Privacy Policy

Last Modified: 2nd of April 2024

1. PERSONAL INFORMATION WHICH WE MAY COLLECT

   1. While providing our services, we may collect Personal Information, namely:

      1. An information necessary for registration. When you register on our Website and create a standard User account, you will be required to provide Personal Information including, without limitation, email address (including the verified or non-verified status of the email address), password, username, display name (if applicable), country, region and city of residence, photos (if applicable), gender, languages you speak, your interests and fetishes (if applicable). Based on the interface during the registration process, the provision of some of the above Personal Information may be optional and not required, while the provision of other Personal Information will be mandatory. If you use a third-party solution to log in to our Website or create an account on our Website, we may collect and process personal information that you provide to that third party.
      2. An information necessary for registration of Operator account. In certain cases where the User wishes to register special Operator account, we may require additional information (including identity verification information) such as copy of your ID document (which can be national ID, national passport, international passport, citizenship card, state ID, driver’s license (only for countries where a national ID or passport is not mandatory)), your picture and visual appearance, date of birth and place of residence, information related to payments, methods of payments and balance of Operator account, status, date and provider of identity verification. During this registration you will also be required to verify your age and identity through our internal procedure or with the help of our trusted third-party service provider(s). By proceeding with such verification via third-party service provider, you authorize the Company to transfer your personal data to the third party for the purposes of confirming legal age and identity. The registration information listed above is necessary for you to be able to fully use the special Operator account on our Website.
      3. Contact data: when communicating with the Company we might process Personal Information, which you may willingly provide to us, for example: name, address, telephone number, email address, etc. Provision of Personal Information, described in this clause is optional.
      4. Passively collected data: during your activities on the Website, our system might automatically process following information: Internet protocol (IP) address, date and time of your last activity, User’s status and account status, information about reports received and history of such reports, room ID, cookies (as described in more detail in this Policy), video chat screenshots and snapshots for moderation purposes, your visits to our website and your search history (if applicable) that may be recorded in our log files. In addition, when you use our Website, usage information is transmitted back to us so we can determine how users are interacting with our Website, to assist us with improving our Website, and to correct any problems that may occur.
      5. Marketing data: We also automatically record information about your usage of the Service, including actions taken, date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to logins, clicks, messages, contacts, content shared, Chats, use of video features, meetings, and other feature usage and marketing information.
      6. Information related to messages. We may process chat message content, sender and recipients, date, time, and read receipts as well as all text content shared.
      7. Information related to payments. If you are involved in a financial transaction with the Company, we may collect information about your transactions on the Website, currency, number of minutes, identifier of the User associated with the transaction, value, type, status of the transaction, details, type, status of the invoice, information related to refunds including without limitation to the reason of the refunds, type and unique identifier of the services purchased. If an Operator account is created, we may also process billing information (to generate your invoice when you request a payout), payout method, details of the transaction, details of any errors during the transaction, number of minutes.
      8. Information related to the video communication using Website: participants, date, time, and duration. We process activity during the communication (such as joining or leaving), including without limitation date, time, persons engaged in the communication.
      9. You may wish to share with us some other Personal Information, that is not described in this Policy. We reserve the right to collect and process such data.

2. NO MINORS POLICY

   1. The services of the Company are not intended for use by anyone under the age of eighteen (18) or twenty-one (21) years of age, depending on the age of majority in Your jurisdiction from which the Website is accessed. Only persons of legal age are permitted to use the services of the Company and register on our Website. Therefore, we do not knowingly collect personal data from minors.

3. WAYS OF COLLECTING YOUR PERSONAL DATA

   1. We collect your personal data mainly through the information you provide to us through the Website, for example, when you:
   • Visit and/or use our Website;
   • Create an account on our Website;
   • Request support through our contact details;
   • Contact with us via email, post, or other forms of communication;
   • Interact and communicate with our Website and other Users of the Website.
   
   
   2. What is more, we may collect information about users whenever they interact with the Website through technologies such as cookies, as described below.

4. LEGAL BASIS AND PURPOSES FOR OUR USE OF YOUR INFORMATION

   Part 1: Legal basis for Processing of Personal Data under Article 6 of GDPR

   1. All processing of your Personal Information is performed in accordance with the GDPR. We process your Personal Information for the purposes listed below and on the legal basis indicated below. This clause is further structured as follows - first you will find the legal basis for the processing of your Personal Information and then the indicative purposes for which the Company may use your Personal Information under that legal basis. If the Company will ask to provide any other Personal Information not described above, then such information, the purpose and legal basis for the collection and processing, will be communicated to the user at the point of collecting the Personal Information.

   2. Legal basis No. 1 – for compliance with legal obligations (Art. 6 para. 1 lit. C GDPR)

      
      

      Purposes of collecting Personal Information under this legal basis:
      In the course of its business, the Company is required to comply with various laws and regulations. In order to comply with such regulations, the Company will collect and process Personal Information. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property.
      The following purposes of processing Personal Information, for example, are covered by such legal obligations:

      1. Compliance and risk management, including compliance with applicable laws, regulations, and legal obligations, (for example content moderation, age verification, and protection of the rights of individuals);
      2. Compliance with third party payment processor requirements issued in accordance with applicable regulations;
      3. Retaining payment information for tax and/or audit purposes (if applicable);
      4. Providing legal aid to competent authorities in the context of criminal proceedings or prosecution in accordance with official orders and requests;
      5. Addressing any legal claims, disputes, or investigations.

   3. Legal basis No. 2 – for the performance of our contractual obligations (Art. 6 para. 1 lit. B GDPR).

      
      

      Purposes of collecting Personal Information under this legal basis:
      In order to perform our services, provide you with access to our Website, fulfil our contractual obligations, and to provide you with the possibility to enter into contractual arrangements with us we will process Personal Information.
      The following purposes of processing Personal Information, for example, are covered by such contractual obligations:
      

      1. To maintain our Website. We use Personal Information to ensure general performance of our services, performance and administration of the Company and its Website and execution of the agreement we have with you;
      2. To provide video chat functionality, messaging services, automatic translating functionality, and creation of the account functionality.
      3. To improve our Website and services. Personal Information helps our systems ensure that our interface is accessible for users across all platforms and devices;
      4. To send periodic emails: We may use the information we collect from you when you register or use certain other Website features (e.g. filling of the contact form). This might be for security reasons, to ask your opinion about the Website, to send you advertisement or it may be to keep you updated on any changes to the services provided on the Website;
      5. Responding to any queries, requests, or technical issues.

   4. Legal basis No. 3 – legitimate interests pursued by the Company (Art. 6 para. 1 lit. F GDPR).

      
      

      Purposes of collecting Personal Information under this legal basis:
      Data processing might take place to maintain the legitimate interests of the Company or a third party.
      The following purposes of processing Personal Information, for example, are covered by such legitimate interest:
      

      1. Monitoring and prevention of fraud, misuse (e.g. for illegal purposes), and any other type of criminal activity;
      2. Identification and examination of different possible vulnerabilities of the Website;
      3. Measures for protecting our Users, as well as safeguarding network and information security, also measures to protect our employees, contractors, and property of the Company;
      4. Processing inquiries from competent authorities, lawyers in the course of legal prosecution and enforcement of legal claims in the context of legal proceedings.
      5. Providing information security and IT security on our Website and safeguarding our network;
      6. Protecting against harm to the rights, property, or safety of our users or the public;
      7. Analyzing and improving the quality of the services and the general user experience;
      8. Developing new features for our Users;
      9. Providing advertising, which enables us to offer our services and services of our partners;
      10. Protection of our legitimate interests or those of third parties, provided such interests do not override your fundamental rights and freedoms;
      11. Processing client preferences via cookies on our Website (see more about cookies below).

   5. Legal basis No. 4 – protection of vital interests (Art. 6 para. 1 lit. D GDPR).

      
      

      Purpose of collecting Personal Information under this legal basis is the necessity to protect the vital interests of individuals, such as in emergency situations where someone's life or physical integrity might be at risk. This legal basis will only be applicable in the event that such a situation arises.

   6. Legal basis No. 5 – your consent (Art. 6 para. 1 lit. A GDPR).

      
      

      Purposes of collecting Personal Information under this legal basis:
      If you have given us your consent to process your Personal Information, processing will only take place in accordance with the purposes defined and to the extent agreed in such declaration of consent. You have a right to withdraw your consent at any time if you no longer agree to the processing. Please note that the withdrawal of the consent does not affect the lawfulness of processing based on consent before its withdrawal.
      By checking the respective box as a part of the registration process (or giving consent in other similar way) or by utilizing the Website, the User agrees to this Policy and agrees to the data processing as described herein.

   Part 2: Legal basis for processing of Special Categories of Personal Data under Article 9 of the GDPR

   When interacting with the Website and participating in Chat and communications, you may voluntarily provide special categories of personal data to us. Under Art. 9 para. 1 GDPR special categories of personal data refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. The processing of special categories of User’s personal data will be carried out by us on the legal basis set out below and for the purposes set out below:

   7. Legal basis No. 6 – your explicit consent (Art 9 para 2 lit a GDPR).

      
      

      Purposes of collecting Personal Information under this legal basis:
      Your participation in video chat communications with other Users may include special categories of personal data if you voluntarily choose to disclose such data. We want to emphasize that our role in this process is solely that of an intermediary. We facilitate the video chat communication services, but you are solely responsible for your actions during such communication and for the disclosure of special categories of personal data.
      What is more, during the registration process you may be asked to indicate some of your special categories of personal data, such as information about sex life, sexual preferences, or sexual orientation. During the registration process and in case you sign a specific agreement with us (if applicable), you will be asked to give your explicit consent to the processing of such special categories of personal data, while acknowledging that you are solely responsible for making such information publicly available (if this functionality is available on the Website).

   8. Legal basis No. 7 – processing of data which manifestly made public by you (Art. 9 para. 2 lit. E GDPR).

      
      

      Purposes of collecting Personal Information under this legal basis:
      You further understand that by registering on our Website, you are explicitly expressing your intention to make your special categories of personal data manifestly public in case the Website provides such opportunity and unless otherwise is decided by you. This explicit intention to make your information manifestly public, together with the fact that you fill in special categories of personal data yourself, constitutes an additional legal basis allowing the processing of special categories of personal data.

   9. Legal basis No. 8 – Defence of legal claims (Art. 9 para. 2 lit. F GDPR).

      
      

      Purposes of collecting Personal Information under this legal basis:
      Your special categories of personal data will be processed in compliance with Article 9(2)(f) of the GDPR, namely when processing is necessary for the establishment, exercising, or defence of legal claims.

   10. 

5. DATA RETENTION

   1. For how long we retain your Personal Information depends on the type of information and the purpose for which we process the data.
      For example:
      Personal Information collected for purposes related to the performance of a contract and the maintenance of an account will be retained until the completion of the contract and as long as the account exists.
      Personal Information collected for the purposes of the legitimate interests (as well as other purposes described above) shall be retained as long as needed to fulfill such purposes.
   2. What is more, we will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy and to comply with our contractual and/or legal obligations unless and until you ask us to erase this information which is subject to erasure. For more information on your right of erasure, please see the ‘Your rights’ section below.
   3. We may retain your Personal Information for a longer period if the relevant law and/or regulation requires us to retain such information for a longer period, if we receive a relevant complaint, or if we reasonably believe that there is a prospect of litigation in respect to our relationship with you, or if we receive a relevant court order or request by any other competent authority to retain such information.

6. SHARING OF THE INFORMATION

   1. In certain situations, we may be required to disclose Personal Information in response to lawful requests by competent authorities, necessary to fulfil national security, public interests, or law enforcement obligations. We may also share and disclose your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful request for information we receive, or to otherwise protect our legal rights and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request.
   2. Our officers, contractors and/or employees will receive access to your Personal Information on a need-to-know basis only.
   3. Company may share your Personal Information with third parties with your consent, for the purpose of performing a contract or for other purposes defined herein. We require any company with which we may share your Personal Information to protect such data in a manner consistent with this Policy and to limit the use of such Personal Information to the performance of services for the Company.

   4. To a limited extent, we may transmit Personal Information to the following processors:

      
      • AHPS LTD: for hosting services
      • Third party service providers used for verification purposes (if applicable). You will be informed of specific third-party service providers on a separate page during the verification process;
      • Third party service providers used to process your payments. You will be informed of specific third-party payment service providers on a separate page during the payment process on the payment page.

   Processors may only use or disclose such data to the extent necessary to perform services for us or to comply with legal rules.

7. SECURITY MEASURES

   1. The security of information is very important to the Company, and we strive to protect the information we collect using best practices in personal data security. We maintain comprehensive administrative, technical, and physical measures designed to protect your Personal Information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. For example, we use Transport Layer Security (TLS) cryptographic protocol while dealing with Personal Information.
   2. We use certain security measures to keep your Personal Information safe, but we cannot guarantee that these measures will stop any users try to get around the privacy or security settings of the Website through unforeseen and/or illegal activity. That is why we make no warranty, express, implied or otherwise, that we will prevent such access.

8. COOKIE POLICY

   1. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive. Cookies can be used in various ways, including to make the Website work, to analyze traffic, or for advertising purposes.
   2. Cookies are divided into ‘first party’ and ‘third party’:
      First party cookies are the cookies served by the owner of the Website and domain. Any cookie we place ourselves is a ‘first party cookie’.
      Third party cookies are cookies placed on our domains by trusted partners that we have chosen to allow to do so. These can be advertising partners, security providers, and more.
   3. Cookies can be either ‘session cookies’ or ‘permanent cookies’:
      Session cookies only exist until you close your browser, ending what is called a ‘session’. They are then deleted.
      Permanent cookies have a range of different lifespans and stay on your device after the browser is closed. On our Website, we try to only serve permanent cookies (or allow permanent cookies to be served by third parties) that have a limited lifespan. However, for security reasons, or in other exceptional circumstances, we might sometimes need to give a cookie a longer lifespan.
   4. Web browser cookies may store information such as your IP address or another identifier, your browser type, and information about the content you view and interact with on digital services. By storing this information, web browser cookies can remember your preferences and settings for online services and analyze how you use them.
   5. The first time you visit our Website with one of your devices, a pop-up will appear with the information that our Website uses cookies as well as a link to our Privacy Policy. With this pop-up you will be able to adjust personal settings in regard to cookies.

   6. We use ‘cookies’ to collect information in order to make our Website more user-friendly, for example by remembering your personal preferences and settings. Additional to that, we use cookies to help the Website work properly, improve your user experience, and to ensure that services promoted are relevant to you. The table below explains the cookies that the Company and our third-party partners use, and the purpose of such usage:

      Category of Cookies	Purpose
      Strictly Necessary Cookies	Strictly Necessary Cookies and other similar technologies are necessary for the operation of the Website. These cookies are necessary for our Website to function correctly and cannot be deactivated. They are used to carry out the transmission of a communication over an electronic communications network and to provide you with the requested services, if needed. While you can configure your browser to block these cookies, some or all parts of our service may not work properly. Strictly Necessary Cookies help us with the following without limitation: Saving your preferences: These cookies remember your choices, such as your cookie preferences, preferred language, and customization settings (UI customization cookies); Logging in: These cookies enable you to sign in and keep you logged in to our Website and help us recognize you during your visit (authentication cookies); Enhancing security: These cookies help us maintain online security and prevent malicious activities or violations of our Terms and Conditions of Use (user-centric security cookies); Ensuring system operation: These cookies are essential for the proper and secure operation of our systems and processes (user-centric security cookies); User Authorization: These cookies verify whether a user is authorized to access specific services or content (authentication cookies); Optimizing Server Load: These cookies balance the load on our servers to provide the best possible experience (load balancing session cookies).
      Performance and functionality cookies	Performance cookies and other similar technologies collect information about how you have used the Website. These cookies help us collect data about how users interact with our Website. Functionality cookies and other similar technologies allow us to remember how you are logged into our Website, when you logged in or out, and the actions you have taken while you have been logged into the Website. These cookies enable the following: They count visits, identify the most and least popular pages, and offer insights into how users navigate the platform; They also assist in evaluating how users respond to new advertisements, pages, or features; These cookies do not identify individual users; they focus on website performance during user interactions; They remember your preferences such as your region and watch history; They retain information as you move between pages, eliminating the need to re-enter information.
      Third-party or targeting cookies	Third-party or targeting cookies and other similar technologies are typically provided by selected third parties and are used to deliver advertisements that are relevant to your interests. These cookies can track your history within our website, including the pages you have visited and the links you have clicked on. These third-parties include, among others, Google, Inc. and Google Analytics services, Amplitude, HotJar. We recommend that you review the privacy and cookie policies of these websites/services to gain a better understanding of the cookies they use and their methods of collecting personal data. Please note that if you choose to disable these types of cookies, you still may see advertisements, but the advertisements will not be tailored to your interests. You can also disable these types of cookies by adjusting your browser's security settings.

   7. We recommend you don't change your cookie settings as it may limit your user experience and the performance of the Website. If you do want to change the cookies setting, you can do this through your browser. Different web browsers may use different ways of controlling cookies, so you'll need to use your browser's help section to find out how to do this. To learn more about cookies and how to manage or delete them, visit allaboutcookies.org.

9. YOUR RIGHTS TO YOUR INFORMATION

   1. In accordance with effective regulations, you have a significant number of rights related to your Personal Information. We undertake to keep your personal data confidential and to ensure that you may exercise your rights. You may exercise your rights free of charge by writing us an email at [email protected], simply informing us of the reason for your request and the right that you wish to exercise. Please find below legal rights that you have under GDPR:

      1. You may request access to the Personal Information we maintain about you. If you request such access, we will provide you with all the information as required by law.
      2. The right to data portability. You may also obtain a copy of any Personal Information that we hold about you in our records in a format compatible and structured to allow you to exercise your right to data portability when the processing is based on your consent or on the performance of the agreement between you and us.
      3. You may also request that we correct, rectify, amend, erase any information which is incomplete, out of date, or inaccurate.
      4. The right to restrict processing. You can request the restriction of the processing (i) if you wish to restrict processing of your Personal Information rather than deleting it as defined by the law, (ii) if you wish the Company to keep your Personal Information because you need it for your defense in the context of legal claims.
      5. The right to erase your Personal Information. You can request the deletion of your Personal Information if (i) your Personal Information is no longer necessary for the purpose of the data processing, (ii) you have withdrawn your consent on the data processing based exclusively on such consent, (iii) you objected to the data processing, (iv) the Personal Information processing is unlawful, (v) the Personal Information must be erased to comply with a legal obligation applicable to the Company.
      6. The right to object to the processing of your data. You have a right to object to our use of your Personal Information for our own purpose at any time. In other words, you can withdraw your consent to processing your Personal Information by us. In case you want to exercise this right, you need to contact us. This right also includes the right to object to processing your personal information for marketing and advertising purposes.
      7. You also have the right to lodge a complaint with the competent supervisory authority. In Cyprus, this is Commissioner for Personal Data Protection - https://www.dataprotection.gov.cy/
   2. There are exceptions to these rights, however. For example, access to Personal Information may be denied in some circumstances if making the information available would reveal Personal Information about another person or if we are legally prevented from disclosing such information. In addition, where some of the data is necessary to maintain the Company or where that is a legal requirement, we may retain such data for the period it is needed or required even if you withdraw your consent or request that we delete your data. Such information shall not be considered subject to erasure.

10. CHANGES TO POLICY

    1. This Policy may be amended at our full discretion without prior notice in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. We encourage you to review it periodically to be aware of the changes we may have made. Reading it carefully and checking for any modifications is your responsibility. By using the Website, you accept and agree to the Policy.

11. CONTACT US

    1. If you have any further questions about this Privacy Policy or the processing of your Personal Information, please contact us via email at [email protected].