NIGHT SCENE PRIVACY POLICY FOR CLUBS

Effective Date: 25 September 2026
Last Updated: 25 September 2026

This Privacy Policy explains how WMP LLC, doing business as Night Scene (“Night Scene,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects personal information relating to clubs, bars, venues, promoters, and their representatives.

Night Scene operates from Puerto Rico and provides a social discovery platform through which nightlife businesses can create profiles, publish events, communicate with users, and promote their venues.

This Privacy Policy is intended to comply with applicable Puerto Rico and United States federal privacy requirements, including Puerto Rico Act No. 39 of January 24, 2012, as amended, and applicable data-security and breach-notification requirements.

Night Scene maintains a zero-tolerance policy regarding Child Sexual Abuse and Exploitation (“CSAE”) and Child Sexual Abuse Material (“CSAM”). This Privacy Policy explains how Night Scene may process personal information when preventing, detecting, investigating, reporting, and responding to suspected child endangerment.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information we collect from or about:

Individuals who apply for a Club Account.
Club owners, directors, managers, employees, contractors, promoters, and authorized representatives.
Individuals who administer or use a Club Account.
Individuals who communicate with Night Scene on behalf of a Club.
Individuals participating in Night Scene’s Club referral, trial, subscription, advertising, or promotional programs.
Visitors to Night Scene’s Club-facing websites, applications, and services.
Individuals who submit, are identified in, or are otherwise connected with a safety or child-endangerment report involving a Club Account.

In this Privacy Policy, “Club” includes a nightclub, bar, lounge, entertainment venue, event venue, promoter, event organizer, or other nightlife business using Night Scene.

This Privacy Policy does not govern how an independent Club collects or uses personal information outside Night Scene. Each Club is independently responsible for its own privacy practices.

A separate user privacy policy may apply to individuals using Night Scene to discover Clubs and events.

2. Who Is Responsible for Your Information?

The organization responsible for the personal information described in this Privacy Policy is:

WMP LLC
Doing business as Night Scene
954 Avenida Ponce de León, Miramar Plaza
Suite 205-PMB# 10164
San Juan, Puerto Rico 00907

Privacy Email: nightscene@altcircleapps.com

Night Scene determines how and why the personal information covered by this Privacy Policy is processed.

3. Personal Information We Collect

The information we collect depends on how you interact with Night Scene, the features you use, and the information you choose to provide.

3.1 Account and Identity Information

When you apply for, create, or manage a Club Account, we may collect:

Your full name.
Email address.
Telephone number.
Username.
Password or other authentication credentials.
Job title or position.
Profile photograph.
Preferred language.
Account settings.
Communication preferences.
Information confirming your relationship with the Club.
Information used to verify your identity or authority.
Information used to confirm that an individual is eligible to create, administer, or access a Club Account, including age-related eligibility information where appropriate.

Passwords should be stored in a protected form rather than as readable text.

3.2 Club and Business Information

We may collect information about the Club you represent, including:

Legal business name.
Trading name.
Business address.
Venue location.
Email address.
Telephone number.
Website address.
Social media accounts.
Business description.
Operating hours.
Club category or venue type.
Age restrictions.
Admission information.
Accessibility information.
Logo, profile image, and cover image.
Business registration details.
Permit or license information.
Alcoholic beverage license information.
Tax information.
Information about owners or authorized representatives.
Documentation used to verify the Club.
Information about the Club’s age-verification, admission, supervision, or safeguarding requirements when relevant to an event or safety investigation.

Some Club information is business information rather than personal information. However, it may be treated as personal information when it identifies an individual, such as a sole proprietor, owner, employee, or representative.

3.3 Event and Content Information

When you publish or manage content through Night Scene, we may collect:

Event names and descriptions.
Event dates and times.
Venue and location information.
Admission prices.
Ticket or reservation links.
Age restrictions.
Dress codes.
Performer, promoter, host, and sponsor information.
Photographs.
Videos.
Audio.
Captions.
Hashtags.
Comments.
Replies.
Likes and other reactions.
Group information.
Other content submitted through the Club Account.
Information concerning whether an event permits minors and any related accompaniment, supervision, admission, identification, or age-verification requirements.

Club profiles, event posts, photographs, videos, comments, and other content intended for publication may be visible to Night Scene users and, depending on the applicable settings, members of the public.

You should not publish private or sensitive personal information unless you have a lawful reason and all necessary permissions to do so.

You must not publish personal information that identifies, locates, targets, or otherwise creates a safety risk for a minor. You must also obtain all permissions required by law before publishing content that identifies or depicts a minor. Permission from a parent or legal guardian does not authorize content that exploits, abuses, endangers, or inappropriately sexualizes a minor.

3.4 Messages and Communications

We may collect communications sent through Night Scene, including:

Direct messages.
Club and user conversations.
Message requests.
Customer-support requests.
Reports and complaints.
Appeals.
Emails sent to Night Scene.
Responses to surveys.
Communications relating to account verification.
Records of consent or policy acceptance.
Reports concerning suspected CSAE, CSAM, grooming, sextortion, child trafficking, predatory behavior, or other child endangerment.
Information provided in connection with child-safety investigations, including the identities of reporting persons, reported persons, affected persons, witnesses, and relevant Club representatives.
Information needed to identify reported content, accounts, events, messages, comments, or interactions.

We may access or review communications when reasonably necessary to provide the messaging service, investigate a report, prevent fraud or abuse, enforce our policies, protect users, or comply with law.

Night Scene does not guarantee that every private communication will be manually reviewed.

Child-safety reports may contain sensitive information. Do not download, copy, screenshot, forward, attach, upload, or otherwise reproduce suspected CSAM when submitting a report. Reports should provide only the information needed to identify where the material or activity appears so that Night Scene can review it safely.

3.5 Referral Information

If you participate in a Night Scene referral program, we may collect:

Your referral code or link.
The identity of the referring or referred Club.
Referral status.
Registration and trial status.
Subscription or qualifying-payment status.
Reward amount.
Payment status.
Referral communications.
Information used to identify duplicate, invalid, or fraudulent referrals.
Tax or payment information required to issue a reward.

When you share a referral link with another person, you are responsible for doing so lawfully and respecting that person’s communication preferences.

3.6 Subscription, Billing, and Payment Information

If Night Scene offers paid Club services or referral payments, we may collect:

Billing name and address.
Subscription plan.
Trial status.
Payment amount.
Transaction date.
Payment status.
Payment-method type.
Limited payment-card details, such as the card brand and final digits.
Invoices and receipts.
Refunds.
Cancellations.
Chargebacks.
Payout information.
Tax-related information.

Payment-card information may be collected and processed directly by a third-party payment provider. Night Scene should not receive or store complete card numbers or security codes unless expressly required and supported by appropriate payment-security controls.

The payment provider’s privacy policy also applies to the information it processes.

3.7 Location Information

Night Scene uses location information to display Clubs and events on maps and help users discover nearby venues.

We may collect:

The Club’s street address.
Map coordinates.
Event locations.
Approximate location derived from an IP address.
Device location, if you authorize Night Scene to access it.
Location information included in posts, photographs, or uploaded files.

A Club’s venue and event locations may be displayed publicly.

You can control device-level location access through your device settings. Disabling location access may affect certain Night Scene features.

Clubs must not use location information obtained through Night Scene to locate, track, target, contact, or facilitate access to a minor for an unauthorized, exploitative, predatory, or otherwise harmful purpose.

3.8 Device, Log, and Usage Information

When you use Night Scene, we and our service providers may automatically collect:

IP address.
Device type.
Device identifiers.
Operating system.
Browser type.
Application version.
Language settings.
Mobile network information.
Login dates and times.
Pages and screens viewed.
Features used.
Search activity.
Posts viewed or selected.
Links clicked.
Referring pages.
Session duration.
Crash reports.
Error logs.
Security events.
Approximate location derived from technical information.
Records relating to the use of reporting, blocking, moderation, age-control, and other safety features.
Technical information that may help identify, investigate, prevent, or document suspected child endangerment or policy violations.

We use this information to operate, secure, analyze, troubleshoot, and improve Night Scene.

3.9 Social Sign-In Information

If you register or sign in using Google or another third-party account, we may receive information authorized by you and provided by that service.

Depending on your settings and permissions, this may include:

Your name.
Email address.
Profile photograph.
Account identifier.
Authentication confirmation.

Night Scene does not receive the password for your third-party account.

Your use of a third-party sign-in service is also governed by that provider’s terms and privacy policy.

3.10 Information from Other Sources

We may receive information from:

Other Club owners or authorized representatives.
Night Scene users.
Referral participants.
Payment processors.
Identity or business-verification providers.
Social sign-in providers.
Public business registries.
Public websites and social media accounts.
Mapping and location providers.
Fraud-prevention and security providers.
Governmental or regulatory authorities.
Business partners.
Parents, legal guardians, witnesses, reporting persons, child-safety organizations, law-enforcement agencies, and other persons or organizations reporting or investigating a potential safety concern.

We may combine this information with information collected directly through Night Scene.

3.11 Child-Safety Reports and Investigation Information

When Night Scene receives or investigates a child-safety report, we may collect and process:

The reporting person’s name, contact information, account details, and relationship to the incident.
Information identifying the affected or potentially affected child, when provided and reasonably necessary.
Information identifying the reported account, Club, event, post, message, comment, or other content.
The date, time, location, and nature of the reported conduct.
Communications, account activity, device information, log information, and technical records relevant to the report.
Information supplied by the Club, witnesses, parents, legal guardians, service providers, governmental authorities, law-enforcement agencies, or child-safety organizations.
Records of Night Scene’s review, findings, actions, reports, referrals, and communications.
Information required to preserve evidence, prevent further harm, comply with law, or respond to a competent authority.

Night Scene seeks to limit the collection and use of this information to what is reasonably necessary for safety, enforcement, legal compliance, and related purposes.

4. How We Use Personal Information

We may use personal information as described below.

4.1 Provide and Operate Night Scene

This includes using information to:

Create and administer Club Accounts.
Verify Club applications and authorized representatives.
Authenticate account users.
Display Club profiles and event listings.
Provide search, feed, map, follow, comment, group, and messaging features.
Process subscriptions, trials, payments, refunds, and referral rewards.
Deliver notifications.
Provide customer support.
Maintain account settings and preferences.
Provide reporting, blocking, age-control, moderation, and other safety features.

4.2 Personalize and Improve the Platform

We may use information to:

Recommend Clubs and events.
Determine which content appears in feeds or search results.
Personalize the Club’s experience.
Understand how features are used.
Measure platform performance.
Develop and test new features.
Diagnose errors and technical problems.
Improve accessibility, reliability, and usability.
Evaluate and improve safety, reporting, moderation, and child-protection systems.

4.3 Communicate with Clubs

We may use contact information to send:

Account notices.
Verification requests.
Security alerts.
Service announcements.
Event or content notifications.
Billing and subscription communications.
Referral updates.
Policy updates.
Responses to support requests.
Marketing communications where permitted.
Safety warnings, requests for information, investigation notices, enforcement notices, and communications concerning a child-safety report.

You may opt out of promotional emails by using the unsubscribe link provided in the message. You may still receive nonpromotional communications necessary to administer the Club Account, protect users, investigate safety concerns, or comply with law.

4.4 Maintain Safety and Security

We may use information to:

Verify identities and authority.
Detect unauthorized access.
Prevent fraud, spam, abuse, and manipulation.
Investigate complaints.
Enforce our Terms & Conditions and policies.
Protect Clubs, users, Night Scene, and third parties.
Identify duplicate, fraudulent, or invalid accounts and referrals.
Maintain platform integrity.
Respond to security incidents.
Receive, review, prioritize, and investigate reports involving suspected CSAE, CSAM, grooming, sextortion, child trafficking, predatory behavior, or other child endangerment.
Identify and remove or disable access to content that may sexually exploit, abuse, or endanger a minor.
Restrict interactions, suspend or terminate accounts, and prevent persons responsible for serious child-safety violations from returning to the platform.
Preserve relevant records, protect affected persons, prevent further harm, and support lawful safety investigations.
Detect patterns of abusive or predatory activity involving related accounts, devices, content, or interactions.

4.5 Comply with Legal Obligations

We may process information to:

Comply with Puerto Rico and applicable federal laws.
Respond to subpoenas, court orders, warrants, and lawful governmental requests.
Protect legal rights.
Maintain financial and tax records.
Investigate possible illegal activity.
Respond to copyright complaints.
Establish, exercise, or defend legal claims.
Meet applicable reporting and recordkeeping requirements.
Comply with applicable child-safety, child-protection, evidence-preservation, and mandatory-reporting requirements.
Report confirmed or apparently unlawful CSAM to the National Center for Missing & Exploited Children (“NCMEC”) or another competent regional authority when required by applicable law.
Cooperate with law-enforcement agencies, courts, governmental authorities, and child-protection organizations where legally required or permitted.

4.6 Conduct Business Operations

We may use information for:

Accounting.
Auditing.
Business planning.
Internal reporting.
Insurance.
Corporate governance.
Corporate transactions.
Vendor management.
Legal and regulatory compliance.
Training, auditing, and evaluating personnel and service providers responsible for trust, safety, moderation, and child-protection functions, subject to appropriate confidentiality and access controls.

5. How We Disclose Personal Information

We may disclose personal information as described below.

5.1 To Night Scene Users and the Public

Information published through a Club profile or event post may be visible to users or the public.

This may include:

Club name.
Venue address and map location.
Club description.
Logo and images.
Event information.
Videos.
Website and social links.
Comments and replies.
Followers or other community information, depending on visibility settings.

Information you publish may be copied, captured, downloaded, indexed, or shared by others. Night Scene cannot control information after another person has copied or shared it outside the platform.

Clubs must consider the privacy and safety of minors before publishing information about them. Information that identifies or depicts a minor must not be published without a lawful basis and any required permission, and it must never be published in a manner that exploits, sexualizes, endangers, targets, or facilitates inappropriate access to the minor.

5.2 To Club Account Users

Owners, managers, staff members, contractors, and other authorized users associated with the same Club Account may access account information according to their permissions.

The Club is responsible for determining who should have access and removing access when it is no longer required.

Access to child-safety reports, information relating to minors, and other sensitive safety information must be limited to individuals who require access for legitimate safeguarding, investigative, legal, or operational purposes.

5.3 To Service Providers

We may disclose information to vendors that perform services for Night Scene, including providers of:

Cloud hosting.
Data storage.
Authentication.
Email, SMS, and push notifications.
Payment processing.
Mapping and location services.
Analytics.
Customer support.
Security and fraud prevention.
Business or identity verification.
Content moderation.
Error monitoring.
Legal, accounting, and professional services.
Trust and safety, child-safety review, evidence preservation, abuse detection, reporting, and investigation support.

These providers may process information only for authorized purposes and subject to appropriate contractual or legal obligations.

5.4 To Third-Party Platforms You Choose to Use

If you connect Night Scene to another service, follow a third-party link, use social sign-in, or share Night Scene content externally, information may be disclosed to that third party as directed by you.

The third party’s privacy policy governs its processing of the information.

5.5 For Legal, Safety, and Child-Protection Reasons

We may preserve or disclose personal information when we reasonably believe doing so is necessary or permitted to:

Comply with applicable law.
Respond to legal process.
Cooperate with a governmental or regulatory authority.
Enforce our agreements and policies.
Investigate fraud, infringement, or illegal activity.
Protect the safety, rights, or property of Night Scene, its users, Clubs, or others.
Prevent or respond to a security incident.
Investigate suspected CSAE, CSAM, grooming, sextortion, child trafficking, predatory behavior, or other child endangerment.
Protect a child or another person from possible harm.
Preserve evidence or relevant account, communication, content, device, and technical records.
Report confirmed or apparently unlawful CSAM to NCMEC or another competent authority when required by applicable law.
Cooperate with law-enforcement agencies, courts, child-protection authorities, or child-safety organizations.

Where legally permitted and appropriate, we may notify the affected Club before disclosing information in response to legal process. However, we may withhold notice when notification is prohibited by law, could compromise an investigation, could expose a person to harm, or could interfere with Night Scene’s safety or enforcement measures.

5.6 During a Business Transaction

Information may be disclosed in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction.

A recipient of the information will be required to handle it consistently with applicable law and any commitments that continue to apply.

5.7 With Consent or at Your Direction

We may disclose information for another purpose when you consent to or direct the disclosure.

Consent will not prevent Night Scene from preserving, using, or disclosing information where reasonably necessary to protect a child, investigate suspected child endangerment, or comply with a legal obligation.

6. Sale of Personal Information and Targeted Advertising

Night Scene does not sell personal information for money.

If Night Scene introduces advertising practices that are legally treated as the sale, sharing, or use of personal information for targeted advertising, we will update this Privacy Policy and provide any notices and choices required by applicable law.

Night Scene may use aggregated or deidentified information for analytics, planning, research, and business purposes. We will take reasonable measures intended to prevent deidentified information from being used to identify an individual.

Night Scene does not sell personal information obtained through child-safety reports or information known to relate to a minor for targeted advertising purposes.

7. Cookies and Similar Technologies

Night Scene and its service providers may use:

Cookies.
Software development kits.
Pixels.
Local storage.
Mobile identifiers.
Log files.
Similar technologies.

These technologies may be used to:

Keep you signed in.
Remember settings.
Maintain security.
Understand platform usage.
Diagnose technical problems.
Measure performance.
Improve Night Scene.
Measure communications or campaigns.
Support advertising, if applicable.
Detect, investigate, and prevent harmful, abusive, or predatory activity and enforce Night Scene’s safety policies.

Where required, Night Scene will obtain consent before using nonessential cookies or similar technologies.

You may be able to control certain technologies through browser settings, device settings, or a consent-management tool made available by Night Scene. Blocking certain technologies may affect platform functionality.

8. Analytics

We may use analytics providers to understand how Clubs use Night Scene.

Analytics information may include:

Pages or screens viewed.
Features used.
Session duration.
Device and browser information.
Approximate location.
Referral source.
Interaction and performance data.

Analytics providers may use cookies, device identifiers, or similar technologies according to their own privacy policies and their agreements with Night Scene.

9. Data Retention

We retain personal information for as long as reasonably necessary to:

Provide the Club Account and requested services.
Maintain accurate business and transaction records.
Complete subscription, billing, or referral processes.
Comply with legal, tax, accounting, and regulatory requirements.
Resolve disputes.
Enforce agreements.
Prevent fraud and abuse.
Protect Night Scene, Clubs, users, and third parties.
Investigate safety reports, protect affected persons, prevent repeated child-safety violations, preserve evidence, and comply with applicable child-protection or reporting requirements.

Retention periods depend on the nature of the information and the reason it was collected.

For example:

Account information may be retained while the Club Account remains active.
Published content may remain available until deleted by the Club or Night Scene.
Transaction and tax records may be retained for legally required periods.
Security and fraud-prevention records may be retained when reasonably necessary to prevent repeated abuse.
Messages and support records may be retained for operational, safety, or legal purposes.
Backup copies may remain temporarily after information is deleted from active systems.
Child-safety reports, enforcement records, account identifiers, communications, and relevant technical records may be retained for as long as reasonably necessary to investigate the matter, protect children and other users, prevent repeated violations, cooperate with competent authorities, establish or defend legal claims, and satisfy applicable legal or evidence-preservation requirements.
Information subject to a lawful preservation request, legal hold, safety investigation, or mandatory-reporting obligation may be retained beyond the period that would otherwise apply.

When information is no longer required, we may delete, anonymize, or securely isolate it.

Closing a Club Account does not necessarily result in the immediate deletion of every record.

Night Scene may retain limited information about an account terminated for CSAE, CSAM, grooming, sextortion, child trafficking, or other serious child endangerment to prevent the responsible person or organization from returning to the platform, where permitted by law.

10. Data Security

Night Scene uses reasonable administrative, technical, and physical safeguards intended to protect personal information.

These safeguards may include:

Access controls.
Authentication measures.
Encryption where appropriate.
Monitoring and logging.
Secure software-development practices.
Vendor assessments.
Employee or contractor confidentiality requirements.
Incident-response procedures.
Data backup and recovery controls.
Restricted access to child-safety reports and information concerning minors.
Procedures for escalating, reviewing, preserving, and reporting suspected CSAE or CSAM.
Training or guidance for personnel responsible for reviewing child-safety concerns.

No electronic service or storage system can be guaranteed to be completely secure. Clubs are also responsible for protecting their credentials, devices, and account access.

If a security incident affects personal information, Night Scene will investigate and provide notifications required under applicable law, including applicable Puerto Rico breach-notification requirements.

Suspected security incidents should be reported to nightscene@altcircleapps.com.

11. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have the right to:

Request confirmation that we hold personal information about you.
Request access to your personal information.
Request correction of inaccurate information.
Request deletion of certain information.
Object to or restrict certain processing.
Withdraw consent where processing is based on consent.
Obtain a portable copy of certain information.
Opt out of certain marketing communications.
Opt out of legally defined sales, sharing, or targeted advertising.
Appeal a decision concerning a privacy request.
Submit a complaint to an appropriate authority.

These rights are not absolute. We may decline or limit a request when permitted by law, including when information must be retained for legal compliance, security, fraud prevention, contract administration, or legal claims.

Night Scene may also decline, delay, or limit a request where fulfilling it would interfere with a child-safety investigation, reveal another person’s confidential information, compromise evidence, enable further abuse, endanger a child or another person, conflict with a lawful preservation requirement, or violate applicable law.

Submitting a Request

To submit a privacy request, contact:

nightscene@altcircleapps.com

Your request should identify:

Your name.
The Club you represent.
Your relationship with the Club.
The email address associated with the account.
The right you wish to exercise.

We may need to verify your identity and authority before completing the request. An authorized representative may submit a request where permitted by law, but we may require evidence of that authorization.

Night Scene will not unlawfully discriminate against you for exercising a privacy right.

12. Managing Your Information

You may be able to review or update certain information through the Club Account.

You may also:

Change notification preferences.
Adjust available profile visibility settings.
Update Club information.
Remove or update content.
Disconnect certain third-party integrations.
Control device permissions.
Unsubscribe from promotional emails.
Request account closure.

Deleting content from the Club Account may not delete copies previously shared, captured, or stored by other users. It may also remain temporarily in backups or be retained where required for legal, safety, or fraud-prevention purposes.

Content and information connected with a child-safety report or investigation may be preserved after it is removed from public view or deleted from an account where preservation is reasonably necessary to protect a child, prevent further harm, investigate a violation, comply with law, cooperate with a competent authority, or establish or defend legal claims.

13. Account Closure

You may request closure of a Club Account through nightscene@altcircleapps.com.

Before closing an account, Night Scene may:

Verify the identity and authority of the requester.
Require payment of outstanding amounts.
Address pending complaints or investigations.
Preserve information required by law.
Retain information needed to prevent fraud or repeated policy violations.
Complete or support a pending child-safety investigation.
Preserve information relating to suspected CSAE, CSAM, grooming, sextortion, child trafficking, predatory behavior, or other child endangerment.
Retain limited account and enforcement information needed to prevent a person or organization responsible for a serious child-safety violation from returning to Night Scene.

Closing a Club Account does not automatically cancel the Club’s obligations to users, ticket holders, vendors, performers, promoters, or governmental authorities.

14. International and Cross-Border Processing

Night Scene operates from Puerto Rico. Information may be processed in Puerto Rico, elsewhere in the United States, or in other countries where Night Scene or its service providers operate.

These locations may have privacy laws that differ from those in your location.

Where required, Night Scene will use appropriate legal mechanisms and safeguards for international transfers of personal information.

Child-safety information may be transferred or disclosed across borders when reasonably necessary to investigate a report, protect a child, comply with law, or cooperate with NCMEC, law-enforcement agencies, child-protection authorities, or other competent organizations.

15. Additional Rights in Other Jurisdictions

Although Night Scene operates from Puerto Rico, privacy laws in other jurisdictions may apply when Night Scene offers services to individuals located there.

Where required, Night Scene will provide additional notices or rights to affected individuals.

This may include rights under privacy laws applicable in certain United States states or, if Night Scene intentionally offers services in those locations, the European Economic Area, United Kingdom, or other jurisdictions.

Any jurisdiction-specific privacy notice will supplement this Privacy Policy. If a supplemental notice conflicts with this Privacy Policy, the supplemental notice will control for individuals covered by it.

16. Children, Minors, and Child Safety

Night Scene is a nightlife platform intended for adults. Individuals under 18 years of age may not create, administer, or access a Club Account.

Night Scene does not knowingly permit a person under 18 to create, administer, or access a Club Account. If we learn that an ineligible minor has created or accessed a Club Account, we may restrict or terminate the account and take reasonable steps to delete or otherwise appropriately handle the minor’s personal information, subject to applicable legal, safety, investigative, and preservation requirements.

Although Club Accounts are restricted to adults, information relating to a minor may be processed in limited circumstances, including when:

A minor is lawfully permitted to attend, participate in, perform at, or work in connection with an event.
A Club publishes lawful content that includes a minor and has obtained all permissions required by applicable law.
A parent, legal guardian, Club, user, witness, or authority submits a safety report.
Information about a minor appears in a message, complaint, investigation, or legal request.
Processing is reasonably necessary to protect a child, investigate suspected harm, preserve evidence, or comply with law.

Night Scene strictly prohibits the use of the platform for CSAE, CSAM, grooming, sextortion, child trafficking, predatory behavior, or any other form of child endangerment.

If Night Scene obtains actual knowledge of suspected CSAM or other child-endangerment activity, we may:

Remove or disable access to the relevant content.
Restrict, suspend, or terminate accounts.
Preserve relevant content, communications, account information, and technical records.
Prevent further contact or interaction.
Investigate related accounts, events, content, or activity.
Cooperate with law-enforcement or child-protection authorities.
Report confirmed or apparently unlawful CSAM to NCMEC or another competent regional authority, as required by applicable law.

A parent or legal guardian who believes that a child’s personal information has been improperly collected, disclosed, or used through Night Scene should contact:

Designated Child-Safety Contact: Asela Neligama
Child-Safety Email: nightscene@altcircleapps.com

A report should identify the relevant account, Club, event, message, comment, or content and explain the nature of the concern. Do not download, copy, forward, attach, screenshot, or redistribute suspected CSAM when making a report.

If a child appears to be in immediate danger, contact local emergency services or law-enforcement authorities immediately. Night Scene’s reporting and support channels are not substitutes for emergency assistance.

Clubs remain responsible for complying with all legal-age, privacy, consent, safeguarding, admission, advertising, employment, performance, and alcoholic beverage requirements governing their venues and events. An individual’s use of Night Scene does not establish that the individual is legally permitted to enter a venue, participate in an event, or consume alcohol.

17. Third-Party Links and Services

Night Scene may contain links to ticketing platforms, Club websites, social networks, mapping services, payment providers, and other third-party services.

Night Scene does not control the privacy practices of these third parties. This Privacy Policy does not apply to information collected independently by them.

You should review the privacy policies of third-party services before providing personal information.

Clubs must not use third-party links or services to circumvent Night Scene’s child-safety requirements or direct users, including minors, toward unlawful, exploitative, predatory, or age-inappropriate content or interactions.

18. A Club’s Responsibilities for Personal Information

A Club may receive information from users through messages, event inquiries, reservations, external ticketing links, or other interactions.

When a Club independently determines how to use this information, the Club is responsible for its own privacy compliance.

The Club must:

Collect and use personal information lawfully.
Provide any required privacy notice.
Use information only for legitimate purposes.
Maintain reasonable security.
Limit access to authorized personnel.
Honor applicable privacy rights.
Avoid sending unauthorized marketing.
Avoid selling or disclosing information without a lawful basis.
Notify Night Scene promptly if Night Scene-supplied information is compromised.
Apply appropriate safeguards to personal information relating to minors.
Obtain any consent or authorization legally required before collecting, using, publishing, photographing, filming, or disclosing information relating to a minor.
Refrain from using personal or location information to contact, locate, profile, target, exploit, or facilitate inappropriate access to a minor.
Restrict access to information relating to minors and child-safety reports to personnel who require it for legitimate and lawful purposes.
Promptly report suspected CSAE, CSAM, grooming, sextortion, child trafficking, or other child endangerment through Night Scene’s in-app reporting mechanism.
Cooperate with lawful child-safety investigations and preservation requirements.
Refrain from retaliating against, intimidating, or attempting to identify or silence a person who submits a child-safety report.
Refrain from downloading, copying, forwarding, attaching, screenshotting, or otherwise reproducing suspected CSAM when submitting a report.

Night Scene is not responsible for a Club’s independent collection or use of information outside the platform.

19. Changes to This Privacy Policy

Night Scene may update this Privacy Policy to reflect changes to:

Its services.
Its information practices.
Its service providers.
Applicable law.
Safety or security requirements.
Its child-safety, reporting, moderation, investigation, preservation, or enforcement procedures.

The revised Privacy Policy will display an updated “Last Updated” date.

When a change materially affects how personal information is collected, used, or disclosed, Night Scene will provide additional notice where required. Notice may be provided through the platform, by email, or through another appropriate method.

Where legally required, Night Scene will obtain consent before applying a materially different practice to previously collected information.

20. Questions, Complaints, and Child-Safety Reports

Questions, requests, or complaints concerning this Privacy Policy may be directed to:

WMP LLC
Doing business as Night Scene
954 Avenida Ponce de León, Miramar Plaza
Suite 205-PMB# 10164
San Juan, Puerto Rico 00907

Privacy Email: nightscene@altcircleapps.com
General Support: nightscene@altcircleapps.com
Security Reports: nightscene@altcircleapps.com

Child-Safety Reports

Users may report suspected CSAE, CSAM, grooming, sextortion, child trafficking, or other child endangerment through the reporting mechanism available within the Night Scene app.

Child-safety concerns may also be submitted to:

Designated Child-Safety Contact: Asela Neligama
Child-Safety Email: nightscene@altcircleapps.com

The designated child-safety contact is authorized to receive potential notifications from Google Play and other parties, review reports concerning potential CSAE or CSAM affecting Night Scene, coordinate enforcement action, and communicate with relevant authorities when required.

A child-safety report should, where reasonably possible, identify:

The relevant account, Club, event, message, comment, or content.
The nature of the concern.
When and where the activity was observed.
Any information that may help Night Scene locate the reported material or activity.

Do not download, copy, forward, attach, screenshot, or redistribute suspected CSAM. Reports should identify where the material appears so that Night Scene can review it safely.

If a child appears to be in immediate danger, contact local emergency services or law-enforcement authorities immediately.

You may also have the right to contact the Puerto Rico Department of Consumer Affairs or another authority with jurisdiction over your complaint.