GAAPHOENIX LLC
PRIVACY POLICY
How gaaphoenix LLC Collects, Uses, and Protects Your Information
Effective Date: June 1, 2025
IMPORTANT NOTICE: This document is a legal template drafted for informational purposes. It must be reviewed and finalized by a licensed attorney before use. gaaphoenix LLC accepts no liability for reliance on this template without legal counsel.
This Privacy Policy explains how gaaphoenix LLC ("Company," "We," "Us") collects, uses, stores, and discloses personal information when you use the OnlySleep platform. By using the Platform, you consent to the practices described in this Policy.
This Policy applies to all users globally, including users in the United States, the European Union (GDPR), and California (CCPA). Where regional laws provide additional rights, they are described in dedicated sections below.
1. INFORMATION WE COLLECT
1.1 Information You Provide Directly
Account information: name (or pseudonym), email address, password
Identity verification data: government-issued ID (processed by our verification partner, not stored by us)
Payment information: credit card details, bank account information (processed by Stripe, not stored by us directly)
Creator-specific: streaming setup information, payout preferences, tax forms
Communications: support tickets, messages sent through the Platform
1.2 Information Collected Automatically
Device information: IP address, browser type, operating system, device identifiers
Usage data: pages visited, content viewed, time spent, clicks and interactions
Stream data: viewing duration, replay activity, gift/tip transactions
Log data: access times, error logs, referral URLs
Cookies and similar tracking technologies (see Section 6)
1.3 Information from Third Parties
Payment processors (Stripe): transaction confirmation data
Identity verification services: age and identity confirmation results
Analytics providers: aggregated usage patterns
2. HOW WE USE YOUR INFORMATION
We use collected information for the following purposes:
2.1 Platform Operations
Creating and managing your account
Processing payments and Creator payouts
Providing access to Sleep Content
Identity verification and age confirmation
Fraud prevention and security
2.2 Communications
Sending transactional emails (receipts, account updates)
Platform notifications and alerts
Responding to customer support requests
Marketing communications (with your consent where required)
2.3 Platform Improvement
Analytics and performance monitoring
A/B testing and feature development
Research and data analysis to improve services
2.4 Legal Compliance
Complying with applicable laws and regulations
Responding to lawful requests from government authorities
Enforcing our Terms of Service and Creator Agreement
3. HOW WE SHARE YOUR INFORMATION
We do not sell your personal information. We may share information in the following circumstances:
3.1 Service Providers
We share data with trusted third-party vendors who assist in operating the Platform, including:
Stripe (payment processing) — stripe.com/privacy
Identity verification providers
Cloud hosting providers (servers located in the United States)
Email service providers
Analytics providers
All service providers are contractually bound to use data only for specified purposes and to maintain appropriate security standards.
3.2 Creator-Subscriber Interactions
Creators' pseudonyms and content are shared with Subscribers. Creators' real identities, legal names, addresses, and payment information are never shared with Subscribers.
3.3 Legal Requirements
We may disclose information if required by law, court order, or government authority, or if we believe disclosure is necessary to protect the safety of any person or to prevent fraud or illegal activity.
3.4 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our business, your information may be transferred to the acquiring entity, subject to the same privacy protections.
4. DATA RETENTION
We retain personal information for as long as necessary to provide services, comply with legal obligations, and resolve disputes. Specific retention periods:
Account data: retained while account is active, then 7 years for tax/legal purposes
Payment records: 7 years in accordance with US tax law
Stream data and analytics: 3 years
Support communications: 2 years
Identity verification records: as required by applicable law, minimum 3 years
You may request deletion of your account and personal data at any time (see Section 7). Some data may be retained after deletion where required by law.
5. DATA SECURITY
We implement industry-standard security measures to protect your personal information, including:
Encryption of data in transit (TLS/SSL) and at rest (AES-256)
Access controls limiting employee access to personal data
Regular security audits and penetration testing
Two-factor authentication for sensitive account actions
No method of transmission over the internet is 100% secure. We cannot guarantee absolute security, but we are committed to protecting your information using commercially reasonable means.
In the event of a data breach affecting your rights and freedoms, we will notify you and relevant authorities within the timeframes required by applicable law.
6. COOKIES AND TRACKING
6.1 Types of Cookies We Use
Essential cookies: required for Platform functionality (login sessions, security)
Analytics cookies: help us understand how users interact with the Platform
Preference cookies: remember your settings and preferences
Marketing cookies: used to deliver relevant advertisements (with consent)
6.2 Managing Cookies
You can control cookies through your browser settings. Disabling certain cookies may affect Platform functionality. For EU users, we display a cookie consent banner and only activate non-essential cookies with your explicit consent.
7. YOUR RIGHTS
7.1 General Rights (All Users)
Access: Request a copy of personal information we hold about you
Correction: Request correction of inaccurate or incomplete data
Deletion: Request deletion of your personal data (subject to legal retention requirements)
Portability: Request your data in a machine-readable format
Opt-out: Opt out of marketing communications at any time
7.2 GDPR Rights (European Union / EEA Users)
If you are located in the EU or EEA, you have additional rights under the General Data Protection Regulation (GDPR):
Right to object to processing based on legitimate interests
Right to restrict processing in certain circumstances
Right to withdraw consent at any time without affecting prior lawful processing
Right to lodge a complaint with your local Data Protection Authority (DPA)
Our legal basis for processing EU user data includes: performance of contract (account and subscription services), legitimate interests (fraud prevention, security), legal obligation (tax and regulatory compliance), and consent (marketing, non-essential cookies).
For EU data transfers: As a US-based company processing EU user data, we rely on Standard Contractual Clauses (SCCs) and other approved transfer mechanisms to ensure adequate protection of your data in compliance with Chapter V of the GDPR.
7.3 CCPA Rights (California Residents)
California residents have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
Right to know what personal information is collected, used, shared, or sold
Right to delete personal information (with exceptions)
Right to opt-out of the sale or sharing of personal information (we do not sell data)
Right to non-discrimination for exercising your privacy rights
Right to correct inaccurate personal information
Right to limit use of sensitive personal information
To exercise CCPA rights, submit a verifiable consumer request to: legal@onlysleep.com
8. CHILDREN'S PRIVACY
The Platform is strictly for users 18 years of age and older. We do not knowingly collect personal information from minors. If we discover that a minor has provided us with personal information, we will delete it immediately. If you believe a minor has created an account, contact us at legal@onlysleep.com immediately.
9. INTERNATIONAL DATA TRANSFERS
The Platform is operated from the United States. If you access the Platform from outside the United States, your data will be transferred to and processed in the United States, where data protection laws may differ from those in your country.
By using the Platform, you consent to this transfer. For EU/EEA users, we ensure appropriate safeguards are in place per GDPR Chapter V requirements.
10. THIRD-PARTY LINKS
The Platform may contain links to third-party websites. We are not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.
11. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. We will notify you of material changes by email or by prominent notice on the Platform at least 30 days before the changes take effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy.
12. CONTACT AND DATA CONTROLLER
gaaphoenix LLC is the data controller for personal information processed under this Policy.
Email: legal@onlysleep.com
Mailing Address: 1209 Mountain Road PL NE Ste N, Albuquerque, NM 87110, United States
For EU users — EU Representative contact: legal@onlysleep.com (subject line: EU Data Request)
For California users — CCPA requests: legal@onlysleep.com (subject line: CCPA Request)
We aim to respond to all data rights requests within 30 days.