Privacy Policy

NJK HOLDINGS LIMITED (“NJK Holdings”, “Company”, “we”, “our” or “us”) respects your privacy and is committed to protecting the personal information you share with us.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit noahklinghammer.com, interact with the Content Society brand, submit an application or enquiry, communicate with us, or use our creator management, consulting, marketing or related services.

By using our website, submitting information to us or engaging our services, you acknowledge the practices described in this Privacy Policy.

Who We Are

NJK HOLDINGS LIMITED provides creator management, business consulting, marketing, content strategy, monetisation strategy and related services to models, creators, influencers and other digital businesses.

Our services may be provided through:

• noahklinghammer.com
• Content Society
• and other websites, platforms or brands operated by NJK HOLDINGS LIMITED.

Information We Collect

We may collect personal information directly from you, automatically through our websites and systems, or through third parties where legally permitted.

The information we may collect includes:

Personal Identification Information

• full name;
• stage name or professional name;
• date of birth;
• age;
• gender where voluntarily provided;
• identification or verification information where required;
• country of residence;
• nationality where relevant to service eligibility.

Contact Information

• email address;
• telephone number;
• social media handles;
• messaging application details;
• business contact information.

Creator and Business Information

Where you apply for or use our creator management services, we may collect information including:

• creator platform usernames;
• social media accounts;
• subscriber information;
• follower numbers;
• audience information;
• business performance data;
• revenue information;
• sales data;
• account analytics;
• content performance;
• pricing information;
• subscription information;
• marketing information;
• business goals;
• existing agency relationships;
• professional experience;
• content categories;
• availability;
• account status; and
• other information relevant to assessing or managing your creator business.

Application and Onboarding Information

We may collect information you provide through:

• application forms;
• contact forms;
• onboarding forms;
• questionnaires;
• consultations;
• interviews;
• emails;
• telephone calls;
• video calls;
• messaging platforms;
• support requests; and
• other communications with us.

Adult Creator and Age Verification Information

Certain services provided by NJK HOLDINGS LIMITED may relate to adult-oriented or age-restricted creator businesses.

Where necessary for legal, contractual, platform or compliance purposes, we may request or process information required to confirm that a creator or content participant satisfies applicable age requirements.

This may include:

• date of birth;
• identification information;
• verification status;
• model releases;
• consent records; and
• records confirming that persons appearing in content are legally eligible to participate.

We do not knowingly provide adult creator management services to minors.

Our minimum age for creator management services is eighteen (18).

Where applicable law, a platform or another relevant service requires a higher age, including twenty-one (21), the higher age requirement shall apply.

Content and Media

Creators may provide photographs, videos, audio recordings, written content or other media as part of our services.

We may process such material where reasonably necessary to provide services including:

• content planning;
• editing;
• scheduling;
• publishing;
• promotion;
• distribution;
• social media management;
• monetisation;
• marketing;
• performance analysis; and
• account management.

Such content remains subject to the ownership provisions of the applicable Management Agreement and Terms of Service.

Account Access Information

Where creator management services require account access, we may process information connected with creator accounts, including:

• account usernames;
• account identifiers;
• analytics;
• subscriber statistics;
• transaction information;
• content statistics;
• messages;
• sales information;
• audience information; and
• other account-related information necessary to provide agreed services.

Where possible and appropriate, secure access methods should be used instead of unnecessary disclosure of permanent account credentials.

Technical Information

When you access our websites or digital services, certain technical information may be collected automatically.

This may include:

• IP address;
• browser type;
• operating system;
• device type;
• device identifiers;
• referring website;
• pages viewed;
• time spent on pages;
• website interactions;
• approximate geographic information;
• cookie information;
• analytics data; and
• technical logs.

This information may be collected through cookies, analytics software and similar technologies.

How We Use Your Information

We may use personal information to:

• provide creator management services;
• assess creator applications;
• determine whether our services are suitable for you;
• onboard new clients;
• manage creator accounts;
• provide consulting and coaching;
• develop marketing strategies;
• develop content strategies;
• provide monetisation strategy;
• optimise creator accounts;
• analyse business performance;
• respond to enquiries;
• provide customer support;
• schedule meetings;
• communicate with clients;
• process payments;
• administer contracts;
• manage business relationships;
• detect security risks;
• prevent fraud;
• protect our business;
• enforce our agreements;
• improve our website;
• improve our services;
• analyse how our services are used;
• maintain business records;
• comply with legal and regulatory obligations; and
• establish, exercise or defend legal claims.

Creator Application Assessment

Where you apply to work with NJK HOLDINGS LIMITED or Content Society, information submitted through an application may be used to assess:

• whether you are suitable for our services;
• whether we believe we can assist your business;
• your existing audience;
• revenue level;
• account performance;
• growth potential;
• content strategy;
• availability;
• willingness to participate in agreed strategies; and
• other relevant commercial considerations.

Submitting an application does not guarantee acceptance as a client.

Communications

We may use your contact information to communicate with you regarding:

• enquiries;
• applications;
• consultations;
• onboarding;
• meetings;
• creator accounts;
• services;
• contracts;
• invoices;
• payments;
• support;
• security;
• operational updates; and
• other matters connected with our business relationship.

Marketing Communications

Where permitted by law, and where consent is required after obtaining appropriate consent, we may send promotional or marketing communications.

These communications may relate to:

• NJK HOLDINGS LIMITED;
• Content Society;
• creator management services;
• consulting services;
• business services;
• educational materials;
• events;
• promotions; or
• other relevant services.

You may unsubscribe from marketing communications at any time by using the unsubscribe mechanism provided or contacting us.

Opting out of marketing does not prevent us from sending essential service, contractual, security or account-related communications.

SMS and Messaging Communications

Where you provide your telephone number and appropriate consent, we may contact you by SMS, WhatsApp or other messaging services.

Messages may include:

• consultation reminders;
• meeting reminders;
• onboarding messages;
• service updates;
• account notifications;
• operational communications;
• support messages; and
• promotional communications where legally permitted.

Message frequency may vary.

Your mobile provider may charge standard message or data fees.

Where applicable, you may withdraw consent for promotional messaging at any time.

We do not sell SMS consent information or provide SMS consent information to unrelated third parties for their own marketing purposes.

Legal Bases and Permitted Processing

We process personal information where we have an appropriate legal basis or other lawful justification to do so.

Depending on the circumstances, this may include processing necessary:

• to provide requested services;
• to perform a contract;
• to take steps before entering into a contract;
• to comply with legal obligations;
• for legitimate business purposes;
• to protect legal rights;
• to prevent fraud or security incidents; or
• where you have provided consent.

Where processing relies on consent, you may withdraw that consent where permitted by applicable law.

How We Share Information

We do not sell personal information.

We may share information where reasonably necessary with:

• employees;
• authorised contractors;
• creator managers;
• consultants;
• marketing specialists;
• content editors;
• social media managers;
• customer support providers;
• technology providers;
• CRM providers;
• cloud storage providers;
• hosting providers;
• analytics providers;
• payment processors;
• accountants;
• lawyers;
• professional advisers;
• security providers; and
• other service providers assisting with our operations.

Such parties may receive only the information reasonably necessary for their role or service.

Third-Party Platforms

Our services may involve third-party platforms such as:

• social media networks;
• subscription platforms;
• payment processors;
• messaging platforms;
• CRM systems;
• analytics providers;
• cloud storage services; and
• other business software.

Information processed through these services may also be subject to the privacy policies and terms of those third parties.

NJK HOLDINGS LIMITED is not responsible for the independent privacy practices of third parties.

OnlyFans and Other Creator Platforms

Where a client uses OnlyFans or another creator platform, information relating to the creator's account may be processed as part of agreed management services.

NJK HOLDINGS LIMITED is an independent business and is not owned by, controlled by or affiliated with OnlyFans unless expressly stated otherwise.

The operation and processing practices of third-party creator platforms are governed by their own privacy policies and contractual terms.

International Data Processing

Because we operate internationally and work with creators, contractors and technology providers in different countries, personal information may be processed or stored outside the country in which you reside.

Where personal information is transferred internationally, we will take reasonable steps required under applicable law to protect that information.

Data Security

We use reasonable administrative, technical and organisational measures intended to protect personal information from:

• unauthorised access;
• loss;
• misuse;
• alteration;
• disclosure;
• destruction; and
• other unauthorised processing.

Security measures may include access restrictions, password controls, authentication measures, secure software systems and limited internal access.

However, no electronic system, internet transmission or storage system can be guaranteed to be completely secure.

Accordingly, we cannot guarantee absolute security.

Passwords and Creator Credentials

Where creators provide access to digital accounts, both NJK HOLDINGS LIMITED and the creator are expected to take reasonable security precautions.

Creators should use:

• strong passwords;
• unique passwords;
• multi-factor authentication where available;
• secure recovery methods; and
• appropriate device security.

Clients should immediately notify us if they suspect that an account has been compromised.

Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.

Retention periods may depend on:

• the duration of our business relationship;
• contractual requirements;
• accounting requirements;
• payment records;
• legal requirements;
• regulatory requirements;
• dispute resolution;
• fraud prevention;
• security requirements; and
• potential legal claims.

Certain records may therefore be retained after a client relationship ends where reasonably necessary or legally required.

Your Privacy Rights

Depending on your location and applicable law, you may have rights concerning your personal information.

These may include the right to:

• request access to personal information;
• request correction of inaccurate information;
• request deletion of information;
• request information concerning how data is processed;
• withdraw consent where processing is based on consent;
• object to certain processing;
• request restriction of certain processing; and
• exercise other rights available under applicable data protection law.

Not all rights apply in every jurisdiction or circumstance.

We may need to verify your identity before processing certain privacy requests.

Deletion Requests

You may request deletion of personal information by contacting us.

We may retain certain information where retention is reasonably necessary to:

• comply with law;
• maintain accounting records;
• enforce contracts;
• resolve disputes;
• prevent fraud;
• protect legal rights; or
• establish or defend legal claims.

Accuracy of Information

You are responsible for ensuring that information you provide to us is accurate and current.

If your personal information changes, you should notify us where the change is relevant to our services.

Cookies

Our website may use cookies and similar technologies for purposes including:

• website functionality;
• security;
• remembering preferences;
• analytics;
• measuring website performance;
• marketing; and
• understanding visitor behaviour.

Users may be able to control cookies through their browser or device settings.

Additional information may be provided through a separate Cookie Policy where applicable.

Analytics

We may use analytics technologies to understand:

• website traffic;
• visitor behaviour;
• page performance;
• referral sources;
• device information;
• marketing performance; and
• how users interact with our website.

Analytics information may be aggregated or pseudonymised where appropriate.

Business Transfers

If NJK HOLDINGS LIMITED is involved in a merger, acquisition, restructuring, investment, financing, sale of assets or transfer of business, personal information may be transferred as part of that transaction where legally permitted.

Any recipient of such information will remain subject to applicable data protection obligations.

Legal Disclosure

We may disclose personal information where we reasonably believe disclosure is necessary to:

• comply with applicable law;
• comply with a court order;
• respond to lawful requests from authorities;
• protect our legal rights;
• investigate suspected fraud;
• protect users;
• protect our business;
• enforce agreements; or
• establish, exercise or defend legal claims.

Children's Privacy

Our creator management services are not intended for children.

We do not knowingly provide adult creator management services to any person under the applicable minimum legal age.

If we become aware that information relating to a minor has been provided in connection with adult creator services, we may immediately restrict access, terminate the relevant process and take any further action reasonably necessary.

Third-Party Links

Our website may contain links to websites or services operated by third parties.

We are not responsible for:

• third-party websites;
• third-party content;
• third-party security;
• third-party data collection; or
• third-party privacy practices.

You should review the privacy policy of any third-party service before providing personal information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes in our services;
• changes in technology;
• operational changes;
• legal requirements; or
• regulatory developments.

The latest version will be made available through our website with an updated “Last Updated” date.

Contact Us

For privacy questions, requests, complaints or concerns regarding personal information, you may contact:

Governing Framework

This Privacy Policy shall be interpreted together with applicable privacy and data protection laws and our Terms of Service.

Where applicable law grants individuals mandatory privacy rights, nothing in this Privacy Policy is intended to exclude or limit those rights.