Privacy Policy

Effective Date: September 11, 2025

Company Name: KKY Group LLC
Registered in: Delaware, United States

KKY Group LLC ("Company," "we," "our," or "us") operates Hot‑Pepper (the "Website"). We are committed to protecting your privacy and being transparent about how we collect, use, and safeguard information.

By using the Website, you agree to this Privacy Policy. If you do not agree, please discontinue use of our services.

1) Eligibility & Age Verification

  • The Website is intended only for individuals 18 or older. We do not knowingly collect information from anyone under 18.
  • Where required by law or platform policy, we may implement age and identity verification (which may be conducted by vetted third‑party providers). If biometric verification (e.g., liveness/face match) is used, we will provide a separate notice and obtain consent where required by law.

2) What We Collect

We collect information in the following categories (depending on how you interact with the Website):

  • Account & Identity Information: name, email address, date of birth, phone number, country, identity documents and selfies (for KYC/age/AML checks when required), creator tax information (e.g., W‑9/W‑8), payout information (e.g., wallet address).
  • Financial/Transaction Information: on‑chain wallet addresses, transaction hashes, order IDs, payment status, and related metadata. Note: We do not store full card numbers; fiat purchases are processed by MoonPay. Crypto payments are processed through Coinbase Commerce.
  • Technical Information: IP address, device and browser type, operating system, language, time zone, referral URL, cookie identifiers, approximate location (derived from IP), and general activity logs.
  • Content & Communications: user‑generated content (UGC), profile details, public posts, media uploads, comments, messages, and reports/flags related to moderation.
  • Support & Compliance: messages to support, identity or risk review outcomes, and records necessary to comply with law (e.g., AML/CTF) and our Terms.

We may combine information we collect from you with information from our service providers, analytics tools, or publicly available sources.

3) How We Use Information

We use information to:

  • Provide and operate the Website and process crypto payments (Coinbase Commerce) and fiat card purchases of crypto (MoonPay).
  • Verify age/identity and comply with AML/KYC, sanctions screening, and risk checks (where applicable).
  • Manage accounts, creator payouts, and customer support.
  • Detect, prevent, and investigate fraud, abuse, illegal content, or violations of our Terms (including content safety and moderation).
  • Improve and personalize the Website, including analytics, debugging, and service optimization.
  • Send transactional communications (e.g., receipts, security alerts). For marketing communications, we obtain consent where required and provide opt‑out options.
  • Comply with legal/regulatory obligations and enforce our agreements.

Legal bases (EEA/UK): contract performance, legitimate interests (e.g., site security, fraud prevention), legal obligations (e.g., AML/CTF, tax), and consent (e.g., certain cookies/marketing or biometric verification where applicable).

4) Payments & Third‑Party Providers

  • Crypto payments via Coinbase Commerce. When you elect to pay in crypto, aspects of your transaction are handled directly by Coinbase Commerce. Coinbase Commerce and/or its affiliates may act as independent controllers of certain data (e.g., wallet, transaction details) and process such data per their privacy notices. See Coinbase Commerce’s Privacy Policy for details.
  • Fiat card purchases via MoonPay. If you choose to fund a wallet using fiat (e.g., card/Apple Pay), we integrate MoonPay as a fiat‑to‑crypto on‑ramp. MoonPay acts as an independent controller for the personal data you submit to them and will conduct any required KYC/AML processes under its own terms and privacy policy.
  • We do not store full card numbers on our servers. We receive limited payment metadata (e.g., status, timestamp) for reconciliation, support, fraud prevention, and accounting.

Links: Coinbase Commerce Privacy Policy and Coinbase Global Privacy Policy; MoonPay Privacy Policy (see §14 below for references).

5) Sharing of Information

We may share information with:

  • Payment & Fintech Partners: Coinbase Commerce (crypto), MoonPay (fiat on‑ramp), and any other vetted payments or payout partners.
  • Service Providers/Processors: hosting, cloud storage/CDN, analytics, security, anti‑fraud/abuse, email/SMS delivery, customer support tools, identity/age verification, and moderation providers.
  • Legal & Compliance: regulators, law enforcement, competent authorities, or parties to legal proceedings when required by law or to protect rights, safety, and property.
  • Corporate Transactions: in connection with a merger, acquisition, or asset sale (with appropriate safeguards and notice where required).

We do not sell personal data. We also do not permit third‑party ad networks to profile users on the basis of adult content consumption.

6) Cookies & Similar Technologies

We use cookies, local storage, and similar technologies for authentication, security, preference management, analytics, and site performance.

  • Where required (e.g., EEA/UK), we present a cookie consent banner so you can accept/decline non‑essential cookies.
  • You can manage cookies in your browser settings; disabling certain cookies may break some features.

7) Public Blockchains & Transparency

Transactions broadcast on public blockchains are public, immutable, and may be searchable by anyone. Your wallet address, transaction hash, and related metadata may be visible on‑chain and to blockchain analytics providers. We cannot alter or delete blockchain records.

8) Data Retention

We retain personal data for as long as necessary to provide the Website and for the purposes outlined above, including:

  • Account data for the life of the account and a reasonable period thereafter for dispute resolution, fraud prevention, and legal compliance.
  • KYC/AML, tax, and business records kept for periods required by law (often 5–7 years or longer where local law requires).
  • Content, logs, and moderation records retained as necessary to maintain platform integrity and comply with safety and reporting obligations.
    When retention is no longer necessary, we delete or anonymize data.

9) Security

We implement technical and organizational measures to protect personal data, including encryption in transit, least‑privilege access controls, monitoring, and secure development practices. However, no method of transmission or storage is 100% secure. If we become aware of a data breach that affects your rights, we will notify you and/or regulators as required by law.

10) Your Rights & Choices

Your rights vary by location and may include: access, correction, deletion, restriction, portability, and objection to processing. You may also withdraw consent (where applicable) without affecting the lawfulness of processing before withdrawal.

  • Marketing communications: you can opt out via the link in the email or in your account settings.
  • EEA/UK users: you may lodge a complaint with your local supervisory authority.
  • U.S. state laws (e.g., CA, CO, CT, VA, UT): residents may have additional rights, including the right to opt out of certain processing (e.g., targeted advertising or “sharing”). We do not sell personal information. If we engage in activities considered “sharing” under applicable law, we will provide a “Do Not Sell/Share My Personal Information” link and honor opt‑out preference signals where required.

To exercise rights, contact support@hot‑pepper.co. We may take steps to verify your identity before responding.

11) International Data Transfers

We are based in the United States and may transfer data to the U.S. and other countries that may not provide the same level of data protection as your home jurisdiction. Where required, we rely on appropriate safeguards (e.g., Standard Contractual Clauses and supplementary measures) for transfers from the EEA/UK.

If we appoint an EU or UK representative under GDPR/UK GDPR Article 27, we will update this Policy with their contact details.

12) Creators, Messaging & Moderation

  • Creators: If you are a creator, we process additional data for onboarding, payout, and tax reporting (e.g., W‑9/W‑8 for U.S. tax compliance).
  • Messaging: Direct messages may be scanned automatically and/or reviewed to detect spam, illegal activity, or policy violations.
  • Illegal Content: We enforce strict prohibitions against illegal content. We may preserve and disclose relevant data to law enforcement where legally required.

13) Children’s Data

We do not knowingly collect data from anyone under 18. If you believe a minor has provided data, contact us so we can take appropriate action.

14) Third‑Party Notices (References)

These third parties process data under their own policies and may act as independent controllers for certain activities.

15) Changes to This Policy

We may update this Policy periodically. We will post updates here and revise the Effective Date. If changes materially affect your rights, we will provide additional notice as required by law.

16) Contact Us

KKY Group LLC
 Registered in Delaware, United States
Email: support@hot‑pepper.co

If you have questions about this Policy or wish to exercise your rights, please contact us at the email above.

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