Privacy Policy

Last updated: June 26, 2025

Thank you for choosing to be part of our community at Rens LLC ("Rens", "we", "us", or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at contact@thefold.club.

This privacy notice describes how we collect, use, disclose, and safeguard your information when you use our mobile application The Fold (the "App"), available on Apple’s App Store and Google Play Store. The Fold is a private, invitation‑only network for accredited investors; all content and data remain within this highly‑vetted community.

Important: This Privacy Policy is provided for general information purposes only and does not constitute legal advice. Requirements vary by jurisdiction (e.g., GDPR in the EU, CCPA/CPRA in California, LGPD in Brazil). Consult qualified counsel to ensure full compliance.

1. Information We Collect

CategoryExamplesCollected?Personal IdentifiersName, email address, phone number, mailing addressYesDevice InformationDevice model, operating system version, unique device identifiers, mobile network informationYesUsage DataApp interactions, feature usage analytics, crash logs, diagnostic dataYesLocation DataGPS, Wi‑Fi, or cell‑tower‑derived locationNoPayment InformationPayment card tokens, transaction IDsNoUser ContentImages or files you voluntarily upload to the AppYes

We do not collect age or date‑of‑birth.

We collect information:

Directly from you when you create an account, complete your profile, or upload content.
Automatically through analytics and diagnostic tools when you use the App.
From essential service providers that help us operate and secure The Fold.

2. How We Use Your Information

We process personal information strictly to:

Provide and maintain The Fold – create member accounts, authenticate identity, and operate core features.
Improve and secure the App – monitor performance, fix bugs, conduct analytics, and protect against fraud.
Enable member interactions – display your user‑generated content within the private network according to your actions.
Communicate with you – transactional emails, push notifications, security alerts, and critical updates.

We do not use your information for advertising, profiling, or any purpose outside The Fold.

3. Sharing Your Information

We do not sell, rent, or otherwise disclose your personal information to third parties outside The Fold community. Information may be shared only with:

Recipient TypePurposeOther MembersWhen you post content, initiate chats, or otherwise engage within the App, selected information (e.g., your name and uploaded files) becomes visible to other vetted members.Service Providers (cloud hosting, analytics, authentication)Operate, maintain, and improve the App under strict confidentiality agreements restricting use to our instructions.Legal AuthoritiesComply with applicable laws, court orders, or lawful requests.

4. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described above, unless a longer retention period is required by law. When no longer needed, we will delete or anonymize your data.

5. Security of Your Information

We use administrative, technical, and physical safeguards designed to protect your information. Despite our efforts, no electronic transmission or storage technology is entirely secure, and we cannot guarantee absolute security.

6. Your Privacy Rights

Depending on your location, you may have rights to:

Access – obtain a copy of personal data we hold.
Correction – request correction of inaccurate data.
Deletion – request erasure of your data.
Restriction / Objection – limit or object to certain processing.
Portability – receive data in a structured, commonly‑used format.

To exercise these rights, email contact@thefold.club. We may request identity verification before responding.

California Residents (CCPA/CPRA)

We do not "sell" or "share" personal information as defined by California law. California residents may still request access or deletion of their data.

European Economic Area (GDPR)

Our legal bases for processing personal data are:

Performance of a contract (Art. 6(1)(b))
Legitimate interests (Art. 6(1)(f)) – securing and improving the App
Compliance with a legal obligation (Art. 6(1)(c))

If you believe we are unlawfully processing your data, you have the right to lodge a complaint with your local supervisory authority.

7. Children’s Privacy

The Fold is not directed to children under 13 (or under 16 in the EEA). We do not knowingly collect personal information from children. If you learn that a child has provided us with personal data, please contact us and we will delete it.

8. Google Play Child‑Safety & EASI Compliance

Google Play requires all apps to address child‑safety risks—even if the app is not intended for children—under its “Expanded Audiences & Sensitive Information” (EASI) framework. We comply as follows:

8.1 Target Audience

The Fold is exclusively for adults (18+) who are accredited investors. We do not market to or permit registration by minors. Age‑gating mechanisms restrict account creation to users who confirm they are 18 or older.

8.2 EASI Data Handling

We do not knowingly collect, store, or process "EASI data" (personal or sensitive information relating to children) as defined by Google Play Child‑Safety Standards.

8.3 In‑App Safety & Reporting

Reporting Tool: Every user‑generated post or profile contains a “Report” option. Members can flag any content, including potential child exploitation or harassment, directly within the App.
Review Timeframe: Reports are reviewed by our Trust & Safety team within 24 hours. Confirmed violations result in content removal and, where appropriate, permanent account suspension.
Escalation: Where legally required, we immediately escalate child‑exploitation imagery or conduct to the National Center for Missing & Exploited Children (NCMEC) or relevant authorities.

8.4 Designated Child‑Safety Contact

For urgent child‑safety matters, email contact@thefold.club with the subject line “Child Safety”. We prioritize such messages ahead of other requests.

9. International Data Transfers

We are headquartered in the United States. Where data is transferred outside your country, we implement appropriate safeguards (e.g., Standard Contractual Clauses) to protect it.

10. Third‑Party Links

The App may contain links to third‑party websites or services. Their privacy practices are governed by their own policies; we encourage you to review them.

11. Changes to This Privacy Policy

We may update this Policy from time to time. The "Last updated" date will reflect the most recent changes. If changes are material, we will notify you via the App or email.

12. Contact Us

Privacy Team – Rens LLC
Email: contact@thefold.club

Apple App Store Privacy Labels & Google Play Data Safety

The disclosures above align with the data categories required by Apple and Google (including EASI‑related child‑safety declarations). Confirm that the answers you provide in App Store Connect and Google Play Console match this Policy.

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