enGEN3 Privacy Policy

Effective Date: 25. August 2026

Last Updated: 25.August 2026

enGEN3 LLC ("enGEN3," "we," "our," or "us") provides this Privacy Policy to explain how we collect, use, share, and protect information about individuals who access enGEN3 through any enGEN3 site, application, product, or service that links to this policy (collectively, the "Platform").

This policy covers every enGEN3 surface, including Turbocharger. Turbocharger is a product of enGEN3 LLC, not a separate entity, and there is no separate privacy policy for it. Where a product has its own supplemental terms, those terms govern the contract; this policy governs data handling across all of them.

enGEN3 is a participatory intellectual property platform. Rights holders—the Creators of the underlying intellectual property—publish universes to the Platform, and fans participate as Co-Creators under licences that define what they may create, use, share, or commercialize. Because of this structure, some of the information you provide is shared with the rights holder whose universe you are working in. This policy explains when and why.

1. Information We Collect

1.1 Information You Provide

Account information: name, email address, username, password credentials, and authentication data.

Profile information: display name, avatar, biography, social media handles, and any other details you choose to add.

Blockchain wallet address, where you connect a wallet to the Platform.

Payment and tax information: billing details, payout preferences, mailing address, and tax identification numbers where required for payments or tax reporting.

Communications: messages you send to support, feedback, survey responses, and correspondence with us.

1.2 Creative Inputs and Content

Prompts, briefs, scripts, notes, and other text you submit to generation tools.

Reference images, video, audio, documents, and other assets you upload.

Generated outputs, including intermediate versions, revisions, and version history.

Project, storyboard, and world data, including asset metadata and lineage records.

Provenance records associating you with the assets you create, including timestamps, model and provider identifiers, prompt records, and derivative lineage.

1.3 Biometric and Likeness Information

Certain features involve digital twins or likeness-based creation. We may collect facial imagery and voice recordings as content you provide. Some features may also capture, derive, or process facial geometry, voiceprints, or other data that qualifies as a biometric identifier or biometric information under applicable law.

Where a feature involves biometric identifiers or biometric information regulated by applicable law, we provide any notice and obtain any consent or written release required by that law before the regulated collection or processing occurs. A Co-Creator’s representation that they have permission to upload another adult’s image does not replace a direct subject consent or written release where applicable law requires one. Section 4 sets out our biometric practices in full.

1.4 Information Collected Automatically

We and our service providers automatically collect information about your interactions with the Platform, including IP address, browser and device type, operating system, referring URLs, pages and features accessed, session duration, timestamps, and similar technical data, collected through cookies, SDKs, log files, and comparable technologies. See Section 9.

1.5 Performance Data from Third-Party Platforms

Where you publish content created on the Platform to third-party social or video platforms as part of a campaign, program, or revenue-sharing arrangement, we collect publicly available performance data about those posts, including view counts, engagement metrics, and comparable statistics. We collect this to calculate payments owed to you and to measure campaign performance for the applicable rights holder or brand.

1.6 Information from Third Parties

We may receive information about you from identity and authentication providers, payment processors, analytics providers, rights holders who have invited you to participate in a universe or program, and publicly available sources.

2. How We Use Information

We use the information we collect for the following purposes:

To create and administer your account and provide the Platform to you.

To operate generative and creative tools, including routing requests to model providers and returning outputs to you.

To apply rights, permissions, and canon governance, including automated review of submitted and generated content against the rules a rights holder has established for their universe.

To maintain provenance and rights records associating Co-Creators and other originating Account Holders with assets, and to make those records available to rights holders and downstream licensees as required.

To operate the marketplace, process transactions, calculate fees, and administer payouts.

To calculate and administer payments owed to you under campaigns or revenue-sharing programs, including sharing relevant performance and payment data with the applicable rights holder or brand.

To develop, train, evaluate, and improve models and features, subject to Section 5.

To personalize your experience and recommend universes, tools, and content.

To communicate with you about your account, transactions, and support requests.

To send marketing and promotional messages, subject to your choices in Section 11.

To detect, investigate, and prevent fraud, abuse, security incidents, and violations of our terms.

To comply with legal obligations, enforce our agreements, and establish or defend legal claims.

For any other purpose disclosed to you at the point of collection and, where required, with your consent.

3. Legal Bases for Processing (EEA and UK)

Where the EU or UK General Data Protection Regulation applies, we process personal data on the following bases:

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You may object to this processing as described in Section 12.

4. Biometric Information

This section applies when enGEN3 collects or processes data that qualifies as a biometric identifier or biometric information under applicable law. Facial imagery and voice recordings are handled under this Policy generally and do not constitute regulated biometric information under every law or in every processing context. Where the Illinois Biometric Information Privacy Act (BIPA) applies, this section is intended to address the notice, consent, disclosure, security, retention, and destruction obligations applicable to enGEN3.

Purpose. We collect and use regulated biometric information only for the disclosed purpose for which it was obtained, including where applicable to create, train, operate, maintain, or secure a Digital Twin or likeness-based feature, or to verify rights associated with a likeness.

Consent. We do not begin a collection or processing activity that requires a subject’s consent or written release under applicable biometric privacy law until the required notice has been provided and the required consent or release has been obtained. Where BIPA applies, a written release may include informed written consent or an electronic signature. Documentation supplied by a rights holder does not substitute for a subject’s own written release where applicable law requires that release from the subject.

No sale. We do not sell, lease, trade, or otherwise profit from biometric information.

Disclosure. We disclose biometric information only: (a) to the individual depicted or their authorized representative; (b) to the rights holder who licensed the likeness; (c) to service providers who process it on our behalf under contractual restrictions consistent with this section; (d) with your separate written consent; or (e) where required by law, warrant, or subpoena.

Retention and destruction. We retain regulated biometric information only for as long as necessary for the disclosed purpose and as permitted by applicable law. Where BIPA applies, we permanently destroy biometric identifiers and biometric information when the initial purpose for collecting or obtaining them has been satisfied or within three years after the individual’s last interaction with enGEN3, whichever occurs first, subject to any preservation required by law or legal process.

Withdrawal. Where processing is based on consent, you may withdraw that consent by contacting us at info@Film3Squad.io. Withdrawal does not affect processing lawfully carried out before withdrawal. Depending on the feature and applicable law, withdrawal or expiry of an underlying likeness consent may require deactivation of a Digital Twin or cessation of future use of affected content.

Storage. We store biometric information using a reasonable standard of care, and in a manner at least as protective as we use for our own confidential and sensitive information.

5. Model Training and Development

Training is central to how the Platform works. We are explicit about it.

Rights-holder models. Identity, character, and style models are trained on a source-of-truth dataset controlled by the applicable rights holder: captured or licensed material for real people, and approved artwork, style guides, model sheets, or archival material for fictional characters. Provider-generated outputs are used only as approved augmentation, with the provider, prompt, source assets, and derivative lineage recorded.

Your content. We may use content you create on the Platform to train, evaluate, and improve our own models, safety systems, and governance tooling. Where a universe is governed by a rights holder, your content within that universe may also be used to train models for that universe under the terms of the applicable licence.

What we exclude. We do not use your account credentials, payment information, tax identifiers, or private communications with our support team as training data.

Third-party providers. Where a generation request is routed to a third-party model provider, that provider's own terms govern whether your inputs may be retained or used for their training. We contract for zero-retention and no-training terms with providers where commercially available.

5A. AI Transparency and Synthetic Media

Where applicable law requires people to be informed that they are interacting with an AI system, or requires AI-generated or AI-manipulated content to carry a machine-readable mark, label, or disclosure, enGEN3 may apply the required notice or marking. We may also retain information reasonably necessary to support provenance, transparency, and compliance with those requirements. Product terms may require users not to remove or obscure required markings or disclosures.

6. How We Share Information

We share information as follows:

Rights holders. Where you create within a universe, participate in a campaign, or publish to a rights holder's surface, we share your identity, participation status, submitted and generated content, provenance and rights records, content review outcomes, performance data, and payment information with that rights holder, to the extent necessary to administer the universe, enforce their canon and licensing rules, and process payments.

Model and infrastructure providers. We share prompts, reference assets, and related inputs with the model providers required to fulfil your generation requests, and with hosting, storage, and compute providers.

Service providers. We share information with vendors who process it on our behalf, including payment processors, tax reporting services, identity verification providers, analytics providers, customer support platforms, email providers, and security vendors. They are contractually restricted to processing on our instructions.

Payment processors. Payment and payout information is shared with our payment processors and, where required for tax reporting, with tax authorities.

Joint venture and affiliate partners. We may share information with our affiliates and joint venture partners for the purposes described in this policy.

Corporate transactions. We may share information in connection with an actual or prospective merger, acquisition, financing, reorganization, sale of assets, or bankruptcy proceeding.

Legal. We may share information in response to a subpoena, court order, regulatory request, or other legal process; to enforce our terms; to protect the rights, property, or safety of any person; and to investigate fraud or security incidents.

With your direction. We share information with third parties where you direct us to, including when you connect an external account or publish content to a third-party platform.

Deidentified information. We may use and share deidentified or aggregated information without restriction, and will not attempt to reidentify it.

We do not sell personal information for money. Certain sharing for analytics or advertising purposes may constitute "selling" or "sharing" under some US state laws. See Section 13.

7. Public Nature of Your Content

The Platform includes features that publish your content, including to public marketplaces, fan surfaces, galleries, and third-party social platforms. Content you publish, and the profile information attached to it, can be viewed, copied, and redistributed by others. Visibility on third-party platforms depends on the settings of your account with that platform.

Where you publish content created on the Platform to a third-party platform as part of a campaign or revenue-sharing program, we and the applicable rights holder may monitor the public performance of those posts, including views and engagement, to administer the program and calculate payments.

Deleting content from the Platform does not remove copies that others have downloaded, reposted, or that remain on third-party platforms.

8. Payments, Financial and Tax Information

If you earn revenue through the marketplace, a campaign, or a revenue-sharing program, we collect the financial and tax information required to pay you and to meet applicable reporting obligations, including your legal name, address, and tax identification number. This information is shared with the applicable rights holder or brand where necessary to administer payment, and with our payment processors. We do not retain full financial account numbers beyond what is necessary to process a specific payment.

9. Cookies and Analytics

We use cookies, pixels, SDKs, and similar technologies to operate the Platform, remember your preferences, measure performance, and understand usage. We work with third-party analytics providers, including Google Analytics, which collect information about your use of the Platform over time. Information about Google's practices is available at google.com/policies/privacy/partners, and you can opt out at tools.google.com/dlpage/gaoptout.

Your browser may allow you to block or delete cookies. Some Platform features may not function correctly if you do.

Where required by law, we present a consent banner and process non-essential cookies only with your consent.

10. Data Retention

We retain personal information for as long as your account is active and thereafter as needed for the purposes described in this policy.

We may retain information longer where required by law, or where necessary to establish, exercise, or defend legal claims.

11. Your Choices

Marketing. Unsubscribe using the link in any marketing message. We will continue to send transactional messages relating to your account and purchases.

Account. You can review and update your profile information in your account settings.

Cookies and analytics. See Section 9.

Biometric consent. You may withdraw consent as described in Section 4.

12. Rights Under GDPR and UK GDPR

If you are in the EEA, UK, or Switzerland, you have the right to request access to your personal data; correction of inaccurate data; erasure; restriction of processing; portability; and to object to processing based on legitimate interests or carried out for direct marketing. Where processing is based on consent, you may withdraw that consent at any time without affecting prior processing.

To exercise these rights, contact info@Film3Squad.io. You also have the right to lodge a complaint with your local supervisory authority, or with the UK Information Commissioner's Office.

Controller. The controller of your personal data is enGEN3 LLC, 2260 Franklin St, Sheridan, WY 82070, USA.

International transfers. We transfer personal data to the United States and other countries whose laws may differ from those of your jurisdiction. Where we transfer data out of the EEA or UK, we rely on the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, together with supplementary measures where required. You may request a copy of the relevant safeguards at info@Film3Squad.io.

13. Rights Under US State Privacy Laws

If you are a resident of California, Colorado, Connecticut, Virginia, Texas, or another state with a comprehensive privacy law, you may have the right to know what personal information we collect, use, and disclose; to request deletion; to request correction; to obtain a portable copy; to opt out of sale, sharing, or targeted advertising; and to be free from discrimination for exercising these rights.

Sensitive personal information. We collect biometric information, precise account credentials, and financial account information, all of which may be classified as sensitive personal information. We use it only for the purposes described in this policy and do not use it to infer characteristics about you. You may direct us to limit its use.

Categories collected in the past 12 months: identifiers; commercial information; internet activity; geolocation (approximate, from IP); professional information; biometric information; financial information; audio and visual information; and inferences drawn from the above. Sources, purposes, and recipients for each category are described in Sections 1, 2, and 6.

To exercise these rights, contact info@Film3Squad.io. We will verify your request through your account credentials or comparable means. Authorized agents may submit requests with proof of authorization.

14. Children

The Platform is not directed to children. You must be at least 18 years old to create an account. There is no supervised-minor path on any enGEN3 surface, including Turbocharger. We do not knowingly collect personal information from children under 13. If we learn we have done so, we will delete it. Contact info@Film3Squad.io to report a concern.

15. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, access controls, and monitoring. No system is completely secure, and we cannot guarantee the security of information transmitted to us.

16. Changes to This Policy

We will post any changes to this policy on this page and update the "Last Updated" date. Where changes are material, we will provide additional notice by email or in-product notification, and where required, obtain your consent.

17. Contact Us

enGEN3 LLC

2260 Franklin St, Sheridan, WY 82070, USA

info@Film3Squad.io