Brushly

Privacy Policy

Last updated: July 11, 2025

Welcome to Brushly

We understand the importance of your privacy and are committed to being transparent about how we collect, use, and protect your information.

This Privacy Policy explains our practices regarding data collection and usage. By using our platform, you agree to the collection and use of information as described in this policy.

Who We Are

Brushly Digital Ltd Co. is a platform that connects artists with clients seeking commissions. Our platform facilitates the commission process, payments, and communication between parties.

Information We Collect

Information You Provide to Us

Account Information: Name, email address, username, and password when you register
Profile Information: Portfolio samples, commission rates, and biographical information for artists
Payment Information: Payment details processed securely through Stripe (we don't store complete card numbers)
Commission Details: Project information, requirements, and communications
Feedback and Reviews: Content you provide in reviews or ratings

Information We Collect Automatically

Usage Data: How you interact with our platform, pages visited, and features used
Device Information: Device type, browser, IP address, and operating system
Cookies & Technologies: Cookies to enhance your experience and understand usage patterns

How We Use Your Information

We use your information to:

Provide, maintain, and improve our services
Process payments and commissions
Communicate about accounts and updates
Monitor usage for security and performance
Prevent fraud and enforce terms
Comply with legal obligations

Sharing Your Information

We may share your information with:

•
Artists and Clients: To facilitate commissions and communication between parties
•
Service Providers: Third-party vendors like Stripe for payment processing
•
Legal Requests: When required by law or to protect our rights

We will never sell your personal information to third parties.

Your Rights and Choices

Depending on your location, you may have rights to:

Access, correct, or delete your personal information
Object to or restrict certain processing of your data
Data portability
Withdraw consent

To exercise these rights, please contact us at support@brushly.app

GDPR Information for EU Users

Your GDPR Rights

If you are located in the European Union, you have additional rights under the General Data Protection Regulation (GDPR). This section explains these rights and how we comply with GDPR requirements.

Data Controller: Brushly Digital Ltd Co. is the data controller for your personal information.

Legal Basis for Processing

We process your personal data under the following legal bases:

Contract Performance: To provide our commission platform services and process payments
Legitimate Interest: To improve our services, prevent fraud, and ensure platform security
Consent: For marketing communications and optional features (you can withdraw anytime)
Legal Obligation: To comply with tax, accounting, and other legal requirements

Your GDPR Rights

Under GDPR, you have the following rights regarding your personal data:

Right of Access

Request a copy of all personal data we hold about you

Right to Rectification

Correct any inaccurate or incomplete personal data

Right to Erasure

Request deletion of your personal data (subject to legal obligations)

Right to Restrict Processing

Limit how we process your data in certain circumstances

Right to Data Portability

Receive your data in a structured, machine-readable format

Right to Object

Object to processing based on legitimate interests or direct marketing

Right to Withdraw Consent

Withdraw consent at any time where processing is based on consent

Right to Lodge a Complaint

File a complaint with your local data protection authority

Data Retention Periods

We retain your personal data for the following periods:

Account Information: Until account deletion + 30 days for backup recovery
Commission Data: 7 years after completion (tax and legal requirements)
Payment Information: 7 years (financial record requirements)
Marketing Data: Until consent is withdrawn or 3 years of inactivity
Analytics Data: 26 months (anonymized after 14 months)

International Data Transfers

Your data may be transferred outside the EU to our service providers. We ensure adequate protection through:

Standard Contractual Clauses (SCCs) approved by the European Commission
Adequacy decisions for transfers to countries with adequate protection
Regular assessments of third-party security measures

How to Exercise Your GDPR Rights

To exercise any of your GDPR rights, please contact us using the methods below. We will respond within one month.

Data Protection Officer:

Brushly Digital Ltd Co.
GDPR Compliance Team
[Company Address]
Email: dpo@brushly.app

Important: You also have the right to lodge a complaint with your local supervisory authority if you believe we have not adequately addressed your concerns.

Data Security & Protection

Security Measures

We implement appropriate security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. However, no internet transmission is 100% secure, and we cannot guarantee absolute security.

Data Retention

We retain your information as long as your account is active or as needed to provide services. We may retain certain information to comply with legal obligations, resolve disputes, and enforce agreements.

International Data Transfers

Your information may be transferred to and processed in countries other than your residence. We ensure appropriate safeguards are in place to protect your information when transferred internationally.

Special Policies

Children's Privacy

Our services are not directed to individuals under 13 (or higher age as required by local law). We do not knowingly collect personal information from children. If we learn we have collected information from a child, we will delete that information.

NSFW Content

While Brushly supports artists who create NSFW content, we take steps to ensure all content complies with applicable laws:

  • • All NSFW content must be properly labeled and age-restricted
  • • We prohibit illegal content, including content depicting minors
  • • We comply with all legal requirements for platforms that host NSFW content
  • • NSFW content is subject to our Terms of Service

Policy Updates & Contact

We may update this Privacy Policy periodically. We will notify you of significant changes by posting the new policy on this page and updating the effective date.

If you have questions about this Privacy Policy, please contact us:

Contact Support