Privacy Policy

Welcome to Avento. This Privacy Policy explains how Avento ("Avento", "we", "us", or "our") collects, uses, discloses, and safeguards information when you access or use our live streaming and social community mobile application and related services (collectively, the "Service"). By creating an account, browsing, or otherwise using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use the Service.

Avento is intended exclusively for adults. The Service is not directed at, and must not be used by, anyone under eighteen (18) years of age. Section 16 and Section 17 of this Policy describe in detail how we address age eligibility and protect against child exploitation.

1. Scope and Acceptance

1.1 Application of this Policy. This Privacy Policy applies to all users of the Service worldwide, including viewers, broadcasters, and any visitor to Avento-branded websites, support portals, or community pages linked from the app.

1.2 Relationship to Other Documents. This Policy should be read together with our Terms of Service and any supplemental notices we provide for specific features, such as live streaming, virtual gifting, or promotional campaigns. In the event of a direct conflict solely regarding data handling, this Privacy Policy controls.

1.3 Acceptance Through Use. Continued use of the Service after any update to this Policy constitutes acceptance of the revised terms, subject to the notice requirements described in Section 25.

2. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Face Data" means the facial image displayed on a government-issued identification document; still images or video frames of a user's face captured during broadcaster verification; and facial feature measurements and a one-to-one similarity score generated on the user's device to compare those two sources. A separate verified/not-verified account status is not Face Data because it contains no image, video, facial template, feature measurements, or information capable of reconstructing a face.
• "Broadcaster" or "Host" means a user who initiates or conducts a live stream on the Service.
• "Viewer" means a user who watches, comments on, or interacts with a live stream.
• "UGC" or "User-Generated Content" means posts, comments, live stream video and audio, chat messages, images, captions, and any other material a user submits, uploads, or transmits through the Service.
• "Virtual Items" means gifts, coins, tokens, badges, or other digital items that may be purchased, sent, or received within the Service.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.

3. Eligibility and Age Requirement

3.1 Minimum Age. You must be at least 18 years old to create an account, broadcast, or otherwise use the Service. By registering, you represent and warrant that you meet this age requirement.

3.2 Age Assurance Measures. We may use a combination of self-declared birth date, payment method verification, document checks, and behavioral or technical signals to assess whether an account holder meets the minimum age requirement. Accounts that we reasonably believe belong to a person under 18 will be suspended and, where appropriate, permanently removed.

3.3 No Knowing Collection From Minors. We do not knowingly collect Personal Data from individuals under 18. If we learn that we have inadvertently collected such data, we will delete it promptly and take appropriate account action, as further described in Sections 16 and 17.

4. Information We Collect

We collect the categories of information described below directly from you, automatically through your use of the Service, and from third parties, in order to operate, secure, and improve Avento.

4.1 Account and Profile Information

• Registration details such as username, display name, email address, phone number, and password (stored in hashed form).
• Profile content you choose to add, including profile photo, avatar, bio, gender, birth date, and interests.
• Login credentials and identifiers when you register or sign in through a third-party account, such as Apple, Google, or Facebook.

4.2 Broadcaster Verification Information

• Government-issued identification document data presented in the app solely to confirm that you are a real, eligible adult before you are permitted to broadcast.
• A live selfie or short verification video captured only when you choose to apply for broadcaster status, and used to compare the person appearing on camera with the identification presented.
• A broadcaster-verification status (verified or not verified) associated with your account. This status contains no Face Data and cannot be used to reconstruct your face.

4.3 Face Data Used for Broadcaster Verification

4.3.1 Face Data Collected. Only when a user voluntarily applies to become a Broadcaster, Avento accesses the Face Data defined in Section 2: the facial image on the identification presented, images or frames from the live selfie or short verification video, facial feature measurements generated from those images, and the resulting one-to-one similarity score. Avento does not collect Face Data from Viewers or during ordinary account creation, and no other facial data is collected for this function.

4.3.2 How Face Data Is Collected and Consent. The user initiates broadcaster verification, is shown a clear notice describing the Face Data processing, and must affirmatively consent before the app accesses the camera or processes Face Data. The user then presents an identification document and captures a live selfie or short video. The identification portrait and the captured facial images are compared one-to-one entirely on the user's device. If the user does not consent, Face Data is not collected and broadcaster verification cannot be completed.

4.3.3 Uses. Face Data is used solely to determine whether the person applying to broadcast appears to be the same person shown on the identification document, to determine broadcaster eligibility, and to help prevent impersonation and verification fraud. Face Data is not used for account sign-in or ongoing authentication, advertising, marketing, recommendations, analytics, tracking, user profiling, data mining, or training artificial-intelligence or machine-learning models. It is not used to identify a user among a population or to reconstruct an anonymous user's identity or profile.

4.3.4 On-Device Processing and Storage Location. All Face Data processing occurs locally within the Avento app on the user's device. Face Data is stored only in the app's device-local sandbox. It is never uploaded or transmitted to Avento servers, cloud storage, or any third-party server. Avento's servers store only the non-face broadcaster-verification outcome needed to enable or disable broadcaster access; that outcome cannot be used to reconstruct the user's face.

4.3.5 No Third-Party Sharing. Avento does not disclose, share, transfer, sell, rent, license, or otherwise provide Face Data to any third party, including identity-verification providers, analytics providers, advertising platforms, data brokers, or information resellers. No Avento employee, contractor, or service provider can access Face Data stored in the app's local sandbox.

4.3.6 Retention and Deletion. The retention and deletion rules for Face Data are stated in Section 11.1. Users may withdraw consent or request deletion as described in Section 13.

4.4 Device and Technical Information

• Device model, operating system and version, unique device identifiers, advertising identifiers, IP address, mobile network information, browser type, and language settings.
• App diagnostics such as crash logs, performance data, referral URLs, and feature usage timestamps.

4.5 Location Data

• Approximate location derived from IP address, used to localize content, enforce regional restrictions, and comply with law.
• Precise GPS location, only if you separately grant location permission, for features such as discovering nearby live streams or nearby users.

4.6 User-Generated Content and Communications

• Live stream video and audio, thumbnails, and stream titles.
• Posts, comments, captions, hashtags, and reactions.
• Private and public chat messages, including messages sent during live streams (overlay comments) and direct messages between users.

4.7 Transaction and Virtual Item Information

• Purchase history of coins, gifts, subscriptions, or other Virtual Items, and records of gifts sent to or received from other users.
• Payment confirmation data from app store platforms or payment processors; we do not store full payment card numbers ourselves.

4.8 Information from Third Parties

• Information from social login providers, limited to the data fields you authorize us to receive.
• Information from fraud prevention, sanctions screening, and age-assurance partners.

5. How We Use Information

We use the information described in Section 4 for the following purposes:

• To create, authenticate, and maintain your account, and to verify broadcaster eligibility.
• To perform the device-local, one-to-one broadcaster identity comparison described in Section 4.3, with your clear and conspicuous consent.
• To operate core features, including live streaming, commenting, direct messaging, following, and gifting.
• To personalize your experience, including recommending live streams, creators, and posts based on your activity and preferences.
• To process purchases of Virtual Items and to maintain accurate transaction and gifting records.
• To monitor, detect, investigate, and prevent fraud, abuse, harassment, impersonation, and violations of our Terms of Service or Community Guidelines.
• To send service-related notices, security alerts, and, where permitted, marketing communications you may opt out of at any time.
• To conduct analytics, improve app stability, and develop new features.
• To comply with legal obligations, respond to lawful requests, and enforce our agreements.

6. Legal Bases for Processing

Where applicable data protection law requires a legal basis, we rely on one or more of the following: performance of our contract with you (our Terms of Service), your consent (including clear and conspicuous consent before any collection or use of Face Data, as well as consent for precise location or marketing messages), our legitimate interests (such as securing the Service and preventing fraud), and compliance with legal obligations. You may withdraw consent-based processing at any time as described in Section 13, without affecting processing carried out before withdrawal.

7. Live Streaming, Public Visibility, and Recording

7.1 Public Nature of Live Streams. Live streams, along with associated titles, comments, and viewer counts, are generally visible to other users of the Service and, where a stream is shared externally, may become visible outside the Service. You should not disclose sensitive personal information while broadcasting or commenting.

7.2 Recording and Clips. We may retain temporary recordings or automatically generated clips of live streams for a limited period for safety review, dispute resolution, trust and safety investigations, and legal compliance, even if the live session itself has ended.

7.3 Screen Recording by Other Users. While we prohibit unauthorized recording or redistribution of another user's stream under our Community Guidelines, we cannot fully prevent third parties from capturing publicly displayed content. Broadcast at your own discretion.

8. Virtual Gifts, Virtual Currency, and Payment Data

• Purchases of coins or Virtual Items are processed through the applicable app store's in-app payment system; we receive confirmation of purchase but not your full financial account details.
• Gifting activity, including sender, recipient, item type, and value, is recorded to support the gifting economy, calculate creator earnings, and detect fraudulent or coercive gifting patterns.
• Where a broadcaster is eligible for payouts, we or our payment partners may collect tax identification and payout account details solely for payment processing and legal reporting.

9. Information Sharing and Disclosure

We do not sell your Personal Data. We may share information in the following circumstances:

9.1 With Other Users

• Your public profile, posts, comments, live streams, and follower or gifting activity are visible to other users as part of normal Service functionality.

9.2 With Service Providers

• Cloud hosting and content delivery providers, live streaming infrastructure providers, payment processors, analytics providers, and customer support tools, each bound by contractual confidentiality and data protection obligations. These providers do not receive or have access to Face Data.

9.3 For Legal and Safety Reasons

• To comply with applicable law, regulation, legal process, or governmental request.
• To investigate or respond to violations of our policies, protect the rights, property, or safety of Avento, our users, or the public, including in connection with suspected CSAE, harassment, or fraud.

9.4 Business Transfers

• In connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections and, where required, notice to affected users.

9.5 Aggregated or De-Identified Data

• We may share aggregated or de-identified data that cannot reasonably be used to identify you, for research, reporting, or industry benchmarking.

9.6 Face Data

• Face Data is not shared with any third party and is not transmitted off the user's device. The limited service-provider disclosures described in Section 9.2 do not include Face Data. Avento may store only the non-face verification outcome described in Section 4.3.4.

10. International Data Transfers

As a global service, Avento transfers, stores, and processes information in countries other than your own, including jurisdictions whose data protection laws may differ from those of your home country. Where required, we implement appropriate safeguards, such as standard contractual clauses or equivalent mechanisms, to protect information transferred internationally.

For clarity, Face Data is not transferred internationally because it never leaves the user's device. The international transfers described in this Section 10 do not include Face Data.

11. Data Retention

11.1 Face Data Retention and Deletion

• Face Data is retained only in the Avento app's local sandbox on the user's device while the account remains active. It is retained no longer than the completion of account deletion.
• When account deletion is completed through Avento's in-app account-deletion process, the app immediately and permanently deletes the locally stored Face Data. Uninstalling the app also removes Face Data stored in the app's local container on that device.
• Because Face Data is never transmitted off the device, Avento and its service providers have no server, cloud, backup, or third-party copy to retain after deletion. The non-face verification outcome is retained while the account remains active and is deleted or de-identified when the account is deleted, subject only to legal recordkeeping requirements that do not require retention of Face Data.

11.2 Other Data Retention

• Account and profile information is retained for as long as your account remains active and for a reasonable period thereafter to address legal, security, and dispute-resolution needs.
• Other non-face broadcaster verification records, including the verification outcome, are retained only for as long as necessary to maintain broadcaster eligibility and satisfy applicable recordkeeping obligations, after which they are securely deleted or irreversibly de-identified. Face Data is governed exclusively by Section 11.1.
• Chat messages and live stream recordings retained for safety review purposes are subject to shorter, clearly bounded retention windows unless preserved for an active investigation or legal hold.
• Transaction and gifting records are retained as required by applicable financial, tax, and accounting laws.

12. Data Security

• We use administrative, technical, and physical safeguards, including encryption of data in transit, access controls, and network monitoring, designed to protect information against unauthorized access, alteration, disclosure, or destruction.
• Access to sensitive systems, including verification data and payment records, is restricted to authorized personnel on a need-to-know basis.
• Face Data is protected by the iOS app sandbox and device access controls and is not transmitted over a network. Avento personnel, contractors, and service providers cannot access device-local Face Data.
• No method of transmission or storage is completely secure. If we become aware of a security incident affecting your Personal Data, we will notify you and relevant authorities as required by applicable law.

13. Your Rights and Choices

Depending on your location, you may have some or all of the following rights regarding your Personal Data:

• Access a copy of the Personal Data we hold about you.
• Correct inaccurate or incomplete Personal Data through your in-app profile settings or by contacting us.
• Request deletion of your account and associated Personal Data, subject to legal retention requirements described in Section 11.
• Withdraw consent to Face Data processing before or during broadcaster verification by cancelling the process. After verification, you may request deletion of Face Data by using the in-app Delete Account function or by contacting us at service@avento.fans. Completing deletion removes the device-local Face Data and ends verified broadcaster access.
• Object to or restrict certain processing, including personalized recommendations, and withdraw previously given consent.
• Request a portable copy of certain data you provided to us, where technically feasible.
• Opt out of marketing communications at any time using the unsubscribe link or in-app notification settings.

To exercise any of these rights, contact us at service@avento.fans. We may need to verify your identity before completing certain requests, and we will respond within the timeframe required by applicable law.

14. Cookies, SDKs, and Similar Technologies

• We and our partners use cookies, mobile SDKs, and similar technologies to authenticate sessions, remember preferences, measure app performance, and deliver relevant content.
• Analytics, advertising, performance, and other third-party SDKs do not receive, store, or process Face Data.
• Where required by law, we will request your consent before deploying non-essential tracking technologies and will honor your choices through in-app privacy controls.

15. Push Notifications and Marketing Communications

• We may send push notifications about live streams you follow, new followers, gifts received, comments, and account or safety alerts. You can manage these through your device or in-app notification settings.
• Marketing emails or messages, where sent, include an option to unsubscribe; certain transactional or safety-related communications cannot be opted out of while your account remains active.

16. Children's Privacy

16.1 Strict Adult-Only Policy. Avento is designed exclusively for users 18 years of age and older. We do not permit registration by, and do not knowingly collect Personal Data from, anyone under 18.

16.2 Discovery of Underage Users. If we determine that an account belongs to a person under 18, whether through user reports, automated signals, or verification review, we will immediately suspend the account, remove associated content from public visibility where appropriate, and delete the underlying Personal Data except where retention is legally required, such as for safety investigations.

16.3 Parental Inquiries. A parent or guardian who believes their child has created an account or otherwise provided Personal Data to Avento may contact us at service@avento.fans to request review and deletion.

17. Zero Tolerance for Child Sexual Abuse and Exploitation (CSAE)

• Avento maintains a zero-tolerance policy toward Child Sexual Abuse and Exploitation (CSAE) in any form, including content, solicitation, grooming behavior, or facilitation of contact with minors.
• We use a combination of automated detection tools, hash-matching against known CSAE databases, human moderation, and user reporting to identify and remove violating content and accounts.
• Where legally required, we report confirmed or suspected CSAE to the National Center for Missing and Exploited Children (NCMEC) or other applicable authorities, and we cooperate with law enforcement investigations.
• Accounts found to violate this policy are permanently banned, and associated evidence may be preserved and disclosed to authorities notwithstanding the general retention periods described in Section 11.
• Users can report suspected CSAE at any time through in-app reporting tools or by contacting service@avento.fans; reports are prioritized for expedited review.

18. User-Generated Content: Collection, Storage, and Use

• Content you post, stream, or send, including video, audio, images, text, and metadata such as timestamps and hashtags, is collected and stored to operate the Service, including displaying content to other users and enabling moderation.
• By submitting UGC, you grant Avento a worldwide, non-exclusive, royalty-free license to host, store, reproduce, and display such content solely for the purpose of operating, promoting, and improving the Service, as further described in our Terms of Service.
• You retain ownership of your original content and may delete posts or end live streams at any time; however, previously viewed, downloaded, screenshotted, or archived copies held by other users or third parties, and copies preserved for legal or safety purposes under Section 11, may not be immediately removed.

19. Copyright, Intellectual Property, and Content Removal

• We respect intellectual property rights and respond to properly submitted notices of alleged copyright or trademark infringement, including under frameworks such as the Digital Millennium Copyright Act (DMCA) where applicable.
• Repeat infringers are subject to content removal and account termination in accordance with our Terms of Service.
• Users who believe their content was removed in error may submit a counter-notice through the process described in our Terms of Service.

20. Community Safety and Content Moderation

• We review reported content and accounts against our Community Guidelines, using a combination of automated classifiers and trained human moderators.
• Violations, including harassment, hate speech, non-consensual intimate imagery, and any sexual content involving or appearing to involve a minor, result in content removal and may result in account suspension, permanent ban, and referral to law enforcement.
• Moderation decisions may rely on the Personal Data and UGC described in Section 4 to assess context, patterns, and repeat behavior across accounts.

21. Third-Party Links and Integrations

• The Service may contain links to, or integrations with, third-party platforms such as social login providers or external payment processors. This Privacy Policy does not apply to third-party services, and we encourage you to review their respective privacy policies.

22. California Privacy Rights

• If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), including the right to know, delete, correct, and opt out of the sale or sharing of Personal Data, and the right to non-discrimination for exercising these rights.
• Avento does not sell Personal Data for monetary consideration. To the extent certain data-sharing arrangements with advertising partners are considered a "sale" or "sharing" under CPRA, you may opt out by contacting us at service@avento.fans.

23. European and United Kingdom Privacy Rights

• If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the rights described in Section 13, along with the right to lodge a complaint with your local data protection supervisory authority.
• We will identify a representative or point of contact in the European Union or United Kingdom where required by applicable law.

24. Other Regional Privacy Notices

• We continually monitor emerging privacy and age-verification legislation across our markets and will provide supplemental regional notices or in-app disclosures where locally required, without diminishing the protections described in this Policy.

25. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. If we make material changes, we will notify you through the app, by email, or by posting a prominent notice prior to the change becoming effective. The 'Effective Date' at the top of this Policy indicates when it was last revised. Your continued use of the Service after the effective date of any update constitutes your acceptance of the revised Policy.

26. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: