Last updated: October 10, 2024
Introduction
This Privacy Policy describes how we collect, use, and protect your Personal Data when you use Online-Companions website (the 'Site') which is operated by 'TS Interactive LTD' (the 'Site Operator'), a company incorporated in Cyprus with the address 'Souliou, 1, MEZZANINE, Strovolos, 2018, Nicosia'. It is important that you read this Privacy Policy carefully to understand our practices regarding your Personal Data.
Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- "User" refers to any individual who accesses or uses the Site (logged-in or not logged-in).
- "Visitor" refers to a user who accesses the Site logged-in by using a regular account.
- "Model" refers to a user who accesses the Site logged-in by using an account with an elevated level of service and who, but not only, broadcasts their own webcam on the Site as a performer or entertainer.
- "Token" refers to the virtual currency used by the Site.
- "Cookies" refers to small files that are placed on your computer, mobile device or any other device.
- "Personal Data" refers to any information that relates to an identified or identifiable individual.
- "Payment Information" refers to any necessary information required for financial transactions, which may include legal Name and Surname, Address, Credit Card Number, Tax Identification Number (TIN), Value Added Tax number (VAT), Bank Account, and IBAN number. This does not mean that all of this information is always collected.
- "Third-Party" refers to any partner the Site Operator have a contractual agreement with, for the purpose of making the Site fully functional.
Use of Personal Data
In general, we collect Personal Data for various purposes, which includes:
- Providing and maintaining our Site
- Notifying Users about changes to the Site
- Allowing Users to participate in interactive features of the Site when they choose to do so
- Providing customer care and support
- Providing analysis or valuable information so that can be used to improve the Site
- Monitoring the usage of the Site
- Detecting, preventing and addressing technical issues
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
- Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Site Operator or by a Third-Party, except where such interests are overridden by Users interests or fundamental rights and freedoms which require the protection of Personal Data.
Retention of Personal Data
We will retain your Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We will retain and use your Personal Data to the extent required to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Upon deletion of your account, which you can do at any time, all your Personal Data (except Payment Information) will be deleted.
If your account remains inactive for 5 years, your Personal Data will be automatically deleted (except Payment Information).
Your Payment Information will be retained for 10 years to ensure compliance with potential authority requests and our own accounting needs.
Transfer of Personal Data
We mainly process your data within the European Union. Due to the nature of our activity, we may need to transfer your data outside the European Union. In this event, such transfers are covered by the appropriate guarantees in accordance with regulations.
Data Collection
Depending on the actions you take and the level of authentication you are using while browsing the Site, the Site Operator and Third Parties collect several types of Personal Data from Users, including but not limited to:
| Personal Data | Level of Authentication | Usage |
|---|---|---|
| Email address | Visitor, Model | Used to validate the authenticity of an Account, send password reset links and communicate with the User (In-mail, Support, Moderation, Promotional Offers etc.). |
| Name and Surname | Visitor, Model | The Site Operator collects the Official Identity of the Models performing on the Site. Third parties, such as our payment processor partners, may collect your Name and Surname for processing your payment information. |
| Payment Information | Visitor, Model | The Site Operator may collect Payment Information to facilitate transactions, such as payments for services, refunds, or affiliation partnerships. The legal basis for this data processing is the Directive on Administrative Cooperation – 7th amendment (DAC7). Third-party service providers may collect and store your credit card information to enable the purchase of Tokens on the Site. The legal basis for this data processing is Art. 6 (1) (a) — (c) GDPR. |
| IP Address | User | IP addresses may be stored temporarily during a session to determine the User's location and apply local laws and geoblocking. IP addresses may be stored permanently to identify Users with unique Personal Data if they engage in activities such as acquiring Tokens (e.g., Token giveaways or purchases). |
| Browser type and version | User | The Site Operator stores information on User's browser to provide analysis or valuable information so that we can improve the Site. It is also used to detect, prevent and address technical issues. |
| Time zone setting | User | The Site Operator uses time zone settings to provide analysis or valuable information so that we can improve the Site. It is also used to improve your personal experience browsing the Site. |
| Operating system and platform | User | The Site Operator uses time zone settings to provide analysis or valuable information so that we can improve the Site. It is also used to detect, prevent and address technical issues. |
| Page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page | User | Used to provide analysis or valuable information so that the Site Operator can improve the Site. It is also used to detect, prevent and address technical issues. |
| Profile information | Visitor, Model | As a registered user, you will have the ability to enter personal information, such as your Gender, Location, Sexual Orientation, Marital Status etc. As the abovementioned information will be visible to the public, we highly recommend to refrain from disclosing real information about yourself. However, should you fill in your profile information, you will be able to edit and/or delete it from your account at any time through your Profile Information settings. |
Cookies
When accessing the Site, you are required to accept essential cookies. You may also choose to allow us to collect Analytics Data from you. Essential cookies are necessary for the operation of the Site, while other cookies help us improve your experience and the performance of the Site.
| Cookie | Usage | Lifetime |
|---|---|---|
| Session (essential) | Unique identifier for your session on the Site. | Session |
| Session "Remember me" | When logging-in and ticking the "Remember me" checkbox. | 30 days |
| Age verification (essential) | Stores your acknowledgment that you are 18 years old or older. | Session |
| Cookie consent (essential) | Stores your consent preferences for cookies. | Session (on adult rated pages) or 1 month (if you accepted all cookies on PG pages) |
| Pak session | Unique identifier for your session on our analytics software. | Session |
| Pak ID | Long-term unique identifier for our analytics software. | 1 year |
| Affiliate | Store the affiliate Unique Identifier if you followed an affiliate link. | 10 years |
It's important to note that you may change your cookie consent preferences for each session (each time you close your browser or log out).
By logging in, you accept our analytics cookies, which provide the Site Operator with valuable information to improve the Site. You may exercise your right to object if you disagree by contacting us.
Disclosure of Personal Data
We may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Site
- Prevent or investigate possible wrongdoing in connection with the Site
- Protect the personal safety of Users of the Site or the public
- Protect against legal liability
Security of Personal Data
The security of your Personal Data is of utmost importance to us. While no method of transmission over the Internet or method of electronic storage is 100% secure, we strive to use all necessary technological means, such as encryption, to protect your Personal Data. Although we implement commercially acceptable measures to safeguard your information, we cannot guarantee its absolute security.
Your Rights under the GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
Under GDPR, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- 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.
- The right to data portability. You have the right to be provided with a copy of the information we have on you 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 relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
Your Rights under the CCPA
If you are a resident of California, you have the following rights:
- The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits you to request and obtain from us information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Site or its subsidiaries to a third-party for the third party’s direct marketing purposes.
- The right to know about your Personal Data. You have the right to request and obtain from us information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom we share Personal Data
- The specific pieces of Personal Data we collected about you
- The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer's rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell your Personal Information to anyone.
Service Providers
We may employ third party companies and individuals to facilitate our Site ("Service Providers"), to provide the Site on our behalf, to perform Site-related services or to assist us in analyzing how our Site is used.
These third parties may have access to Personal Data, or part of them, only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We do not use any third-party analytics services. We collect analytics data using our own software, subject to your consent. Please note that by creating an account and logging in to the Site, you grant the Site Operator the right to collect analytics data.
Payments
We may provide paid products and/or services within the Site. In that case, we use Third-Party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our Third-Party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Links to Other Sites
Our Site may contain links to other sites that are not operated by us. If you click on an external link, you will be directed to a third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children's Privacy
Our Site does not address anyone under the age of 18. 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. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. As such, Users may consult updates directly on the Site.
Contact Us
If you have any questions about this Privacy Policy, you can contact us by email at support(at)online-companions.com or by visiting this page on our website: Contact us.