Who we are
3. This Platform is operated by Siteways International AG. We are a software services provider.
4. We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA). We are responsible as ‘controller’ of that personal information for the purposes of those laws.
Our collection and use of your personal information
7. We collect personal information about you when you access our Platform, register an account with us, contact us, send us feedback, purchase services via our Platform, post material to our Platform and/or complete customer surveys or participate in promotions via our Platform.
8. We collect this personal information from you either directly, such as when you register with us, contact us or purchase services via our Platform or indirectly, such as your browsing activity while you are using our Platform (see ‘Cookies and other tracking technologies’ below).
9. The personal information we collect about you depends on the particular activities carried out through our Platform. This information includes: * your name, location and contact details; * date of birth; * bank account and payment details; * details of any feedback you give us by phone, email, post or via social media; * information about the services we provide to you; * preferences for services provided by Models via our Platform; and * your account details, such as username, login details.
10. We use this personal information to: * create and manage your account with us; * verify your identity and that you are over 18 years old; * provide services to you; * customise our Platform and its content to your particular preferences; * notify you of any changes to our Platform or to our services that may affect you; and * improve our services.
11. This Platform is not intended for use by children under any circumstances and we do not knowingly collect or use personal information relating to children.
Our legal basis for processing your personal information
12. When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
13. The legal bases that we may rely on include: * consent: where you have given us clear consent for us to process your personal information for a specific purpose; * contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract; * legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations); and * legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third-party (unless there is a good reason to protect your personal information, which overrides our legitimate interests).
Further information—the personal information we collect, when and how we use it
14. For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:
|When information is collected||What information we ask for||How and why we use your information|
|When you register with us||Contact details: your name and email address; and Age verification: a photo of you holding valid photo identification in high resolution.||We ask for this: * to create and manage your account with us; * to communicate with you about your account; and * where applicable, to pass on details of Fans to Models who subscribe to that Model.
We rely on consent as the lawful basis for collecting and using your personal information. We will keep your contact details until you close your account with us, or we close your account
This will be collected by our third-party payment provider in order to process payments and confirm Fan subscriptions, one-off payments and premium account subscriptions.
We rely on our contract with you as the lawful basis for collecting and using your personal information.
Your payment information will be shared with our payment services providers Pay Square and Pay Safe. For more information on how Pay Square and Pay Safe process your personal data, please review the Pay Square Privacy Notice and the Pay Safe Privacy Notice.
|When you use or otherwise access our Platform||Browsing data and preferences in relation to our Platform||We ask for this: * in order to optimise the performance of the platform; and * fully enable its functionality for you.
This will be collected automatically by our cookie and third-party software analytics providers.
We rely on consent as the lawful basis for collecting and using your personal information.
We keep this information for as long as you give consent for us to collect it.
|When Models upload content onto the Platform||Content that includes the likeness and images of Models||We rely on consent as the lawful basis for collecting and using your personal information.|
15. We routinely share Fans’: * account profile with Models that they wish to subscribe to; * payment details with our payment providers in order to process payments and issue refunds where applicable; and * browsing habits with our software analytics providers in order to optimise the performance of the Platform and fully enable its functionality.
16. We routinely share Models’: * account profiles with Fans that subscribe to them; * payment details with our payment providers in order to process payments and issue refunds where applicable and to process subscription and other payments made by Fans to Models; and * content and page interaction statistics with our software analytics providers in order to analyse the performance of the Model Listings and share the resulting information with Models to help improve the popularity of their Listings.
17. Some of those third-party recipients may be based outside the European Economic Area. For further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.
18. We will share personal information with law enforcement or other authorities if required by applicable law.
19. We will not share your personal information with any other third-party or for any other purposes.
Whether information has to be provided by you, and if so why
20. We require you to provide: * Verification of your age, identity and your contact details in order to register for an account with us; and * your payment information to enable us to facilitate payments on your behalf and process refunds.
21. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
The impact of our use of your personal information
22. Our use of your personal information will allow us to provide services to you and will result in your data being shared with our third-party service providers who will then be permitted to contact you for marketing purposes should you provide your consent.
Transfer of your information out of the EEA
23. We may transfer your personal information to the following which are located outside the European Economic Area (EEA).
24. Under data protection law, we can only transfer your personal data to a country or international organisation outside the EEA where: * the EU GDPR applies and the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’); * there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or * a specific exception applies under data protection law.
25. These are explained below.
26. We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include: * all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’); * Gibraltar; and * Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
27. The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
28. Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
29. Where there is no adequacy decision, we may transfer your personal data to another country we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
30. The safeguards will usually include using legally-approved standard data protection contract clauses. In relation to transfers to our overseas offices or other companies within our group, the safeguards may instead include legally binding rules and policies which have been approved by the European Commission.
Transfers under an exception
31. In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country where an exception applies under relevant data protection law, for example if you have explicitly consented to the proposed transfer after having been informed of the possible risks or the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request.
32. We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
33. If you would like further information please contact us. We will not otherwise transfer your personal data outside of the area comprising the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Cookies and other tracking technologies
36. We would like to send you information about our services, competitions and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email, telephone, text message (SMS) or automated call.
37. We would also like to share your information with selected third-parties so that they may send you information about their products and/or services, depending on what you agree with us.
38. We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you make a booking with one of our providers via the platform.
39. If you have previously agreed to being contacted in this way, you can unsubscribe at any time by: * contacting us; * using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts; or * updating your marketing preferences in your account settings.
40. It may take up to 7 days for this to take place.
41. For more information on your rights in relation to marketing, see ‘Your rights’ below.
43. For further information on each of those rights, including the circumstances in which they apply, see Rights of the Individual published by the European Data Protection Supervisor.
44. * email, call or write to; * let us have enough information to identify you (e.g. account number, user name, registration details); * let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and * let us know the information to which your request relates including any account or reference numbers, if you have them.
Keeping your personal information secure
45. We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
46. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
47. We hope that we can resolve any query or concern you raise about our use of your information.
48. You have the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the EEA is the European Data Protection Supervisor who may be contacted online here or by telephone at: +32 2 283 19 00.
How to contact us