Adult Entertaiment Affiliate World Systems International Limited, a limited liability company formed under the laws of the Republic of Cyprus, and Belvedere V Limited with its registered office at Woodford house, Peter Street, St. Helier, Jersey JE2 4SP, in their capacity as payment agents for Woodlaine Digital Solutions Limited, a limited liability company formed under the laws of the Republic of Cyprus with its registered office at Woodlaine Digital Solutions Limited, Kennedy 12-14, 1st Floor, Office 108, 1087 Nicosia, Cyprus.
We operate the following websites;
All parties and websites mentioned above are hereafter referred to as "Adult Entertaiment".
If there are any provisions in this policy that you would like further clarification on, or to exercise your privacy rights, please get in contact via email@example.com
Adult Entertaiment is the Data Controller and is responsible for your Personal Data (collectively referred to as "Adult Entertaiment", "we", "us" or "our" in this policy).
We keep this policy under regular review and it is subject to change. You should refer to this policy at least once a year to remain updated.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
Any information and content you provide via your public profile (Advertisers only), will be deemed as public information. Whilst in the public domain, your data can be copied, cached and stored by third parties and displayed on their site or search engine. This data may continue to exist on these sites, systems and search engines for a period even after you instruct us to remove it from our systems.
Personal Data, or personally identifiable information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you, please see the various categories and some examples of data in those categories below:
Identity Data - First name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data - Billing address, delivery address, email address and telephone numbers.
Financial Data - Bank account and payment card details.
Transaction Data - Details about payments to and from you and other details of products and services you have purchased from us.
Technical Data - Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data - Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data - Information about how you use our website, products and services.
Special Categories of Personal Data
Within the General Data Protection Regulation (GDPR) these include; details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, or any information about criminal offences, alleged or convicted.
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions - You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Third parties or publicly available sources - We will receive Personal Data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as Google;
advertising networks; and
search information providers.
Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.Third-Party Processors - We use the following categories of third parties to process your data and deliver services for the purposes shown. All of these processors have access to some of your Personal Data as appropriate for the delivery of the purpose specified.
|Management/Moderators||Service management, monitoring & accounting|
|Technical Management||Website technical & support services|
|Hosting||Secure data centre & hosting services|
|Software Development||Service development & improvement|
|Online Services||Website apps & features for members|
|Payment Service Providers||Stripe PSP, credit/debit card PSP, banking & other financial services|
|Emails Communications/Marketing||Communications, promo offers, informational mailshots & direct marketing|
If you, as a User of Adult Entertaiment, interact with a Member or Manager of an Adult Entertaiment Group, any data available to the Group Member will be accessible to the Group Manager also. By interacting with any such Member, you agree and consent to your information being available to one or both parties.
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Purposes for which we will use your Personal Data
We will only use your Personal Data in conjunction with the lawful basis of processing for which we collected it (see below). We may also process your data for another purpose/on a different legal basis provided that it is in line with the original purpose of processing.
Note: We may process your Personal Data without your knowledge or consent, in compliance with this policy and the law.
Please see below a table describing all of the ways we may use your Personal Data and on which legal bases we do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity(b) Contact||Performance of a contract with you|
|To process and deliver your order including:(a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may share your Personal Data with the parties set out below for the purposes set out in the table above.
We may share or transfer your Personal Data outside of the European Economic Area (EEA).
If ever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring we use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business 'need to know'. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you keep my Personal Data?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data; see your legal rights below for further information.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event of a law enforcement request involving your account or the data we hold about you on file. We are obliged by law to comply with the request and retain the data until the case has been closed by Law enforcement. Data may be held beyond the deletion request for the basis of complying with law enforcement.
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.
|GDPR: Individual Rights||Description|
|Right to Erasure||Every individual has the right to be forgotten upon request. The Data Controller must remove your Personal Data from its systems and request the same of any third-party systems of that controller|
|Right to Access||Every individual has the right to access their Personal Data held about them upon request.|
|Right to Portability||Every individual has the right to request their Personal Data and use it for other parties they wish to engage with.|
|Right to be Informed||Every individual has the right to be informed about how their Personal Data is being used, which may be provided upon request of the individual, or before the controller changes any use of that data, giving the individual the right to consent or object.|
|Right to Objection||Every individual has the right to object to the use of their Personal Data for any purpose proposed by a controller.|
|Right to Rectification||Every individual has the right to have errors in their Personal Data to be corrected.|
|Right to Restrict||Every individual has the right to restrict the uses of their Personal Data for any specific type of processing.|
|Rights on automated decisions & profiling||Every individual has the right to restrict or object to automated decision-making processes or profiling based on their Personal Data.|
If you wish to exercise any of the rights set out above, please contact us via: firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We have a responsibility to identify you as the data owner when processing any DSAR or similar requests. This may mean requesting specific information from you to help us confirm your identity and assure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
Under the GDPR we are obliged to respond to any DSAR within 30 days. It could take us longer than a month if your request is particularly complex or you have made a number of requests; in this case, we will notify you and keep you updated.
What is a Lawful Basis of use?
Legitimate Interest - In the interest of our business, in conducting and managing it, to enable us to give you the best service/product and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required/permitted to by law.
Performance of Contract - Processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Compliance with a legal obligation - Processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. Other Adult Entertaiment Terms, Policies and Agreements
Other Terms, Policies and Agreements may apply to the supply of any products or services by the Adult Entertaiment website(s) guest and/or registered Users.