Effective date: April 22nd, 2019
Agency4Web Development LTD. (“Operator”, "us", "we", or "our" and appropriate forms thereof) operates the www.LetsAdore.com website (hereinafter referred to as the "Service", or “LetsAdore”), respects your privacy and is committed to protecting it through our compliance with this policy.
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data, as well as the types of information that we may collect or that you may provide to us when you use our Service.
This policy DOES NOT apply to information that you provide to or is collected by any third party (including without limitation Product Distributors, Studios, Models, Pornstars, Another Users, Advertisers and any other third parties whose services and products you encounter by using our Service). These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Service. Service is the www.LetsAdore.com website operated by Agency4Web Development LTD
Personal Data. Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data. Usage Data is data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies. Cookies are small files stored on your device (computer or mobile device).
Data Controller. Data Controller means the natural or legal person who (either alone, jointly or in common with other persons) determines the purposes for which, and the manner in which, any personal information is, or is to be, processed.
Data Processors (or Service Providers). Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User). Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service.
Types of Data Collected
While you are using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
First name and Last name
Login and Password
Your Sexual Preferences
Your Interests and Hobbies
Cookies and Usage Data
Information that is about you but individually does not identify you, such as a Pseudonym that you create to be used on LetsAdore
We may use your Personal Data to send you confirmation of your registration, confirmation of purchases made via the Service, as well as to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may collect real-time information about the location of your device. If you do not want us to collect this information you may opt out at any time by going to your Account settings/browser settings and turning off location tracking for LetsAdore therein. Note, however, that opting out of LetsAdore’s collection of location information will cause our location-based features to be disabled.
Special category of data
LetsAdore is an adult entertainment site and, due to the nature of our site and its purpose, we may have data about you, which could possibly reflect your sexual interests.
If, after creating an account, you freely indicate certain sexual preferences in order to give yourself more visibility and presence on our site, you are providing us with details about your sexual interests.
When you use our site, for example when you visit the pages of the Models, or Product Distributors on the Marketplace we process and store information related to your activity (e.g. the category of Models you watched or the page you visited) in order to provide you with the services you requested for and enhance your experience on the site. If you agreed to receive promotional emails from us, we will also send you special offers and news about our features based on your interests on our site.
Due to the explicit meaning of each category name, as well as the types of Models you request services from it is possible that the chosen categories indicate your online sexual preference to us.
We understand that this may not explicitly reflect the reality of your life outside of the site. Your online preferences may only be a role that you choose to play in a virtual environment. However, in order to provide you with the highest level of data protection, we categorize such type of data under the sensitive data category, which is highly protected and handled with the utmost care.
What are your choices regarding the collection and use of your sensitive data?
Because your online sexual preferences and other data relating to your sexual interests are essential aspects of privacy, we are maintaining very high IT security standards. We are periodically proceeding with controls and assessments of our security measures, in order to guarantee a trustworthy environment.
We will always ask you to agree to the use of your sensitive data.
Please be aware that you can change your opinion regarding the processing of the aforementioned sensitive data in your consent settings at any time.
However, please note that refusing to provide or revoking your consent to have this data collected and used means that you will not be able to log into your account and use the services, as we will not be able to provide you with the services without processing such information.
In case you freely indicated your sexual preferences in your account settings, and you just want to delete this data, you can easily remove it from your profile in your account. This will not affect your use of the site.
Tracking Cookies Data
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Advertising Cookies. Advertising Cookies are used to provide you with advertisements that may be relevant to you and your interests.
Use of Data
We use the collected data for various purposes:
To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
We may process your Personal Data because:
We need to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
You have given us permission to do so;
The processing is in our legitimate interests and it is not overridden by your rights;
For payment processing purposes;
To comply with the law.
Retention of Data
We implement serious security measures, including technical and organizational security measures, to grant maximum protection to your personal information against unauthorized access, modification, disclosure or deletion. Your data is protected by our highly sophisticated security systems.
We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our site and the entire IT infrastructure related to it are updated against the latest network security vulnerabilities. We periodically test our IT systems and do sophisticated penetration tests. Our site incorporates the most advanced security technologies available in order to ensure maximum safety of its users and the safekeeping of their related information.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a short period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
We will retain your personal data for as long as we consider it necessary to:
Enable you to use our services and provide our services to you, including maintaining your customer account;
Comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
Conduct our business and for our legitimate business interests, such as establishing, exercising or defending legal claims, chargeback prevention, fraud detection and prevention, hindering any other illegal activity on our site, and enhancing safety. For example, if we close or suspend your account for fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information shall also be kept available in case of ongoing judicial proceedings/and or investigations. As part of our fraud detection and prevention process, we also blacklist all former usernames for a certain time. Therefore, a former username cannot be used for a new registration.
Protect our site and your personal information from accidental or malicious loss and destruction. Residual copies of your personal information may not be removed from our backup systems for a very limited time (usually 30 days). Some copies of your information (e.g., log records) may also remain in our database, but are disassociated from personal identifiers.
Transfer of Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside of these jurisdictions, please note that we transfer the data, including Personal Data, to Germany and United States of America and process it there.
We comply with the EU Data Protection Regulation commonly called "GDPR" (If you want to learn more you can check: EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC), which provides a high level of protection of your personal data.
If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.
Disclosure of Data
Under certain circumstances, Operator may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency) in the good faith belief that such action is necessary:
To comply with a legal obligation
To protect and defend the rights or property of Operator
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service (including you) or the public
To protect against legal liability
Additionally, we may disclose personal information that we collect or that you provide:
To contractors, service providers, and other third parties with which we do business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them (including, by way of illustration, payment processing services and fraud prevention services).
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Agency4Web Development LTD’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Agency4Web Development LTD about our Service’s users is among the assets transferred.
To fulfill the purpose for which you provide it.
With your consent.
Security of Data
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out this information in public areas like message boards.
Unfortunately, the transmission of information via the internet and mobile platforms is not 100% secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We currently DO NOT provide any personal information to third parties for such purposes. However, to make such a request, you can send an email to info@LetsAdore.com.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you, and/or if you want it to be removed from our systems, you can send an email to info@LetsAdore.com.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information. You can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you at info@LetsAdore.com.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information. Basically, you can ask us to put on hold the use of your data in 4 cases:
If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.
You have objected to a processing activity based on legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.
You consider that the processing is unlawful but you object to erasure and request restriction, instead.
We have no further need for the data but you require it to establish, exercise, or defend legal claims.
The right to data portability. You have the right to be provided with a copy of the information we have in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service, namely we are currently using the AdWords and Remarketing Lists features of Google Analytics for Display Advertisers. We and Google use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our Site.
We may use third-party Service Providers to show you advertisements on our LetsAdore.com website to help support and maintain our Service in the future. However, as of the Effective Date of this Policy, we DO NOT share your information with third-party advertisers, and only use it to advertise on the LetsAdore.com website.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors).
The payment processors we work with are:
PayPal / Braintree
Links to Other Sites
These third parties may use tracking technologies to collect information about you when you click such a third-party link and are directed to a third-party website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, mobile apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us at info@LetsAdore.com. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.