limited right to opt-out of certain personal data sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

EU/UK Privacy Rights and Disclosures

If you live in the European Union (or European Economic Area) or the United Kingdom (UK), the following terms apply to you.

Controller. Network Capital, LLC, with its registered office at 1395 Brickell Ave, Suite 800, Miami, FL, 33131, is the controller and is responsible for the processing of your personal data as described in this privacy policy.

Legal Basis for Processing. We only process your personal data where applicable law permits or requires it, including:

  • Where the processing is necessary for the performance of our contract with you, such as processing your prompts to provide a response.
  • Where the processing is necessary for our legitimate interests or the legitimate interests of third parties, such as when we train and improve our models.
  • Where the processing is necessary to comply with a legal obligation, such as responding to a legal request or retaining transaction information to comply with record-keeping obligations.
  • With your consent.

Legal Rights. Under certain circumstances, you have rights under data protection laws concerning your personal data. Your rights may include the following:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we might not always be able to comply with your erasure request for specific legal reasons that will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
  • Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy; (2) where our use of the data is unlawful, but you do not want us to erase it; (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (4) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising Your Rights. If you wish to exercise any of the rights set out above, please contact us at [email protected].

Fees. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.

Verification. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information regarding your request to speed up our response.

Responding to Your Request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will let you know and keep you updated.

Right to Lodge Complaint. If you believe our data processing practices violate your rights under the EU or UK GDPR, you may lodge a complaint with the supervisory authority in your country of residence or work. If you are in the EU, you can find your local supervisory authority here. For any unresolved complaints relating to the UK you can reach out to the Information Commissioner’s Office and for Switzerland, to the Federal Data Protection and Information Commissioner⁠. While you have the right to lodge a complaint directly with the supervisory authority, we welcome the opportunity to address your concerns and resolve any issues first.

Data Security

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. Our payment processor encrypts any payment transactions using SSL technology.

The safety and security of your information also depends on you. We urge you to take care when providing information in public areas of the Service, which any Service visitor can view.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Service. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in the Service.

Children’s Online Privacy

We do not direct our Service to minors and we do not knowingly collect personal data from individuals under 18. If we learn we have mistakenly or unintentionally collected or received personal data from an individual under 18, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about an individual under 18, please contact us at [email protected].

Changes to Our Privacy Policy

We will post any changes we may make to our privacy policy on this page. If the changes materially alter how we use or treat your personal data we will notify you through a notice on the Service home page. Please check back frequently to see any updates or changes to our privacy policy.

Contact Information

Please address questions, comments, and requests regarding this privacy policy and our privacy practices to [email protected].

Our corporate headquarters are located at 1395 Brickell Ave, Suite 800, Miami, FL, 33131.