ARTICLE 1 — INTRODUCTION
1.1 Purpose
Welcome to Ch4pter.
Ch4pter, LLC ("Ch4pter," "we," "our," or "us") values the privacy of our Users and is committed to handling personal information responsibly, transparently, and securely.
This Privacy Policy explains how Ch4pter collects, uses, stores, protects, discloses, and otherwise processes personal information when individuals access or use the Ch4pter Platform.
This Privacy Policy applies to all Users of the Platform, including Clients, Service Providers, visitors, applicants, and other individuals who interact with Ch4pter through our websites, mobile applications, communications, or related services.
1.2 Relationship to Other Agreements
This Privacy Policy forms part of Ch4pter's overall legal framework and should be read together with:
- the Terms of Service;
- the applicable Marketplace Agreement;
- Booking-specific terms;
- and any additional policies or agreements incorporated by reference.
If a conflict exists between this Privacy Policy and another agreement regarding the processing of personal information, this Privacy Policy governs unless applicable law requires otherwise.
1.3 Scope
This Privacy Policy applies to personal information collected through:
- the Ch4pter website;
- mobile applications;
- Photographer Studio;
- Client Dashboard;
- Galleries;
- messaging features;
- booking tools;
- payment-related interactions;
- customer support;
- marketing communications;
- and any other services operated by Ch4pter that link to this Privacy Policy.
This Privacy Policy does not apply to third-party websites, services, or applications that Ch4pter does not own or control, even if they are accessible through links provided on the Platform.
1.4 Our Role
Ch4pter operates a technology marketplace that connects independent Service Providers and Clients.
In operating the Platform, Ch4pter processes personal information necessary to:
- create and manage Accounts;
- facilitate Bookings;
- process Marketplace transactions;
- deliver Galleries;
- provide customer support;
- maintain Platform security;
- improve Platform functionality;
- and comply with applicable legal obligations.
Ch4pter generally does not determine how independent Service Providers use personal information they collect outside the Platform or independently of Ch4pter's services.
1.5 Changes to this Privacy Policy
As Ch4pter evolves, our privacy practices may also evolve.
We may update this Privacy Policy from time to time to reflect changes in:
- Platform functionality;
- applicable law;
- security practices;
- business operations;
- Marketplace features;
- or other legitimate operational needs.
When required by applicable law or when material changes are made, Ch4pter will provide appropriate notice through the Platform, by email, or through another reasonable communication method before the revised Privacy Policy becomes effective.
The "Last Updated" date at the beginning of this Privacy Policy indicates the most recent revision.
Continued use of the Platform after an updated Privacy Policy becomes effective constitutes acknowledgment of the revised Privacy Policy to the extent permitted by applicable law.
1.6 Contact Information
Questions regarding this Privacy Policy or Ch4pter's privacy practices may be directed to:
Ch4pter, LLC 130 Townsend St Midland, MI 48640
Business Telephone: (989) 824-9474
Privacy & Legal Contact:
ARTICLE 2 — OUR PRIVACY PRINCIPLES
Protecting personal information is fundamental to maintaining trust between Ch4pter, Service Providers, Clients, and every participant in the Marketplace.
Our privacy practices are guided by the following principles:
2.1 We Collect Only What We Need
We strive to collect only the personal information reasonably necessary to operate, improve, secure, and support the Platform and the Marketplace.
2.2 We Are Transparent
We explain what information we collect, why we collect it, how we use it, when it may be shared, and what choices Users have regarding their information.
2.3 We Protect Personal Information
Ch4pter implements commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction.
No security system is perfect, but safeguarding User information remains one of our highest priorities.
2.4 We Do Not Sell Personal Information
Ch4pter does not sell Users' personal information.
If applicable law later requires additional disclosures regarding data sharing practices, Ch4pter will update this Privacy Policy accordingly.
2.5 Private Booking Content Stays Private
Ch4pter distinguishes between Public Portfolio Content and Private Booking Content.
Private Booking Content—including private Galleries, Deliverables, Messages, booking information, consultation materials, and other non-public Booking information—is processed solely for legitimate Platform operations, Booking fulfillment, security, dispute resolution, legal compliance, and related operational purposes.
Private Booking Content is not used for advertising or promotional purposes without any additional permissions required under applicable law.
2.6 Public Portfolio Content Promotes the Marketplace
Public Portfolio Content exists to help Service Providers market their businesses.
Consistent with the licenses granted under the applicable Marketplace Agreement, Ch4pter may display Public Portfolio Content throughout the Platform and in promotional materials that market the Service Provider, the Marketplace, or both.
2.7 Responsible Use of Artificial Intelligence
Ch4pter may use artificial intelligence and automated technologies to improve Platform functionality, including fraud prevention, search, moderation, workflow automation, customer support, analytics, recommendations, accessibility, and similar operational functions.
Ch4pter does not use Private Booking Content—including private Galleries, Deliverables, or Messages—to train publicly available artificial intelligence models.
2.8 User Trust Comes First
Every decision regarding the collection, use, storage, and disclosure of personal information is intended to support a trustworthy Marketplace where Service Providers and Clients can confidently conduct business.
ARTICLE 3 — INFORMATION WE COLLECT
3.1 Information You Provide Directly
We collect personal information that you voluntarily provide when you create an Account, complete your profile, request or provide Services, communicate through the Platform, contact Customer Support, participate in Marketplace activities, or otherwise interact with Ch4pter.
The categories of information collected depend upon how you use the Platform.
3.2 Account Information
When you create an Account, we collect information necessary to establish and maintain your Account, which may include:
- first and last name;
- business name;
- username;
- email address;
- telephone number;
- mailing address;
- profile photograph;
- business logo;
- password credentials (stored in encrypted or hashed form through our authentication providers);
- account preferences;
- communication preferences;
- account verification status;
- and other information reasonably necessary to provide the Platform.
3.3 Service Provider Information
Service Providers may provide additional information, including:
- biography;
- service descriptions;
- specialties;
- service areas;
- portfolio images;
- pricing;
- availability;
- scheduling preferences;
- travel information;
- business licensing information, where applicable;
- tax reporting information;
- payout information processed through our payment providers;
- insurance information, where applicable;
- and other Marketplace-related information.
3.4 Client Information
Clients may provide:
- Booking requests;
- preferred dates;
- locations;
- event information;
- family information voluntarily provided for a Booking;
- questionnaires;
- inspiration photographs;
- communication preferences;
- reviews;
- and other information submitted in connection with Marketplace transactions.
3.5 Booking Information
When a Booking is created, we collect information relating to that transaction, including:
- Booking date;
- Booking location;
- participating Users;
- Booking Amount;
- Deposit amount;
- cancellation policy;
- Booking status;
- payment status;
- Deliverable status;
- timeline information;
- and other information reasonably necessary to administer the Marketplace.
3.6 Messages and Communications
We collect information exchanged through Platform messaging features, including:
- message content;
- timestamps;
- attachments;
- delivery status;
- read status;
- and related communication records.
These communications are processed to operate the Platform, facilitate Bookings, provide customer support, investigate disputes, maintain security, and comply with legal obligations.
3.7 User Content
We collect User Content uploaded through the Platform, including:
- Public Portfolio Content;
- Private Booking Content;
- profile images;
- Galleries;
- Deliverables;
- videos;
- documents;
- questionnaires;
- reviews;
- comments;
- captions;
- and other uploaded files.
Ownership of User Content remains with the applicable User or rights holder, subject to the licenses described in the applicable Marketplace Agreement and Terms of Service.
3.8 Customer Support Information
When you contact Ch4pter, we collect information necessary to respond to your request, including:
- your contact information;
- support communications;
- troubleshooting information;
- screenshots you voluntarily provide;
- attachments;
- and related correspondence.
3.9 Information Collected Automatically
When you access or use the Platform, we automatically collect certain technical information necessary to operate, maintain, and secure the Platform.
This information may include:
- IP address;
- browser type;
- browser version;
- operating system;
- device type;
- device identifiers;
- language settings;
- time zone;
- referring pages;
- pages visited;
- clicks;
- search activity;
- session duration;
- feature usage;
- error logs;
- crash reports;
- internet service provider;
- approximate geographic location derived from technical information;
- cookies;
- similar technologies;
- and other technical information generated through normal use of the Platform.
3.10 Information from Third Parties
We may receive information from trusted third parties that help operate the Platform, including:
- payment processors;
- identity verification providers;
- fraud prevention services;
- analytics providers;
- cloud hosting providers;
- authentication providers;
- mapping and geolocation services;
- communication providers;
- and other technology partners.
The information received depends upon the services being provided and the permissions you grant.
ARTICLE 4 — INFORMATION GENERATED THROUGH PLATFORM USE
4.1 Marketplace Activity
As you use the Platform, Ch4pter generates operational records relating to your Marketplace activity.
These records may include:
- Booking history;
- Booking requests;
- Booking outcomes;
- cancellations;
- refunds;
- payment history;
- payout history;
- review history;
- search history;
- favorites;
- saved preferences;
- and Marketplace participation history.
4.2 Gallery Activity
To facilitate Gallery delivery and Marketplace administration, Ch4pter generates records concerning:
- uploads;
- downloads;
- preview access;
- Gallery creation;
- Gallery publication;
- Gallery expiration;
- file counts;
- storage usage;
- delivery status;
- and related operational information.
4.3 Scheduling Information
We generate records relating to scheduling functionality, including:
- calendar availability;
- blocked dates;
- appointment requests;
- confirmations;
- reschedules;
- cancellations;
- and other scheduling activity.
4.4 Platform Usage
We generate operational information concerning how the Platform is used, including:
- feature usage;
- navigation patterns;
- search activity;
- response times;
- software performance;
- system diagnostics;
- error reporting;
- and other technical metrics used to improve Platform functionality.
4.5 Fraud Prevention Information
To protect Users and the Marketplace, Ch4pter generates and maintains information used to identify potential fraud, abuse, unauthorized access, payment irregularities, suspicious Booking activity, spam, automated abuse, and other threats to Platform integrity.
Automated fraud detection may assist in identifying suspicious activity but does not independently determine that a User has violated these Terms.
4.6 Platform Data
Certain operational information generated through the operation of the Platform constitutes Platform Data.
Platform Data includes anonymous usage statistics, Marketplace performance metrics, fraud-detection signals, software telemetry, operational logs, analytics, aggregated Marketplace statistics, and similar operational information generated by Ch4pter.
Platform Data is used to operate, improve, secure, analyze, and maintain the Platform and does not include ownership of User Content or personal information beyond the rights described in this Privacy Policy and the applicable agreements.
ARTICLE 5 — PAYMENT INFORMATION
5.1 Payment Processing
Payments made through the Platform are processed by independent third-party payment providers selected by Ch4pter.
These providers process payment transactions, verify payment methods, facilitate Marketplace payouts, assist with fraud prevention, and perform other payment-related services.
5.2 Payment Card Information
Ch4pter does not store complete payment card numbers, card security codes (CVV), or other sensitive payment credentials entered during checkout.
Payment card information is processed directly by our payment providers in accordance with their own privacy practices and applicable payment industry standards.
5.3 Payment Information We Receive
Although Ch4pter does not receive complete payment card information, we may receive information relating to transactions, including:
- payment status;
- transaction identifiers;
- payment method type;
- partial payment information (such as the last four digits of a payment card where available);
- refunds;
- chargebacks;
- payout status;
- transaction timestamps;
- and other information necessary to administer Marketplace transactions.
5.4 Tax Information
Where required, Service Providers may provide tax reporting information through Ch4pter or our payment providers.
Tax information is collected solely for lawful business purposes, including tax reporting, identity verification, fraud prevention, and compliance with applicable law.
5.5 Payout Information
Service Providers may provide bank account information or other payout instructions through our payment providers.
Ch4pter generally receives only the information reasonably necessary to administer Marketplace payouts and does not store complete banking credentials when those credentials are maintained directly by the payment provider.
5.6 Fraud Prevention
Payment-related information may be used to:
- verify transactions;
- detect fraud;
- prevent unauthorized activity;
- investigate payment disputes;
- administer refunds;
- comply with legal obligations;
- and protect Users and the Platform.
ARTICLE 6 — GALLERIES, DELIVERABLES, AND FILE STORAGE
6.1 Gallery Services
Ch4pter provides digital Gallery services that enable Service Providers to upload, organize, preview, deliver, and manage photographic and other digital Deliverables.
6.2 Public Portfolio Content
Public Portfolio Content is processed to:
- display Service Provider profiles;
- facilitate Marketplace discovery;
- improve search functionality;
- recommend Service Providers;
- operate featured creator programs;
- and promote both the Service Provider and the Marketplace, consistent with the applicable Marketplace Agreement.
6.3 Private Booking Content
Private Booking Content is processed solely for legitimate Platform operations, including:
- facilitating Bookings;
- storing Galleries;
- delivering Deliverables;
- maintaining backups;
- customer support;
- fraud prevention;
- dispute resolution;
- security;
- legal compliance;
- and related operational purposes.
Private Booking Content is not used for advertising or promotional purposes without any additional permissions required under applicable law.
6.4 Gallery Metadata
Ch4pter may collect technical information relating to uploaded files, including:
- upload dates;
- file names;
- file sizes;
- file formats;
- image dimensions;
- timestamps;
- storage usage;
- Gallery status;
- and related operational metadata.
This information is used to operate, maintain, secure, and troubleshoot the Platform.
6.5 Downloads
We maintain records relating to Gallery downloads, including download dates, download activity, and related operational information to facilitate Marketplace operations, customer support, fraud prevention, and dispute resolution.
6.6 Retention
Gallery files may remain stored for varying periods depending upon:
- subscription level;
- storage limits;
- Account status;
- applicable law;
- backup schedules;
- and operational requirements.
Deletion requests are processed in accordance with this Privacy Policy and applicable law.
6.7 Backups
To improve reliability and disaster recovery, encrypted backup copies of certain information may continue to exist for a limited period after deletion from active systems.
Backup copies are maintained solely for legitimate operational, security, disaster recovery, legal compliance, and business continuity purposes and are routinely overwritten or deleted according to Ch4pter's backup retention practices.
ARTICLE 7 — COMMUNICATIONS
7.1 Marketplace Communications
Ch4pter processes communications exchanged through the Platform in order to:
- facilitate Bookings;
- coordinate Services;
- provide customer support;
- maintain Marketplace records;
- investigate disputes;
- prevent fraud;
- enforce Platform policies;
- and comply with legal obligations.
7.2 Transactional Communications
Ch4pter may send transactional communications relating to:
- Account activity;
- Bookings;
- payments;
- refunds;
- Gallery availability;
- security notifications;
- password resets;
- legal notices;
- policy updates;
- and other operational matters.
These communications are considered part of the Platform and generally cannot be opted out of while maintaining an active Account.
7.3 Marketing Communications
With your consent where required by applicable law, Ch4pter may send newsletters, promotional materials, feature announcements, educational content, Marketplace updates, and other marketing communications.
You may unsubscribe from marketing emails at any time using the methods provided in those communications.
Unsubscribing from marketing communications does not prevent Ch4pter from sending necessary transactional communications.
7.4 Push Notifications and SMS
Where supported, Ch4pter may send push notifications or text messages relating to Marketplace activity, Bookings, security, or marketing.
Applicable consent and opt-out mechanisms will be provided where required by law.
7.5 Customer Support
Communications with Customer Support may be retained for quality assurance, training, dispute resolution, fraud prevention, security, and improvement of support services.
ARTICLE 8 — COOKIES AND SIMILAR TECHNOLOGIES
8.1 Cookies
Ch4pter uses cookies and similar technologies to operate, secure, personalize, and improve the Platform.
Cookies are small files stored on your device that allow the Platform to recognize your browser and remember certain information.
8.2 Types of Cookies
Depending upon Platform functionality, Ch4pter may use:
- essential cookies;
- authentication cookies;
- security cookies;
- preference cookies;
- analytics cookies;
- performance cookies;
- session cookies;
- persistent cookies;
- and similar technologies.
8.3 Purposes
Cookies may be used to:
- maintain secure login sessions;
- remember preferences;
- improve Platform performance;
- analyze usage;
- prevent fraud;
- personalize the user experience;
- and support Marketplace functionality.
8.4 Browser Controls
Most web browsers allow Users to control cookies through browser settings.
Disabling certain cookies may limit or prevent portions of the Platform from functioning properly.
8.5 Future Technologies
As technology evolves, Ch4pter may use comparable technologies serving functions similar to cookies, provided such use remains consistent with this Privacy Policy and applicable law.
ARTICLE 9 — HOW WE USE PERSONAL INFORMATION
9.1 General Use
Ch4pter uses personal information only for legitimate business purposes related to operating, improving, securing, and supporting the Platform.
The specific information used depends upon the nature of the User's interaction with the Platform.
9.2 Operating the Marketplace
We use personal information to:
- create and maintain Accounts;
- authenticate Users;
- facilitate Bookings;
- process Marketplace transactions;
- coordinate communications;
- provide Galleries;
- deliver Deliverables;
- administer subscriptions;
- operate Marketplace features;
- and otherwise provide the services requested by Users.
9.3 Customer Support
We use personal information to:
- respond to inquiries;
- troubleshoot technical issues;
- resolve disputes;
- investigate reported problems;
- improve support services;
- verify Account ownership;
- and provide assistance requested by Users.
9.4 Payments
Personal information is used to:
- process transactions;
- administer Marketplace Commissions;
- facilitate payouts;
- prevent payment fraud;
- process refunds;
- investigate chargebacks;
- verify payment activity;
- and comply with financial reporting obligations.
9.5 Platform Security
We use personal information to:
- authenticate Users;
- detect unauthorized access;
- investigate suspicious activity;
- identify fraud;
- maintain Platform integrity;
- protect Accounts;
- enforce Platform security;
- and respond to security incidents.
9.6 Legal Compliance
Personal information may be processed to:
- comply with applicable law;
- respond to lawful legal requests;
- satisfy regulatory obligations;
- enforce contractual rights;
- protect Ch4pter's legal interests;
- and resolve disputes.
9.7 Platform Improvement
We use information to:
- improve existing features;
- develop new functionality;
- analyze Platform performance;
- measure reliability;
- identify bugs;
- evaluate Marketplace trends;
- improve accessibility;
- and enhance the overall User experience.
9.8 Communications
We use personal information to send:
- transactional communications;
- security notices;
- customer support responses;
- Booking updates;
- Marketplace announcements;
- subscription information;
- policy updates;
- and, where permitted, marketing communications.
9.9 Analytics
We analyze Platform usage to better understand:
- Marketplace activity;
- feature adoption;
- search behavior;
- booking trends;
- system performance;
- storage usage;
- and other operational metrics.
Where reasonably practicable, analytics are performed using aggregated or de-identified information.
ARTICLE 10 — ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING
10.1 Use of Artificial Intelligence
Ch4pter may use artificial intelligence, machine learning, and other automated technologies to improve Platform functionality and Marketplace operations.
Examples include:
- fraud detection;
- spam prevention;
- customer support assistance;
- search improvements;
- recommendations;
- workflow automation;
- accessibility improvements;
- image processing;
- content moderation assistance;
- quality assurance;
- analytics;
- and software development.
10.2 Human Oversight
Automated systems assist Ch4pter personnel but do not independently determine Marketplace enforcement actions, account terminations, copyright determinations, or other significant decisions without appropriate human review where reasonably appropriate.
10.3 AI Training Commitment
Ch4pter does not use Private Booking Content—including private Galleries, Deliverables, Messages, consultation information, or other non-public Booking information—to train publicly available artificial intelligence models.
10.4 Internal Development
Ch4pter may use information generated through operation of the Platform, including Platform Data, aggregated information, anonymized information, and information lawfully available to Ch4pter, to develop, improve, test, and operate internal software, analytics, automation, and artificial intelligence systems.
Such use does not transfer ownership of User Content to Ch4pter.
10.5 Public Portfolio Content
Public Portfolio Content may be processed by automated systems as reasonably necessary to:
- improve search functionality;
- recommend Service Providers;
- organize Marketplace listings;
- optimize image presentation;
- moderate content;
- and operate Marketplace features.
Such processing is governed by the applicable Marketplace Agreement.
10.6 Facial Recognition and Biometric Information
Ch4pter does not perform facial recognition, biometric identification, biometric profiling, or similar biometric processing of individuals appearing in photographs unless expressly disclosed and separately authorized where required by applicable law.
ARTICLE 11 — WHEN WE SHARE INFORMATION
11.1 General Principle
Ch4pter does not sell Users' personal information.
We share personal information only as reasonably necessary to operate the Platform, fulfill Marketplace transactions, comply with legal obligations, protect Users, or otherwise as described in this Privacy Policy.
11.2 Between Marketplace Participants
To facilitate Bookings, Ch4pter shares information between Clients and Service Providers, including information reasonably necessary to complete the requested Services.
Depending upon the transaction, this may include:
- names;
- profile information;
- communication information;
- Booking details;
- scheduling information;
- Galleries;
- Deliverables;
- reviews;
- and related Marketplace information.
11.3 Service Providers
Ch4pter shares information with trusted service providers who assist us in operating the Platform.
Depending upon the services provided, this may include:
- payment processors;
- cloud hosting providers;
- storage providers;
- authentication providers;
- analytics providers;
- communication providers;
- mapping services;
- customer support providers;
- fraud prevention providers;
- print fulfillment providers;
- and other vendors performing services on Ch4pter's behalf.
These providers are authorized to use personal information only as reasonably necessary to provide services to Ch4pter or as otherwise permitted by applicable law.
11.4 Legal Compliance
Ch4pter may disclose personal information where reasonably necessary to:
- comply with applicable law;
- respond to valid legal process;
- comply with court orders;
- comply with subpoenas;
- respond to lawful governmental requests;
- protect Users;
- investigate fraud;
- protect Ch4pter's legal rights;
- enforce Platform agreements;
- prevent imminent harm;
- or otherwise comply with legal obligations.
11.5 Business Transactions
If Ch4pter is involved in a merger, acquisition, financing transaction, investment, reorganization, sale of assets, bankruptcy proceeding, or similar corporate transaction, personal information may be transferred as part of that transaction, subject to applicable law.
11.6 With Your Direction
Ch4pter may share personal information with other parties when you request, authorize, or direct us to do so.
11.7 Aggregated Information
Ch4pter may publish or share aggregated, anonymous, or de-identified Marketplace information that does not reasonably identify individual Users.
Examples include:
- Marketplace trends;
- booking statistics;
- pricing trends;
- geographic demand;
- seasonal reports;
- and other Marketplace analytics.
ARTICLE 12 — DATA RETENTION
12.1 General Retention Practices
Ch4pter retains personal information only for as long as reasonably necessary to:
- provide the Platform;
- fulfill Marketplace transactions;
- maintain Account functionality;
- comply with legal obligations;
- resolve disputes;
- enforce agreements;
- prevent fraud;
- maintain security;
- preserve business records;
- and operate the Marketplace.
Retention periods vary depending upon the nature of the information and applicable legal requirements.
12.2 Active Accounts
While an Account remains active, Ch4pter generally retains information necessary to provide ongoing Platform functionality, including:
- Account information;
- profile information;
- Marketplace history;
- Booking records;
- Galleries;
- Messages;
- reviews;
- subscriptions;
- and related operational information.
12.3 Closed Accounts
Following Account closure, Ch4pter may retain information where reasonably necessary for:
- legal compliance;
- tax reporting;
- accounting;
- fraud prevention;
- security;
- dispute resolution;
- enforcement of agreements;
- backup restoration;
- and other legitimate business purposes.
Closure of an Account does not require immediate deletion of all associated information.
12.4 Gallery Retention
Gallery retention periods may depend upon:
- subscription level;
- storage limits;
- Account status;
- Photographer settings;
- applicable law;
- backup requirements;
- and operational needs.
Users are responsible for maintaining independent copies of important files unless Ch4pter expressly offers archival storage services.
12.5 Legal Holds
If Ch4pter reasonably believes information may be relevant to:
- pending litigation;
- arbitration;
- government investigations;
- regulatory inquiries;
- fraud investigations;
- or other legal proceedings,
Ch4pter may preserve that information until the applicable matter has concluded or applicable legal obligations have been satisfied.
12.6 Backup Retention
Information removed from active systems may continue to exist in encrypted backup systems for a limited period until normal backup rotation and deletion procedures are completed.
ARTICLE 13 — YOUR PRIVACY RIGHTS
13.1 General Rights
Depending upon applicable law and your place of residence, you may have certain rights regarding your personal information.
These rights may include the ability to:
- access personal information;
- correct inaccurate information;
- update personal information;
- request deletion;
- request portability;
- withdraw consent where processing is based on consent;
- object to certain processing activities;
- or exercise other rights provided by applicable law.
13.2 Access Requests
Eligible Users may request access to the personal information Ch4pter maintains about them, subject to identity verification, legal restrictions, the rights of other individuals, and applicable law.
13.3 Correction Requests
Users may request correction of inaccurate or incomplete personal information maintained by Ch4pter.
Certain profile information may also be updated directly through the Platform.
13.4 Deletion Requests
Eligible Users may request deletion of personal information, subject to applicable legal obligations and Ch4pter's legitimate business interests, including:
- legal compliance;
- tax reporting;
- fraud prevention;
- dispute resolution;
- enforcement of agreements;
- security;
- backup retention;
- and preservation of Platform integrity.
13.5 Data Portability
Where technically feasible and required by applicable law, eligible Users may request a copy of certain personal information they have provided to Ch4pter in a commonly used electronic format.
13.6 Marketing Preferences
Users may opt out of marketing communications at any time using the unsubscribe instructions provided in those communications.
Operational and transactional communications relating to the Platform may continue to be sent as necessary.
13.7 Verification
Before responding to certain privacy requests, Ch4pter may require reasonable verification of the requestor's identity in order to protect Users and prevent unauthorized disclosure.
ARTICLE 14 — CHILDREN'S PRIVACY
14.1 Intended Audience
The Platform is intended for individuals who are at least eighteen (18) years of age or the age of legal majority in their jurisdiction, whichever is greater.
14.2 No Knowing Collection
Ch4pter does not knowingly collect personal information directly from children in violation of applicable law.
If Ch4pter becomes aware that personal information has been collected directly from a child in violation of applicable law, Ch4pter will take reasonable steps to delete that information.
14.3 Parent or Guardian Requests
Parents or legal guardians who believe a child has improperly provided personal information through the Platform may contact Ch4pter using the contact information provided in this Privacy Policy.
14.4 Photographs of Minors
The Platform may contain photographs or other media depicting minors when uploaded by Service Providers or Clients in connection with legitimate Marketplace transactions.
Ch4pter does not independently verify parental or guardian consent for every image uploaded to the Platform.
Service Providers and Clients are responsible for obtaining any permissions, releases, or consents required under applicable law for the creation, upload, sharing, and use of such content.
ARTICLE 15 — SECURITY
15.1 Security Program
Ch4pter maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction.
15.2 Security Measures
Depending upon Platform functionality, security measures may include:
- encrypted communications;
- encrypted storage where appropriate;
- secure authentication;
- access controls;
- least-privilege permissions;
- security monitoring;
- audit logging;
- backup systems;
- vulnerability management;
- software updates;
- fraud detection;
- and other commercially reasonable security practices.
15.3 User Responsibilities
Users also play an important role in protecting personal information by:
- safeguarding Account credentials;
- using strong passwords;
- maintaining device security;
- promptly reporting suspected unauthorized access;
- and following reasonable security practices.
15.4 No Absolute Security
Although Ch4pter uses commercially reasonable safeguards, no method of electronic transmission, storage, or internet communication can be guaranteed to be completely secure.
Accordingly, Ch4pter cannot guarantee absolute security.
15.5 Security Incidents
If Ch4pter becomes aware of a security incident affecting personal information, Ch4pter will respond in accordance with applicable law and may provide notice to affected individuals where legally required.
ARTICLE 16 — CALIFORNIA AND OTHER U.S. STATE PRIVACY RIGHTS
16.1 Applicability
Residents of certain U.S. states, including California and other states that have enacted comprehensive privacy legislation, may have additional privacy rights under applicable law.
Where such laws apply to Ch4pter, this Privacy Policy is intended to supplement—not replace—those rights.
16.2 Additional Rights
Subject to applicable law, eligible Users may have rights to:
- know the categories of personal information collected;
- know the sources from which personal information is collected;
- understand the purposes for which personal information is processed;
- know the categories of third parties with whom personal information is shared;
- request access to specific personal information;
- request correction of inaccurate personal information;
- request deletion of personal information;
- obtain a portable copy of certain information;
- appeal certain privacy decisions where required by law;
- and exercise other rights provided by applicable law.
16.3 Non-Discrimination
Ch4pter will not unlawfully discriminate against a User for exercising privacy rights granted under applicable law.
However, certain Platform functionality may require the collection or processing of specific information. If required information cannot be processed, some Platform features may become unavailable.
16.4 Authorized Agents
Where permitted by applicable law, Users may authorize another person to submit privacy requests on their behalf.
Ch4pter may require reasonable verification of both the User's identity and the authorized agent's authority before responding.
16.5 Appeals
Where required by applicable law, Users may appeal certain privacy request determinations by contacting Ch4pter using the contact information provided in this Privacy Policy.
ARTICLE 17 — INTERNATIONAL USERS
17.1 International Access
The Platform is operated from the United States.
Individuals accessing the Platform from outside the United States understand that their information may be transferred to, stored in, and processed within the United States or other jurisdictions where Ch4pter or its service providers operate.
17.2 Cross-Border Transfers
Where personal information is transferred internationally, Ch4pter will take commercially reasonable measures designed to ensure that such transfers occur in accordance with applicable law.
17.3 Local Laws
Users accessing the Platform from outside the United States remain responsible for determining whether use of the Platform complies with the laws applicable to them.
ARTICLE 18 — BUSINESS TRANSFERS
18.1 Corporate Transactions
If Ch4pter is involved in:
- a merger;
- acquisition;
- investment;
- financing transaction;
- corporate restructuring;
- sale of assets;
- bankruptcy proceeding;
- receivership;
- or another similar business transaction,
personal information may be transferred as part of that transaction, subject to applicable law.
18.2 Continued Protection
In the event of a business transfer, Ch4pter will use commercially reasonable efforts to ensure that personal information remains subject to protections that are substantially consistent with this Privacy Policy until a revised privacy policy becomes effective.
ARTICLE 19 — CHANGES TO THIS PRIVACY POLICY
19.1 Updates
Ch4pter may revise this Privacy Policy from time to time to reflect changes in:
- Platform functionality;
- applicable law;
- Marketplace operations;
- technology;
- security practices;
- business practices;
- or other legitimate operational needs.
19.2 Notice of Material Changes
Where required by law or reasonably appropriate due to the significance of a change, Ch4pter will provide notice through one or more of the following methods:
- email;
- Platform notifications;
- website notices;
- Account notifications;
- or another reasonable communication method.
19.3 Effective Date
The revised Privacy Policy becomes effective on the date identified by the updated "Effective Date" or "Last Updated" designation unless a later effective date is required by applicable law.
Continued use of the Platform after the effective date constitutes acknowledgment of the revised Privacy Policy to the extent permitted by applicable law.
ARTICLE 20 — CONTACT INFORMATION
Questions regarding this Privacy Policy, privacy practices, or requests relating to personal information may be directed to:
Ch4pter, LLC
130 Townsend St
Midland, MI 48640
Business Telephone: (989) 824-9474
Privacy & Legal Contact: legal.ch4pterapp@gmail.com
Copyright & DMCA Agent
Notices of claimed copyright infringement may be sent to Ch4pter's Designated Copyright Agent:
Brandon Morey, Copyright Agent
Ch4pter, LLC
130 Townsend St, Midland, MI 48640
Email: legal.ch4pterapp@gmail.com
Telephone: (989) 824-9474
See the Terms of Service (Copyright Policy and DMCA Compliance) for the full notice-and-takedown procedure.
ARTICLE 21 — ACKNOWLEDGMENT
By creating an Account, accessing the Platform, submitting information, requesting or providing Marketplace Services, or otherwise using the Platform, you acknowledge that:
- You have read and understand this Privacy Policy.
- You understand how Ch4pter collects, uses, stores, shares, and protects personal information.
- You understand that Ch4pter operates a technology marketplace and processes personal information to facilitate Marketplace operations.
- You understand that Ch4pter distinguishes between Public Portfolio Content, Private Booking Content, Platform Data, and other categories of information as described in this Privacy Policy and the applicable agreements.
- You understand that Ch4pter does not sell personal information.
- You understand that Ch4pter does not use Private Booking Content to train publicly available artificial intelligence models.
- You understand that Ch4pter may update this Privacy Policy from time to time in accordance with Article 19.
Ch4pter, LLC
130 Townsend St
Midland, MI 48640
Business Telephone: (989) 824-9474
Privacy & Legal Contact:
Effective Date: ___________________
Last Updated: ___________________