Política de Privacidad
1. Controller
[NOMBRE DE LA SOCIEDAD, S.L.] ("the Platform"), tax ID [NIF], registered office at [DOMICILIO]. Privacy contact: [EMAIL PRIVACIDAD]. Data Protection Officer (DPO): [EMAIL DPO / CONTACTO DPO].
2. Data processed, purposes and legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Account management and access (registration, session, age verification) | Email, alias, credentials (hash), age verification date, language/theme | Contract performance (art. 6.1.b); legal obligation to verify age (art. 6.1.c) |
| Publication of ads and content (Creators) | Alias, photos, videos, description, services, rates, public contact data; identity verification data (outcome only, no documents) | Contract (art. 6.1.b) + explicit consent for special category data (art. 9.2.a: data revealing sexual life) |
| Classified ads (registered advertisers and guests) | Ad contact data (phone, city/location), ad photos, email registered in the ad and editing key (stored hashed for guests), activation and expiry management | Contract (art. 6.1.b) + explicit consent for special category data; the guest's consent is given when checking the declaration box when submitting the ad |
| Buying credits, payments and withdrawals | Transaction data (amounts, dates, payment references, withdrawal IBAN), balance and operations ledger | Contract (art. 6.1.b) + legal accounting obligation (art. 6.1.c) |
| Messaging and interaction (favourites, likes, reviews, stories) | Message content and interactions | Contract + legitimate interest in safety and moderation; explicit consent for messages with special category data |
| Moderation, safety and fraud prevention | Activity logs, IP and technical access data, reports and moderation actions | Legitimate interest (art. 6.1.f) + legal obligation (art. 6.1.c) |
| Transactional and service email communications | Email, name | Contract; commercial communications only with consent (art. 6.1.a + LSSI art. 21) |
Special category data: use of the Platform involves data revealing sexual life (ads, attributes, content). It is processed with explicit consent and reinforced security; verification data is never published.
3. Age verification: data minimisation
Age verification (users) and identity verification (Creators) are carried out by specialised providers as data processors. The Platform only receives the outcome (adult / identity verified) and does not retain identity documents or verification images. See the Age Verification Policy.
4. Retention
- Account data and content: while the account is active; upon closure, personal data is deleted or anonymised (fiscal retention of payment records: invoices and transactions, 4-10 years under tax law).
- Activity and security logs: 12 months.
- Verification records (outcome, date): while the account lasts.
- Content unlocked by buyers: when the buyer closes their account, access is lost; Creators' rights are respected as per the Terms.
- Classified ads: ad data and photos are published while the ad is active (30 days, extendable by renewal); after expiry or deletion they are removed from the site and deleted 30 days later. Guests can delete their ad themselves with the ad number, email (or single-use link) and editing key.
5. Recipients and processors
- Technical providers: EU hosting ([HOSTING]), email, payment processors, age/KYC verification provider, CDN.
- Public authorities when legally required (judicial or police request).
- No personal data is transferred to third parties for advertising purposes. Transfers outside the EEA, if any, will have adequate safeguards (SCCs).
6. Rights
You can exercise your rights of access, rectification, erasure, portability, restriction and objection, and withdraw consent, by writing to [EMAIL PRIVACIDAD] from your account address (or from your dashboard). You may also file a complaint with the Spanish Data Protection Agency (www.aepd.es). Response time: 1 month.
7. Security and impact assessment
The Platform applies proportionate technical and organisational measures (TLS encryption, encrypted backups, access control, data segregation, activity logging) and holds a Data Protection Impact Assessment (DPIA) as it processes special category data at scale, with a designated DPO: [CONTACTO DPO].
8. Cookies
See the Cookies Policy.
Last updated: [FECHA]