Section 01Scope and Who We Are
This policy covers everything MADE CX runs. We are the company responsible for your information. A few services have their own notices, and a few partners — like our payment provider — handle some of your information under their own policies.
This Privacy Policy (the “Policy”) describes how MADE CX Inc., a Delaware corporation headquartered in Los Angeles, California (“MADE CX,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects personal information in connection with the MADE CX platform — including the made.cx website and any subdomain, the REGISTER, MARKET, LEDGER and SERVICES experiences, Culture Maker and Buyer dashboards, public $Ticker profile pages, the Cultural Property Registry, the Cultural Property Ledger, Agentic Operations, Custodial Services, Culture Market Data, application programming interfaces, and the communications we send (collectively, the “Platform”).
MADE CX is the controller (or “business,” under U.S. state law) of the personal information described in this Policy, except where we state that we act on behalf of another party. When we perform Custodial Services under a Custodial Authorization, we process certain information on the Culture Maker’s instructions; when an institution, estate, agency, or enterprise customer provides us with information about its own personnel or members, that customer may be the controller of that information and its own privacy notice will also apply.
This Policy applies to Culture Makers, Buyers, estates and their representatives, contributors who request Receipts, non-user participants who record transactions on the Ledger, people who submit consultation or waitlist forms, visitors to the Platform, and people who are the subject of Culture Market Data drawn from public sources. It does not apply to third-party websites, services, or platforms that we link to or monitor, which are governed by their own policies.
Capitalized terms that are not defined here have the meanings given in the Terms of Use. If this Policy and the Terms of Use conflict on a matter of personal information, this Policy controls.
Section 02Definitions
The words that matter most in this policy, and what we mean by them.
- Personal Information
- Any information that identifies, relates to, describes, or is reasonably capable of being associated with an identified or identifiable individual or household. It includes information about you as a Culture Maker, Buyer, or representative, and may include information embedded in Creative Property, such as a likeness, voice, or name.
- Sensitive Personal Information
- Categories of Personal Information given heightened protection by law, including government identifiers (such as a Social Security or tax identification number), financial account credentials, precise geolocation, biometric identifiers, and information revealing racial or ethnic origin, religious beliefs, health, or sexual orientation.
- Processing
- Any operation performed on Personal Information, including collection, recording, organization, storage, analysis, scoring, transcription, disclosure, anchoring, and deletion.
- Public Record
- The parts of the Platform that are designed to be publicly visible: registry entries, $Ticker profile pages, MARKET tiles and tapes, and the Cultural Property Ledger, each subject to the rules in Sections 7 and 8.
- Confidential Designation
- An election you make through the tools we provide to keep Creative Property, evidence, license terms, or asset-level Valuation Data out of the Public Record.
- Service Provider
- A company that processes Personal Information on our behalf and under our instructions, bound by contract to use it only to provide services to us (also called a “processor” or “contractor” under applicable law).
- Anchoring
- Writing a cryptographic hash and minimal metadata to a public blockchain so that a record can later be verified as unchanged.
Section 03Information We Collect
We collect what you give us to register, value, license and protect your work; what your devices tell us when you use the platform; and what we receive from partners and public sources. We try to collect only what the service needs.
3.1Information You Provide
| Category | Examples | When |
|---|---|---|
| Account and identity | Name, professional or artist name, email address of record, password or sign-in credential, phone number, city and country, organization and role | Creating an account, signing in, updating your profile |
| $Ticker and profile | Claimed $Ticker, display name, biography, profile image, links, disclosure preferences | Claiming a $Ticker; editing your public profile at made.cx/@TICKER |
| Creative Property and metadata | Files, titles, descriptions, dates of creation, co-creators, samples and sources, cultural origin and lineage statements, tags | Registering a work |
| Provenance and authority evidence | Drafts, session files, contracts, correspondence, letters of administration, assignments, operating agreements, witness statements | Verification, deep or contested provenance review, estate and collective registrations |
| Valuation inputs | Usage history, audience and reach information, licensing history, answers to valuation intake questions | Ordering a valuation or strategy path |
| Licensing and commercial | License requests, intended use, media, territory, term, organization details, Attribution Line and Public Use Log entries | Requesting, reviewing, or clearing a Cultural Use License |
| Enforcement and consultation | Affected works, the party using a work, where and when a use was observed, estimated value at issue, supporting links | Requesting a lien consultation; authorizing Custodial Services |
| Ledger and Receipts | Claimed contributions, role in a work or transaction, evidence of contribution, identity confirmation for non-users | Recording a transaction or requesting a Receipt |
| Prompts and voice | Typed instructions, voice recordings and their transcripts, Agent conversation history | Using Agentic Operations |
| Communications | Messages to support, Council submissions, dispute filings, survey responses, waitlist sign-ups | Contacting us or taking part in governance |
Some Creative Property is itself personal: a portrait, a recorded voice, a signature style tied to a named person. When you register such a work, you represent under the Terms of Use that you have the rights and permissions needed to submit it, including the consent of any identifiable person depicted where the law requires it.
3.2Information Collected Automatically
When you use the Platform, we and our Service Providers automatically collect technical information, including IP address; approximate location derived from IP address (city or region, not precise geolocation); browser type, device type, and operating system; referring and exit pages; pages viewed, features used, search queries entered on the Ledger and in MARKET, and the date and time of each action; session and authentication tokens; error and performance logs; and preferences such as your light or dark theme. See Section 13 for the technologies we use to collect this information.
3.3Information We Receive from Others
- Payment and identity partners. Our payment provider tells us whether your payout account is verified, enabled, restricted, or under review; the last four digits of a linked bank account or card; payout and transaction status; and dispute and chargeback notices. We do not receive your full Social Security number, full bank account number, or full card number (Section 10).
- Sign-in providers. If you sign in through a third-party provider, we receive the information that provider shares with your permission, typically your name, email address, and profile image.
- Other Users. Culture Makers may name you as a co-creator or contributor; Buyers may identify their personnel; estates may identify heirs and representatives; a claimant may name you as the party using a work.
- Cultural Moderators and the Council. Reviewers record their findings, verification levels, and determinations about registrations and contributions.
- Public sources. Our Agents compile information from news, social platforms, commerce listings, and audio and visual streams to monitor for uses of registered work and to produce Culture Market Data (Section 12).
- Partners and referrers. Pilot partners, institutions, and people who introduce you to MADE CX may share your name and contact details so that we can reach you.
3.4Information We Do Not Seek
We do not ask for, and ask that you not submit, Sensitive Personal Information beyond what a specific service requires. Where a lineage or cultural-origin statement necessarily reveals information about racial or ethnic origin or religious or community affiliation, we process it only to evaluate and record the provenance of the work under the Cultural Property Rights Standard, with your consent where the law requires it, and we do not use it to profile you, to target advertising, or to make decisions about your eligibility for the Platform.
Section 04How We Use Information
We use your information to run the registry, the ledger and the market; to value, license and protect your work; to pay you; to keep the platform honest and secure; and to tell you what is happening. We do not sell it.
| Purpose | What this involves |
|---|---|
| Provide the Platform | Creating and securing accounts; allocating $Tickers; hosting profile pages; operating dashboards; responding to requests |
| Register and verify | Ingesting and fingerprinting works; issuing BCIDs; reviewing provenance and authority evidence; routing heritage and disputed claims to Moderators and the Council |
| Value and analyze | Computing CPRS Scores, tiers, and TCPMV marks; preparing Registrable Rights Inventories, monetization pathways, forward scenarios, and property position narratives |
| License and attribute | Presenting licensing options to Buyers; clearing Cultural Use Licenses; maintaining Attribution Lines and Public Use Logs so the originator’s name travels with the work |
| Protect and enforce | Monitoring public sources for uses of registered work; preparing notices; administering Cultural Liens and Custodial Services within your authorization |
| Pay and account | Splitting license proceeds; distributing payouts through our payment provider; reconciling fees; meeting tax-reporting obligations |
| Keep the record | Publishing Ledger entries under the privacy rule; issuing and anchoring Receipts; appending corrections |
| Integrity and safety | Detecting fraud, score manipulation, sham transactions, impersonation, and prompt abuse; enforcing the Terms of Use; screening against sanctions lists |
| Improve the service | Measuring feature use; diagnosing errors; evaluating and improving the accuracy and safety of Agents and scoring |
| Communicate | Sending service, security, and legal notices; distribution statements; enforcement reports; and, with your permission, updates and invitations |
| Research and public interest | Producing aggregated or de-identified reports on the cultural economy, including with the CX Foundation, that do not identify individuals |
| Legal and governance | Complying with law, court orders, and lawful requests; establishing, exercising, or defending legal claims; supporting Council review |
We use Personal Information only for the purposes described in this Policy, purposes that are compatible with them, or purposes disclosed to you when we collect the information. If we want to use Personal Information for a materially different purpose, we will tell you and, where the law requires, ask for your consent first.
Where we create de-identified or aggregated information, we maintain it in de-identified form, do not attempt to re-identify it, and contractually prohibit recipients from re-identifying it.
Section 05Legal Bases for Processing
Some laws require us to name the legal reason for each use of your information. Mostly it is because we need it to deliver the service you asked for, because the law requires it, or because it serves a legitimate interest that does not override your rights. Sometimes we ask for your consent.
Where the European Union or United Kingdom General Data Protection Regulation or a comparable law applies, we rely on the following legal bases:
- Performance of a contract — to provide the Platform under the Terms of Use, to register, value, and license your work, to perform Custodial Services under your Authorization, and to pay you.
- Legal obligation — to meet tax, accounting, sanctions, anti-money-laundering, and record-keeping requirements, and to respond to lawful requests.
- Legitimate interests — to keep a continuous and trustworthy registry and Ledger, to monitor for unauthorized use of registered work, to publish Culture Market Data as commentary on the cultural economy, to secure the Platform and prevent fraud, and to improve our services. We balance these interests against your rights and do not rely on them where your interests override ours.
- Consent — for optional marketing communications, SMS messages, non-essential cookies, and any processing of Sensitive Personal Information that requires it. You may withdraw consent at any time without affecting processing that took place before withdrawal.
Section 06Agentic Operations and Artificial Intelligence
AI agents help run the platform. They read what you type or say, draft, score and monitor. A person stays in the loop for anything involving money, legal action, or permanent records. Scores are ratings, not decisions about you.
6.1What Agents Process
To carry out your instructions, Agents process the prompts you type, voice recordings you make and their transcripts, the Creative Property and metadata you submit, your account and $Ticker context, and relevant Platform records. Agents may also process information from public sources to monitor for uses of registered work and to produce Culture Market Data.
6.2Voice Data
When you dictate by voice, your audio is transmitted to a speech-recognition Service Provider, transcribed, and used to perform your instruction. We do not use voice recordings to create a voiceprint or otherwise identify you biometrically. We retain raw audio only as long as needed to complete and quality-check the transcription, as stated in Section 15, and retain the transcript with your Agent history.
6.3Model Providers
Agents rely on large language models and recognition engines operated by third-party Service Providers. We share with them only what is needed to complete the task, under contracts that restrict their use of the information to providing services to us. We configure these services so that your prompts, voice data, and Creative Property are not used by the provider to train its general-purpose models.
6.4Improving Our Own Systems
We may review prompts, transcripts, Agent outputs, and your feedback on them to evaluate accuracy, investigate errors and abuse, and improve our own Agents and scoring. Where practicable we use de-identified or aggregated data for this purpose. We do not use Creative Property you have given a Confidential Designation to improve our systems except to the extent necessary to provide the service to you.
6.5Scoring and Automated Decisions
CPRS Scores, tiers, and valuation outputs are ratings of Creative Property, computed under a published methodology and reviewed as the CPRS provides. They are not assessments of your creditworthiness, character, or eligibility for employment, housing, credit, insurance, or any government benefit. We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing. Actions that could — including payments, liens, enforcement notices, license execution, revocation of a BCID or $Ticker, and irreversible on-chain commitments — require the human checkpoints in Section 7.3 of the Terms of Use. You may ask for human review of any score or automated finding that concerns you (Section 17).
Section 07What Is Public by Design
A registry only works if people can see it. Your $Ticker, your registered works, their scores and your profile page are public so that Buyers can find, license and credit you. Deal terms, evidence and payment details are not. You control some of this, and we tell you what you control.
7.1Public by Default
Unless you make a Confidential Designation where the Platform offers one, the following are visible to anyone:
- your $Ticker, display name, and the profile information you choose to publish at made.cx/@TICKER;
- the title, description, category, registration date, BCID, and verification level of each registered work, and any preview you choose to publish;
- CPRS Scores, tiers, and index-point movements for your registered works and $Ticker, including in MARKET, the market tape, and Platform-generated captions and tiles;
- licensing options and band prices you make available to Buyers;
- the Attribution Line on licensed uses, which names you as originator; and
- Ledger entries recording that registration or commercial activity occurred, subject to the privacy rule in Section 8.
7.2Never Public
We do not publish: license prices actually paid, negotiated terms, or negotiation records; provenance and authority evidence; payment, payout, tax, and identity-verification information; the content of Agent conversations and voice recordings; lien consultation details; Council submissions (except determinations published in redacted form under the Terms of Use); or Creative Property and Valuation Data you have designated confidential.
7.3Buyers
Buyer $Tickers are allocated in a distinct namespace class, and public disclosure of a Buyer $Ticker is off by default. A Buyer’s identity is disclosed to the Culture Maker whose work it seeks to license so that the Culture Maker can review the request, and appears in the Buyer’s own Public Use Log. Ledger entries recording that a use occurred do not name the using party.
7.4Your Controls
You can edit your public profile, choose what previews to publish, and make Confidential Designations for asset-level Valuation Data through your dashboard. A Confidential Designation replaces asset-level data with aggregated or anonymized data in public views. It does not remove the fact of registration from the Ledger, and it does not reach information already anchored or already shared by others before the designation was made.
Section 08The Ledger Privacy Rule
The Ledger proves that culture commerce happened without exposing the private details of any deal. It shows participation, not prices. It does not name who used a work. Volumes only appear when there are enough entries that no one can be singled out.
The Cultural Property Ledger is built to show that participation in cultural commerce occurred while protecting the people and deals behind it. The following rules apply to every public Ledger view:
- Participation, not terms. Entries record that a registration, license, use, contribution, or enforcement event occurred. Prices, license terms, counterparties’ private information, and negotiation records are not published.
- Using parties are not named. Entries recording that a use of Creative Property occurred do not identify the party that used it.
- Minimum thresholds for volume. Volume information is published only in bands, and only where the relevant window contains a minimum number of entries from a minimum number of distinct $Tickers, so that no individual transaction can be inferred from a published figure. The threshold is set in the Cultural Property Rights Standard and may be raised as the Ledger grows.
- Timing controls. Where the Platform offers it, you may elect to coarsen the published time of an entry you recorded — for example, to the week or month — so that a transaction cannot be matched to a public event.
- Evidence stays private. When a Cultural Moderator verifies a claimed contribution, the verification level is published; the evidence behind it is not.
- Corrections are appended. Entries are corrected by a later correction entry rather than deleted, so that the record stays continuous (Section 9).
8.1Receipts and Non-User Participants
A contributor, including someone who does not hold a Platform account, may request a Receipt evidencing participation in a recorded work or transaction. To issue a Receipt or publish a non-user’s entry, we collect the information needed to confirm identity and role, and publish only the participation details the Receipt shows. Receipts use participation language and do not disclose deal terms.
8.2Research Use
The Ledger is a destination for data on direct and indirect contributions to cultural commerce. We and the CX Foundation may use Ledger data in aggregated or de-identified form for research, reporting, and policy work on cultural equity. We do not disclose Personal Information from non-public Ledger fields for these purposes without your consent.
Section 09Blockchain, Distributed Storage and Permanence
Some records are written to a public blockchain so that anyone can verify them later. We only write fingerprints and minimal details there — never your files, never your payment details. Once written, those fingerprints cannot be erased, only marked as revoked.
9.1What We Anchor
When we issue a BCID, anchor a Receipt, or anchor certain Ledger events, we write a cryptographic hash and minimal metadata — such as a BCID, a $Ticker, a timestamp, and an event type — to a public blockchain. We do not write the content of Creative Property, contact details, evidence, payment information, or deal terms on-chain. We design anchored metadata so that, standing alone, it does not directly identify a private individual; however, a $Ticker is by design a public identifier, and anchored records associated with it can be linked to the public profile.
9.2Distributed Storage
Copies of files and metadata you choose to publish may be stored on distributed, content-addressed storage networks through pinning Service Providers. Content on those networks may be copied by nodes we do not control. Files you designate confidential are not pinned to public networks.
9.3Limits on Deletion
Records written to a public blockchain are permanent and publicly readable, and we cannot alter or delete them. When you exercise a right to deletion, we delete or de-identify the corresponding off-chain records to the extent the law permits, unpin content we control, and append an on-chain or Ledger entry marking the record as withdrawn or revoked. Because the anchored hash cannot by itself be reversed into the underlying content, deleting the off-chain record severs the link between the permanent hash and the information it once described. We will tell you before you take an action that creates a permanent on-chain record.
Section 10Payments and Identity Verification
Stripe handles the money and the identity checks. You give your bank details, tax ID and ID documents to Stripe, not to us. We see whether your account is verified and the status of your payouts — enough to pay you and answer questions.
10.1Our Payment Provider
Payments, payouts, and related identity verification on the Platform are handled by Stripe, Inc. and its affiliates (“Stripe”) through Stripe Connect. To receive license proceeds, a Culture Maker completes Stripe’s onboarding, in which Stripe collects and verifies information such as legal name, date of birth, address, Social Security or tax identification number, bank account details, and identity documents, and screens that information against sanctions lists. Buyers enter payment-card details on Stripe-hosted forms. That information is collected by Stripe as an independent controller under the Stripe Privacy Policy and Stripe Services Agreement, which you should review.
10.2What We Receive and Keep
We do not receive or store full card numbers, full bank account numbers, Social Security numbers, or identity documents collected by Stripe. We receive and keep: your Stripe account identifier and verification status; payout schedule and status; the last four digits and type of linked accounts or cards; amounts charged, split, refunded, disputed, and distributed; fees under the 80 / 16 / 4 split; and notices of holds, reserves, and reviews. We use this information to pay you, to show your distribution statements, to reconcile fees, to handle disputes, and to meet our legal obligations.
10.3Tax Reporting
Where required, Stripe generates and files tax information returns (for example, Form 1099-K in the United States) for Culture Makers who meet the reporting threshold, using the information collected during onboarding. We may receive confirmation that such forms were issued.
10.4Holds and Reviews
Stripe may hold funds, impose reserves, or restrict an account at its discretion, including to verify identity or review a transaction. When that happens we receive notice of the action and its general reason so that we can help you respond; we do not control Stripe’s decisions and cannot see the underlying verification records.
10.5Other Payment Methods
If you choose to send or receive a tip or donation through a third-party peer-to-peer service that is not integrated through Stripe, that service processes the payment under its own privacy policy, and we receive only the information you or the service share with us.
Section 11How We Share Information
We share information with the companies that help us run the platform, with the people on the other side of a license or dispute you are part of, with our reviewers and Council, and when the law requires it. We do not sell your personal information, and we do not share it for targeted advertising.
We disclose Personal Information only as described below:
| Recipient | What and why |
|---|---|
| Service Providers | Cloud hosting, database and authentication, website hosting and performance monitoring, email and SMS delivery, AI model and speech-recognition providers, content-recognition engines, blockchain and pinning infrastructure, analytics, and customer support tools — each only to perform services for us, under contract |
| Stripe | Information needed to process payments, onboard payout accounts, verify identity, and handle disputes (Section 10) |
| Other Users in a transaction | When a Buyer requests a license, the Culture Maker sees the Buyer’s identity and intended use; the Buyer sees the originator’s public profile and license terms; both see the executed license. Co-registrants and estate representatives see the registrations they share |
| Enforcement counterparties | When you authorize Custodial Services or a lien, the party using your work receives a notice identifying the registered work, its BCID, and the originator as necessary to assert your rights |
| Cultural Moderators and the Council | Registrations, evidence, and submissions needed to verify contributions, review heritage claims, and resolve disputes, under confidentiality obligations |
| CX Foundation | Aggregated or de-identified community reinvestment and Ledger data; identifiable information only with your consent or as needed to administer a program you join |
| Professional advisers | Lawyers, accountants, auditors, and insurers, under duties of confidentiality |
| Legal and safety | Courts, regulators, law enforcement, and others where we believe in good faith that disclosure is required by law or legal process, or necessary to protect the rights, property, or safety of MADE CX, our Users, or the public. Where lawful, we will notify you of a request for your information |
| Corporate transactions | A buyer, successor, or financing party in a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy’s protections; we will notify you before your information becomes subject to a different policy |
| With your direction | Anyone you ask us to share with, including when you use share tools to post captions, tiles, or profile links |
MADE CX does not sell Personal Information for money or other valuable consideration and does not share Personal Information with third parties for cross-context behavioral advertising. We have not done so in the preceding twelve months.
Section 12Culture Market Data and Public Sources
We report on the cultural economy, sometimes about people and work not registered with us, using public sources. If we have written about you, you can ask us to correct it, claim the work, or remove the tile.
12.1What We Collect from Public Sources
To produce Culture Market Data and to monitor for uses of registered work, our Agents collect publicly available information from news outlets, social platforms, commerce listings, and audio and visual streams. This may include the names, public roles, public statements, and publicly reported activities of artists, public figures, brands, and organizations. We collect this information in compliance with the terms of the sources and applicable law, and we do not collect information from private accounts, closed groups, or behind access controls.
12.2How We Use It
We use public-source information to produce commentary and analysis on the cultural economy, including MARKET tiles and captions that identify their source; to compute Scores and indices; to identify possible unauthorized uses of registered work for review; and to invite the people behind culturally significant work to register it. Monitoring findings are indications, not determinations, and no enforcement follows without the human checkpoints described in Section 6.5.
12.3If You Are the Subject
If you appear in Culture Market Data, you may contact us at the address in Section 23 to correct an inaccuracy, to claim and register the underlying Creative Property, to object to the processing, or to ask us to remove a tile. We review requests in good faith, act where content is inaccurate, unlawful, or outside the Cultural Property Rights Standard, and may decline to remove accurate commentary on matters of public interest where the law allows.
Section 13Cookies and Similar Technologies
We use a small number of cookies and browser storage to keep you signed in, remember your settings, and see how the platform performs. We do not use advertising trackers. We honor Global Privacy Control signals.
| Type | Purpose | Choice |
|---|---|---|
| Strictly necessary | Authentication and session tokens, security and fraud prevention, load balancing, remembering consent choices | Required for the Platform to work |
| Preferences | Remembering your theme, open tabs, filters, and unsent drafts in your own browser | You may clear them in your browser at any time |
| Performance and analytics | Measuring page load, errors, and feature use, including through our website-hosting provider’s performance monitoring | Configurable in your browser; where required, set only with consent |
We do not use third-party advertising cookies, cross-site tracking pixels, or similar technologies to track you across other websites. Fonts and certain scripts are loaded from third-party content-delivery networks, which receive your IP address and browser information when your browser requests them.
Browser signals. We treat a Global Privacy Control signal from your browser as a valid request to opt out of any sale or sharing of Personal Information and of any targeted advertising for that browser, as required by applicable law. Because industry standards for “Do Not Track” signals are not uniform, we do not otherwise respond to them.
Section 14Communications
We will email you about your account, your works and your money. Anything promotional is optional. Texts are opt-in, and you can stop them by replying STOP.
14.1Service Communications
We send service communications to the email address on your account, including notices under the Terms of Use, security alerts, verification requests, Council notices, enforcement reports, distribution statements, and changes to this Policy. These are part of the service and you cannot opt out of them while your account is open.
14.2Updates and Invitations
With your permission, or where the law otherwise allows, we may send news about MADE CX, invitations to events and exhibitions, and editorial content. Every such message includes an unsubscribe link, and you may also change your preferences in your dashboard.
14.3Text Messages
If you provide a mobile number and opt in, we may send transactional and account messages by SMS. Message frequency varies; message and data rates may apply. Reply STOP to opt out and HELP for help. We do not share mobile numbers or SMS opt-in consent with third parties for their own marketing purposes, and consent to SMS is not a condition of using the Platform.
14.4Email Measurement
Our emails may contain technologies that tell us whether a message was opened or a link was clicked, which we use to understand whether our communications are reaching you. You can limit this by disabling automatic image loading in your email client.
Section 15Data Retention
We keep information as long as it is needed for the reason we collected it, for as long as the registry and your licenses depend on it, and as long as the law requires. Then we delete it or make it anonymous.
We retain Personal Information for as long as necessary to fulfill the purposes described in this Policy, including to maintain the integrity of the registry and Ledger, to administer licenses for their terms, to resolve disputes, and to comply with legal obligations. Our standard periods are:
| Information | Retention |
|---|---|
| Account and profile | While your account is open, and up to 90 days after closure to allow reactivation and complete wind-down |
| Registrations and BCID records | For the life of the registration and thereafter as needed to preserve registry integrity; on deletion, de-identified off-chain and marked withdrawn on-chain (Section 9) |
| Provenance and authority evidence | For the life of the registration plus any period in which a dispute concerning it could be brought |
| Licenses and commercial records | For the term of the license plus seven (7) years |
| Payment, fee, and distribution records | Seven (7) years from the transaction, to meet tax and accounting obligations |
| Ledger entries | Indefinitely as part of the public record, under the privacy rule; identifying off-chain fields de-identified on a valid deletion request |
| Raw voice recordings | Up to thirty (30) days after transcription |
| Prompts, transcripts, and Agent history | While your account is open, or until you delete them, subject to records needed for disputes or safety investigations |
| Consultation and waitlist submissions | Up to two (2) years if no service results; otherwise as part of the related service record |
| Security and access logs | Up to twelve (12) months, longer where needed to investigate an incident |
| Marketing preferences and suppression lists | As long as needed to honor your choices |
We may retain information longer where required by law, to comply with a legal hold, to resolve a dispute or Council matter, or to enforce our agreements. Backups are overwritten on a rolling schedule.
Section 16Security
We protect your information with technical and organizational safeguards and limit who can see it. No system is perfectly secure. If something goes wrong that affects you, we will tell you as the law requires.
We maintain administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, loss, misuse, alteration, and destruction, appropriate to the nature of the information and the risks of processing. These include encryption of data in transit, encryption at rest through our infrastructure providers, role-based access controls and row-level security on our databases, least-privilege access for personnel and Moderators, logging and monitoring of access to sensitive records, vendor security review, and confidentiality obligations for everyone who handles Personal Information.
You are responsible for keeping your credentials confidential and for the instructions you give Agents. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a security incident that affects your Personal Information, we will notify you and the appropriate authorities as required by applicable law.
Section 17Your Rights and Choices
You can see what we hold about you, fix it, take a copy, ask us to delete it, and object to some uses. We will not treat you worse for asking. Some rights have limits — mostly because the public record and your licenses depend on the data.
17.1Rights Available to You
Depending on where you live, and subject to the exceptions the law allows, you may have the right to:
- Know and access — confirm whether we process your Personal Information and obtain a copy of it, together with information about how we process it;
- Correct — have inaccurate Personal Information corrected;
- Delete — have Personal Information deleted, subject to Sections 9 and 15;
- Portability — receive Personal Information you provided in a structured, commonly used, machine-readable format;
- Object or restrict — object to, or ask us to restrict, processing based on legitimate interests, including publication of Culture Market Data about you;
- Opt out — of any sale, sharing for targeted advertising, or profiling that produces legal or similarly significant effects (we do not engage in these, but you may still submit the request);
- Human review — ask a person to review a score, verification finding, or automated finding that concerns you;
- Withdraw consent — where processing is based on consent; and
- Appeal — ask us to reconsider if we decline your request (Section 17.4).
17.2How to Exercise Your Rights
You may submit a request through your dashboard or by email to privacy@made.cx. We will verify your identity before acting, generally by confirming control of the email address of record and, for sensitive requests, additional information that matches our records. We will not ask you to create an account to make a request. An authorized agent may submit a request on your behalf with your signed permission; we may ask you to confirm your identity directly. We respond within the time the law requires — generally within forty-five (45) days, which may be extended once where permitted, with notice.
17.3Limits Tied to the Public Record
Deleting your account does not erase Ledger entries or anchored records; it de-identifies the off-chain information linked to them and marks registrations withdrawn. We may also decline or limit a request where the information is needed to complete a transaction, administer a license still in force, pay out proceeds, resolve a dispute or Council matter, meet a legal obligation, protect against fraud, or exercise or defend legal claims. Where a request affects another person’s rights — for example, a co-creator’s registration or a Buyer’s license — we may need to balance both. We will tell you what we did and did not do, and why.
17.4Appeals and Complaints
If we decline your request, you may appeal by replying to our decision or writing to privacy@made.cx with the subject line “Privacy Appeal.” A person not involved in the original decision will review it and respond in writing within the time the law requires. If you are not satisfied, you may contact your state attorney general or, where applicable, your data protection authority.
17.5Non-Discrimination
We will not deny you service, charge you a different price, or provide a different quality of service because you exercised a privacy right.
Section 18U.S. State Privacy Rights
A growing number of states — including California and Maryland — give residents specific privacy rights. This section is the notice those laws ask for. The rights themselves are in Section 17.
18.1Applicable Laws
This Section supplements the Policy for residents of states with comprehensive consumer privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Maryland Online Data Privacy Act, and the comparable laws of Colorado, Connecticut, Virginia, and other states, to the extent they apply to MADE CX. Where these laws apply, you may exercise the rights in Section 17 in the manner described there.
18.2Notice at Collection
In the preceding twelve months we have collected the following categories of Personal Information, from the sources and for the purposes described in Sections 3 and 4, and disclosed them for business purposes to the categories of recipients described in Section 11:
| Statutory category | Examples | Disclosed to |
|---|---|---|
| Identifiers | Name, email, phone, $Ticker, account ID, IP address | Service Providers; Stripe; transaction counterparties; Moderators and Council |
| Customer records | Contact and organization details; last four digits of payout accounts | Service Providers; Stripe |
| Commercial information | Registrations, valuations, licenses, fees, distributions | Service Providers; Stripe; transaction counterparties |
| Internet or network activity | Pages viewed, searches, feature use, logs | Service Providers |
| Audio and visual information | Voice recordings; Creative Property containing likeness or voice | Service Providers; public where you publish it |
| Professional information | Role, organization, creative credits | Service Providers; transaction counterparties |
| Inferences | CPRS Scores and tiers of Creative Property associated with your $Ticker | Public, unless designated confidential |
| Sensitive Personal Information | Account login credentials; cultural-origin statements that may reveal ethnic origin or religious affiliation | Service Providers; Moderators and Council |
Government identifiers and full financial account information needed for payouts are collected directly by Stripe (Section 10), not by MADE CX. We use and disclose Sensitive Personal Information only for the purposes permitted by law — to provide the services you request, to secure the Platform, and to verify provenance — and not to infer characteristics about you. Retention periods are set out in Section 15.
18.3Maryland Residents
Consistent with the Maryland Online Data Privacy Act, we limit collection of Personal Information to what is reasonably necessary and proportionate to provide the services you request, collect and process Sensitive Personal Information only where strictly necessary to provide or maintain a service you requested, and do not sell Sensitive Personal Information.
18.4California Residents
California residents may request, once per year and free of charge, information about any disclosure of Personal Information to third parties for their own direct marketing purposes under California Civil Code § 1798.83. We do not make such disclosures. We do not use or disclose Sensitive Personal Information for purposes that would give rise to a right to limit under California law.
18.5Nevada Residents
We do not sell covered information as defined under Nevada law. Nevada residents may nevertheless submit an opt-out request to privacy@made.cx.
Section 19International Users and Data Transfers
We are based in the United States and store data here. If you use the platform from elsewhere, your information comes to the U.S., and we protect it with recognized safeguards.
MADE CX is operated from the United States, and our Service Providers may process information in the United States and other countries. If you access the Platform from outside the United States, your Personal Information will be transferred to, stored, and processed in countries whose data protection laws may differ from those of your country.
Where we transfer Personal Information from the European Economic Area, the United Kingdom, or Switzerland, we rely on an adequacy decision where one applies or on the Standard Contractual Clauses approved by the European Commission (with the UK Addendum where relevant), together with supplementary measures appropriate to the transfer. You may request a copy of the relevant safeguards by contacting us.
If you are in the EEA, the UK, or Switzerland, you may also lodge a complaint with your local supervisory authority. Where partnerships with organizations in other countries involve local recognition of CPRS registrations, any additional privacy terms are set out in the Supplemental Terms for that program.
Section 20Estates, Heritage and Communities
Culture outlives its makers and belongs to communities as well as individuals. We handle information about people who have passed, their heirs, and communities with care, and we only act for them through people with proven authority.
20.1Deceased Creators
Registrations of works by a deceased creator may include that person’s name, likeness, voice, biography, and creative history. We accept such registrations only from a representative who demonstrates authority under Section 3.4 of the Terms of Use, process the information to record provenance and administer the estate’s rights, and honor lawful requests from the estate’s authorized representative regarding it.
20.2Heirs and Representatives
We collect information about executors, administrators, heirs, and other representatives only as needed to verify authority, administer registrations and distributions, and communicate about the estate’s works. Proof-of-authority documents are treated as provenance evidence under Section 7.2 and are never published.
20.3Community and Lineage Claims
Where a registration involves community-authored aesthetics, lineage, or heritage, the Council may consult community or subject-matter advisors. We share with advisors only what is needed for the review, under confidentiality obligations, and publish Council determinations only in redacted form.
Section 21Children
The platform is for adults. We do not knowingly collect information from children, and if we find we have, we delete it.
The Platform is intended for individuals who are at least eighteen (18) years of age, or the age of majority in their jurisdiction if higher. We do not knowingly collect Personal Information from children under thirteen (13), or from anyone under eighteen (18) in a manner that requires parental consent or that would constitute a sale or targeted advertising. If we learn that we have collected such information, we will delete it promptly. A parent or guardian who believes a child has provided us information may contact us at the address in Section 23.
Creative Property registered by an adult may depict or involve a minor, such as a family photograph or a young performer. A registrant who submits such work represents that they are the minor’s parent or legal guardian or have that person’s written consent, and we will act promptly on a guardian’s request to restrict public display of a minor’s likeness.
Section 22Changes to This Policy
If we change this policy in a way that matters, we will tell you before it takes effect.
We may update this Policy from time to time to reflect changes in our services, our practices, or the law. When we make material changes, we will give at least thirty (30) days’ notice by email to the address on your account or by prominent notice on the Platform before the changes take effect, and where the law requires, we will ask for your consent. The “Effective” date at the top of this Policy shows when it was last revised. We will not apply a material change retroactively to Personal Information collected before the change without your consent. Prior versions are available on request.
Section 23Contact
Here is how to reach us about your privacy.
23.1Privacy Inquiries and Requests
MADE CX Inc.
Attn: Privacy
Los Angeles, California, United States
Email: privacy@made.cx
Privacy requests and appeals: privacy@made.cx, subject line “Privacy Request” or “Privacy Appeal”
Legal notices: legal@made.cx
23.2Related Documents
This Policy is incorporated into and forms part of the Terms of Use. The Ledger privacy rule is set out in full in the Cultural Property Rights Standard (Appendix A to the Terms of Use).
PP-001 · Effective September 28, 2026 · Incorporated by reference into TOU-002 · Prior versions available on request.