JFK Social Influencer Program Privacy Policy
Effective Date: 2026-05-12. Last Updated: 2026-05-12.
This Privacy Policy describes how ACT 3 AI, Inc. ("Company," "we," "us," or "our"), operator of the JFK Social service ("JFK Social"), processes personal information about individuals who apply to, are admitted to, or participate in the JFK Social Influencer Rev-Share Program (the "Program"). It is incorporated by reference into the JFK Social Influencer Rev-Share Agreement (the "Agreement"). Capitalized terms not defined here have the meanings given in the Agreement.
This Policy covers Influencer-program data. End-user data about JFK Social consumers (including the people you refer) is covered by the separate JFK Social consumer privacy policy posted at jfksocial.com/legal.
Table of Contents
- Scope; Who This Policy Covers
- Influencer-Specific Categories of Personal Information We Collect
- How Referral Attribution Works
- Payout and Tax Data (W-9, 1099, Payment Processor)
- Recipients of Influencer Personal Information
- U.S.-Only Default; International Influencers and Transfers
- Public Disclosure Risk When You Promote on Nostr or Public Profiles
- Retention
- Information Security
- Your Privacy Rights (CCPA / CPRA, VCDPA, CPA, CTDPA, UCPA, OCPA, TIPA, others)
- Do-Not-Sell, Do-Not-Share, and Limit Use of Sensitive PI (California)
- Children Under 13 (COPPA)
- Automated Decision-Making and Profiling
- Cookies and Similar Technologies on the Influencer Portal
- Log Files and Audit Trails
- Changes to This Policy
- How to Contact Us; How to Exercise Your Rights
- Related Documents
1. Scope; Who This Policy Covers
This Policy applies to personal information we collect from and about applicants, admitted Influencers, and former Influencers in connection with the Program. It does not cover (a) consumer use of JFK Social, (b) employees or contractors of Company outside the Program, or (c) personal information of the end users you refer (which is governed by the JFK Social consumer privacy policy). "Personal information" means information that identifies, relates to, describes, or could reasonably be linked with you.
2. Influencer-Specific Categories of Personal Information We Collect
We collect the following categories of personal information about Influencers. We collect each category for the purposes stated and from the sources stated.
2.1 Identity and Contact Information. Legal name, preferred name, postal address, email address, phone number, date of birth (for eligibility under Section 6.1 of the Agreement), and the social-media handles you use to promote JFK Social. Sources: directly from you on application; from public posts in which you tag JFK Social.
2.2 Eligibility and Compliance Information. U.S. citizenship or U.S. permanent-resident status (self-declared); confirmation that you are not on a U.S. sanctions list; representations made under Sections 6.3 and 7.3 of the Agreement; and any government-issued identification you submit to satisfy KYC under Section 5.1 of the Agreement. Sources: directly from you; from Company's or its payment processor's identity-verification vendor.
2.3 Tax Information. Taxpayer name, taxpayer identification number (SSN, ITIN, or EIN), business entity type, and address as reflected on Form W-9 or, where applicable, Form W-8BEN or W-8BEN-E. Sources: directly from you.
2.4 Payout Information. Bank account, debit card, or other payout-rail identifier required by the Payout Method, plus any account-verification data the Payout Method returns to us. Sources: directly from you and from the Payout Method.
2.5 Referral and Attribution Data. The Tracking Links and referral codes we issue to you; the click and conversion events tied to those Tracking Links; the device, browser, IP address, approximate location, and timestamp observed when a prospective user interacts with your Tracking Link; the JFK Social account identifiers attributed to you; the dates, plan tiers, and amounts of Qualifying Subscriptions tied to those accounts; chargeback and refund events. Sources: directly from prospective users' browsers and devices when they follow your Tracking Link; from Company's billing and analytics systems; from third-party affiliate-tracking vendors we may engage.
2.6 Earnings, Payment, and Statement Data. Amounts earned, set off, paid, and forfeited; payout history; payout statements; dispute correspondence; 1099 amounts. Sources: generated by Company.
2.7 Promotional Content and FTC Disclosure Records. Copies of, or links to, the public posts in which you promote JFK Social and the disclosure language you used (per Section 7 of the Agreement). Sources: directly from you; from publicly accessible posts on the platforms where you publish.
2.8 Communications. Emails, support tickets, portal messages, and call recordings (where lawful and disclosed at the time of the call) between you and Company. Sources: directly from you and from Company's communications systems.
2.9 Audit and Fraud Signals. Information we use to detect prohibited self-referrals and synthetic sign-ups under Section 4 of the Agreement, including overlap signals across accounts, payment-instrument reuse, IP and device-fingerprint overlap, and behavioral anomalies. Sources: Company's anti-fraud systems and third-party anti-fraud vendors.
2.10 Sensitive Personal Information. Categories 2.2 and 2.3 may include "sensitive personal information" under U.S. state privacy laws (specifically, taxpayer identification numbers and government identification numbers). We process this information only as necessary for tax compliance, payout, KYC, and sanctions screening, and not for advertising or profiling.
3. How Referral Attribution Works
3.1 What We Place. When a prospective user clicks a Tracking Link, we may set a first-party cookie or local-storage value on that user's browser that identifies the Tracking Link, the timestamp, and a short-lived attribution token. We may also log the IP address and the User-Agent header that the user's browser sends.
3.2 What We Observe Later. If that prospective user later creates a JFK Social account, we read the attribution token (if still present) and any matching server-side signals, and we associate the resulting JFK Social account with you per Sections 3 and 4 of the Agreement.
3.3 What We Do Not Do. We do not place tracking cookies or pixels on the websites or social-media platforms where you publish your Tracking Link. The cookie or token is set only when the prospective user actually visits jfksocial.com or a destination we control.
3.4 Third-Party Affiliate Networks. If we engage a third-party affiliate-tracking vendor to help operate the Program, that vendor will process click and conversion data on our behalf as a processor / service provider under the U.S. state privacy laws.
4. Payout and Tax Data (W-9, 1099, Payment Processor)
4.1 W-9 / W-8. We collect Form W-9 (or, where applicable, the W-8 series) before issuing any payout. We use it to comply with IRS information reporting obligations and to perform U.S. backup withholding if required.
4.2 1099-NEC. For each calendar year in which we pay you the IRS-required threshold or more, we will issue a Form 1099-NEC (or other required information return) to you and to the IRS, and where required, to your state tax authority.
4.3 Payment Processor. We use a third-party payment processor or payment-rail provider as the Payout Method. The Payment Processor is an independent controller for its own KYC, AML, and account-management purposes and a processor / service provider for the payout transaction itself. The Payment Processor's privacy notice governs its own processing.
4.4 No Use for Advertising. We do not use Form W-9 information, Form 1099 information, bank account numbers, or government identifiers for advertising, profiling, or any purpose other than payout, tax reporting, sanctions screening, and fraud prevention.
5. Recipients of Influencer Personal Information
We disclose your personal information only to:
5.1 Service Providers and Processors. The Payment Processor; tax-form generation vendors; KYC and identity-verification vendors; affiliate-tracking vendors; cloud-hosting providers (e.g., AWS); email and ticketing providers. Each is contractually bound to use the information only to provide services to us.
5.2 Tax Authorities. The IRS and, where required, state and local tax authorities, by means of Form 1099 and related filings.
5.3 Legal and Safety. Law enforcement, regulators, or courts in response to a lawful request (subpoena, warrant, court order), and where we believe in good faith that disclosure is necessary to (a) comply with law, (b) enforce the Agreement, (c) protect the rights, property, or safety of Company, our users, or the public, or (d) investigate fraud or security incidents.
5.4 Successor in Interest. A successor entity in a merger, acquisition, reorganization, financing, or sale of all or substantially all of our assets, subject to standard confidentiality protections.
5.5 With Your Consent. Any other recipient to whom you direct us in writing.
We do not "sell" your personal information for money, and except as described in Section 11, we do not "share" your personal information for cross-context behavioral advertising.
6. U.S.-Only Default; International Influencers and Transfers
The Program is offered to U.S. citizens and U.S. permanent residents under Section 6.2 of the Agreement. If we admit you from outside the United States, your personal information will be transferred to and stored in the United States, where data-protection laws differ from those of your country of residence. Where the GDPR or UK GDPR applies, we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable) as the transfer mechanism, and you may request a copy by emailing privacy@jfksocial.com.
7. Public Disclosure Risk When You Promote on Nostr or Public Profiles
JFK Social interoperates with the Nostr protocol. If, while promoting JFK Social, you publish posts signed with a Nostr public key (npub), those posts and the npub are propagated to public Nostr relays and become broadcast, replicable, and effectively permanent on the Nostr network. We do not control third-party Nostr relays or their retention, and Nostr's public-by-default model means that information you publish there will be visible to anyone and cannot be reliably deleted from the network. Treat anything you post on Nostr, X, or any other public platform as public.
This Policy does not turn your public promotional posts into our private data; we may collect copies of them as described in Section 2.7, but we do not control their continued public availability on third-party platforms.
8. Retention
We retain personal information about you for as long as is necessary to operate the Program and as required to satisfy our legal obligations, with the following defaults (which may be extended for active litigation, regulatory hold, or audit):
(a) Identity, contact, and eligibility information: for the term of the Agreement and seven (7) years after termination. (b) Tax information (W-9, W-8, 1099): seven (7) years after the end of the calendar year to which it relates, consistent with IRS guidance and applicable statutes of limitations. (c) Payout records, payout statements, and earnings history: seven (7) years after the date of each transaction. (d) Referral, attribution, and earnings calculation data: while the underlying Referred User remains attributed to you, plus seven (7) years. (e) Promotional content and FTC disclosure records: at least two (2) years after each piece of promotional content is published, consistent with Section 7.4 of the Agreement. (f) Communications: three (3) years after the communication, unless tied to a payout or dispute, in which case they follow (c). (g) Fraud and audit signals: up to seven (7) years, longer if needed to investigate or defend an ongoing matter.
When the retention period for a given record ends, we delete or de-identify the record on a reasonable schedule. Backups follow a separate destruction schedule and are not separately searchable on individual deletion requests.
9. Information Security
We use administrative, technical, and physical safeguards designed to protect Influencer personal information, including encryption in transit, encryption at rest for sensitive identifiers, role-based access control, audit logging, KYC integration with regulated payment processors, and vendor security reviews. No security program is perfect; we cannot guarantee that personal information will never be subject to unauthorized access or disclosure.
10. Your Privacy Rights (CCPA / CPRA, VCDPA, CPA, CTDPA, UCPA, OCPA, TIPA, others)
Depending on the U.S. state where you reside, you have one or more of the following rights with respect to your personal information:
10.1 Right to Know / Right of Access. The right to confirm that we process personal information about you, to obtain a copy of that information in a portable format, and to know the categories of personal information we have collected, the sources, the business purposes for collection, and the categories of recipients.
10.2 Right to Correct. The right to correct inaccurate personal information we maintain about you.
10.3 Right to Delete. The right to request deletion of personal information we collected from you, subject to exceptions for tax records, anti-fraud, legal-defense, and other purposes recognized under each statute.
10.4 Right to Opt Out of Sale or Sharing for Cross-Context Behavioral Advertising. See Section 11. We do not sell or share Influencer personal information as those terms are defined under U.S. state privacy laws.
10.5 Right to Limit Use of Sensitive Personal Information. See Section 11. We process sensitive personal information only for the limited purposes described in Section 2.10.
10.6 Right to Opt Out of Profiling. The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in such profiling for Influencers; see Section 13.
10.7 Right to Appeal. If we deny a rights request, you have the right to appeal that decision (where the applicable state law provides this right). Submit appeals to privacy@jfksocial.com with subject line "Privacy Rights Appeal."
10.8 Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights.
10.9 Authorized Agent. You may use an authorized agent to submit a rights request on your behalf where the applicable state law permits. We may require the agent to provide proof of authorization and may require you to verify your identity directly.
10.10 How to Submit. See Section 17. We will respond within the time required by the applicable statute (typically 45 days, extendable once where allowed).
11. Do-Not-Sell, Do-Not-Share, and Limit Use of Sensitive PI (California)
We do not "sell" personal information about Influencers in exchange for monetary consideration, and we do not "share" personal information about Influencers for cross-context behavioral advertising, as those terms are defined under the CCPA / CPRA. We process sensitive personal information (Section 2.10) only for the purposes specified in CCPA Reg. § 7027(m) (legal compliance, payment processing, fraud prevention, and verification of the Influencer's identity), and we do not use it to infer characteristics about you. No separate "Do Not Sell or Share My Personal Information" link or "Limit the Use of My Sensitive Personal Information" link is required for the Influencer Program because we already limit our processing to those exempt purposes; if our practices change, we will update this Section and provide the required links and global-privacy-control honoring.
12. Children Under 13 (COPPA)
The Program is not directed to and is not available to individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete it and terminate any account associated with it. If you believe a child under 13 has provided us personal information in the context of the Program, contact us under Section 17.
13. Automated Decision-Making and Profiling
We use automated systems to detect prohibited self-referrals, synthetic sign-ups, and other conduct that violates Section 4 of the Agreement. A human reviewer makes the final adjudication on any consequential action (forfeiture of rev-share, suspension, termination), per Section 4.5 of the Agreement. We do not use automated decision-making to produce legal or similarly significant effects on you without that human review.
14. Cookies and Similar Technologies on the Influencer Portal
The Influencer Portal uses strictly necessary cookies for authentication, security, and load balancing, plus first-party analytics cookies that help us measure portal usage and detect abuse. We do not use third-party advertising cookies on the Influencer Portal. You can configure your browser to refuse cookies, but the Portal may not function correctly if you do.
15. Log Files and Audit Trails
Our servers automatically record information such as IP address, browser type, pages visited, timestamps, and HTTP status when the Influencer Portal or Tracking Link infrastructure is accessed. We use logs for security, fraud prevention, debugging, and audit. Logs are retained for the periods set in Section 8.
16. Changes to This Policy
We may amend this Policy. Material changes will be communicated by email to your address on file and by notice in the Influencer Portal at least thirty (30) days before they take effect. The "Last Updated" date at the top of the Policy reflects the most recent revision. Continued participation in the Program after the effective date constitutes acceptance.
17. How to Contact Us; How to Exercise Your Rights
Email: privacy@jfksocial.com. For rights requests, use the subject line "Privacy Rights Request — Influencer Program" and include your full name, the email address associated with your Influencer account, and a description of your request. We will verify your identity before responding.
Postal address: ACT 3 AI, Inc., Privacy Office, at the address published at jfksocial.com/legal/contact.
For appeals of denied rights requests, use the subject line "Privacy Rights Appeal — Influencer Program."
18. Related Documents
This Privacy Policy is one of three companion privacy policies JFK Social maintains, one for each category of relationship Company has with a data subject. This Policy applies to Influencer-program data, as defined in Section 1. The two complementary privacy policies address Company's processing of personal information about other categories of individual:
- Consumer (JFKSocial.com User) Privacy Policy — /consumer/privacy. This Policy governs Company's processing of personal information about end users who create accounts on jfksocial.com (including the people you refer). If you are an Influencer who also uses JFK Social as a customer, Company's processing of your consumer-side data is governed by that Policy in addition to this one.
- JFK Fork Operator Privacy Policy — /fork/privacy. This Policy governs Company's processing of personal information about operators who deploy a fork of the JFK Social software. It is unrelated to the Program described here; it is listed for navigability across the JFK Social legal documents.
The licenses that pair with each of the above privacy policies are:
- Influencer Rev-Share Agreement — /influencers/license (the companion agreement to this Policy; it is the contract under which Company processes your personal information for the Program).
- Consumer License — /consumer/license.
- JFK Fork Operator License — /fork/license.