StripChat - Privacy Policy

StripChat, herein referred to as the “Company”, “us”, “our”, or “we”, publishes and operates StripChat.com, the StripChat website, herein referred to as “the Website”.

Effective date: May 7th, 2020
Last modified: April 8, 2020

The Company is committed to protecting their users’ privacy and handling their personal data in a transparent, open manner. The personal data collected and processed will be different depending on how the Website is used.

The privacy policy:

gives an overview of how personal data is collected and processed by the Company and informs users about their rights under the EU’s GDPR (General Data Protection Regulations);
is meant for individuals who:
visit the Website (referred to as “Browsers”);
have created an account and registered as the Website’s members (referred to as “Members”);
have registered as models (referred to as “Models”).

Models, Members and Browsers must be eighteen (18) years and older, or must have reached the age of majority in their specific jurisdiction to be able to use this Website. All individuals who don’t meet this criteria are prohibited from viewing the contents of, accessing, or registering with the Website. We do not knowingly collect personal information from individuals younger than the age of eighteen (18); and

is directed at legal and/or natural persons who have been registered as studio operators (referred to as “Studio Operators”).

For the purpose of this privacy policy:

when “personal information” or “personal data” is referred to, we mean data which may identify or identifies a user and which might for example include your IP or email address;
when “processing” is referred to, we mean your personal data being handled by us, including collecting, protecting and storing your personal data; and
when “sensitive data” is referred to, we mean personal information which may reveal racial or ethnic origin, religious beliefs, political opinions, mental or physical health, trade union activities, biometric or genetic data, or sexual life.

1. Who are StripChat?

Technius is a limited liability company, registered in Cyprus

If you have any requests, comments or questions about this privacy policy or want to attain more details regarding the personal data we process, feel free to contact us by sending an email to help@StripChat.com.

2. How personal data is collected

Personal data is mainly obtained through any information users provide to us through the Website. Personal data is also sometimes shared with us, if a user for example logs in using an authentication system. The list below shows ways in which your personal data is collected:

when the Website is visited and/or used;
when the registration form is completed;
when an authentication system is used to log into the website;
when materials is posted or content uploaded;
when participating in chat sessions;
when taking part in surveys or reporting a problem with the Website; and/or
when we are contacted via post, email, or by using other means of communication.

3. Failing to provide personal data to StripChat

Models

When personal data has to be collected and processed to enable an individual to use the Website as a Model and the data is not provided when requested, we won’t be able to give you final approval to use the Website as a Model or, if such approval was provided previously, such approval may be withdrawn and the operation of the account suspended.

Members & Browsers

Personal data needs to be collected and processed for us to be able to provide you with services and failure to provide the data when requested means we will not be able to provide you with access to the services we offer and/or the Website. This will result in your access to the Website being suspended or, in the case of Members, restricting the operation of their account and the services we provide, and/or preventing access to non-public areas of the Website.

4. Personal data collected and processed

Different categories of personal data is collected depending on the level of interaction with the Website. The collection and processing of information is limited to information required to achieve one or more legitimate reasons as identified in the privacy policy.

Personal data collected and processed from Browsers

Cookies, including web beacons. To learn more about the collection of data via cookies, please check our Cookies Policy.
Technical Data, including an IP (Internet Protocol) address and related country, browser type and version, browser plug-in types and versions, location and time zone setting, mobile phone network information, smart device information, operating system and platform and other technology used by devices used to access the Website;
User Submitted Data, including data collected for a specific reason, for example a survey or contest;
Usage Data, including communication preferences and information about how the Website is used, including services that have been viewed or searched for, download errors, page response times, number and length of visits and page interaction information (such as mouse-overs, clicks and scrolling) as well as links used or clicked on. For more information on the use of cookies and similar technology, please visit our Cookies Policy;
Consent, including any permission, consent or preference that has been given to the Website.
Correspondence and Communications, including any correspondence between us and you, and any other communication between you and other users of the Website, including live chats, emails and customer service requests.

Personal data collected and processed from Members

All personal data collected from Browsers as described in the paragraph above;
Usage Data, including data about which products Members buy and use, all orders placed on the Website and all measurements and metrics pertaining to campaigns, orders, advertisements, bids and any other activities on the Website.
Contact and Identity Data, including username or related identifier, email address, password and full name. Photos or videos uploaded to profiles may also be collected;
Transactional Information, including fund transfers, billing address and direct debit data;
User Submitted Data, including data submitted for a specific function, for example usernames and passwords, preferences, interests, survey and feedback responses, and any images, text, blog posts, videos, comments on forums or other content or media Members upload to the Website.
Marketing Data, including Member’s preferences in receiving marketing from us, third-parties and our affiliates.

Personal data collected and processed from Models

All personal data collected from Members, as described in the paragraph above;
Contact and Identity Data, including pseudonym, address, date of birth, identification number like ID or passport number and a photo of the Model holding their identification document.
Data generated during Website use, including performer ID and screenshots taken from video streams.
Data Submitted by User, including your performance, likeness, acts, play and poses, instrumental, musical, or sound effects and any dialogues with other users.

Personal data collected and processed from Studio Owners that are natural persons

All personal data we collect from Members, as described in the paragraph above;
Identity Data, including the name of the owner of a Studio Operator which is a corporate entity or other of the Studio Operator’ officers which may be disclosed to us. For Studio Operators that are natural persons, we may also collect their ID document, but only if it was uploaded voluntarily to the Studio Operator’s account.

Aggregated data such as demographic or statistical data may also be collected, used and shared for customizing marketing efforts or for use by the Website. Aggregated data that is derived from personal data is not considered personal data as this data does not reveal a person’s identity, directly or indirectly. Usage Data may for example be aggregated to calculate the percentage of users using or accessing a particular Website feature, to generate user statistics, to publish visitor demographics, or to calculate the number of ad impressions served or clicked. If aggregated data is combined or connected with personal data in such as way that it can directly or indirectly identify a specific user, the combined data will be treated as personal data which will be treated in accordance with this privacy policy.

5. Sensitive data

Sensitive data from Browsers or Members may be processed in relation to their sexual orientation or ethnic origin, provided that their explicit consent to do so has been obtained first. Although sexual orientation will never be requested, such information may however be inferred from Website use.

For Models, sensitive data is processed relating to health, or ethnic or racial origin, provided that their explicit consent to do so has been obtained first. Please note if providing such consent is refused, or if consent is withdraw to us collecting and processing such data, you might not be able to use, or continue using, your Website account.

6. Collecting personal data automatically

Technical Data about equipment, browsing actions and patterns is automatically collected as users interact with and navigate through the Website. This data is collected by using cookies and similar technologies. We may also use these technologies to collect information about your online activities across third-party websites. To learn more about the collection of data via cookies, please check our Cookies Policy.

7. Why personal data is needed and how it is used

Information will only be used and shared when necessary to provide lawful services in line with this privacy policy. The description below will enable you to understand fully how personal information may be used.

Personal data will mostly be used as follows:

when required for our legitimate interests (or a third party’s) and those interests are not overridden by your fundamental rights and interests;
when our services are to be performed as necessary in accordance with the Terms of Use of the Website;
when consent has been given;
when legal obligations need to be complied with.

These circumstances are describe in further detail below.

Legitimate interest
1. Customization of Member’s content

Personal data may be collected and processed where it is needed to perform analysis and research of a Member’s use of, or interest in, the Website services and/or content, so that advertising and content may be developed, displayed and tailored to your interests on the Website.

Analytics

Personal data may be collected and processed where it is needed to determine whether Website users are unique, or whether the Website is used by the same users on multiple occasions, and to keep track of aggregate metrics like demographic patterns, pages viewed and total number of visitors.

Security and Functionality

Personal data may be collected and processed where it is needed to administer our relationship with users, manage accounts and provide users with account support, including renewal and expiration notices, and inform users about Website changes that may affect the services they provide.

Other legitimate interests

Apart from the above, data may be processed to the extent needed for our business for:

protecting legal interests and rights, including preparing a defense in litigation and legal claims;
developing new Website services and analyzing and targeting new markets;
ensuring network information security, including monitoring access by Browsers and Members to our information technology to prevent cyber-attacks, unauthorized Website use, and to detect and prevent crime;
monitoring, maintaining and improving internal business processes, data and information, communication and technology services and solutions;
monitoring the effectiveness and performance of Website services;
sending relevant marketing information, including details of other services we provide which we deem to be of interest to Members of the Website;
assessing customer service quality.
Performance of Services
1. Service Provision

Personal data may be collected and processed where it is needed to present the Website and its contents to users, including interactive features on the Website and to provide users with services and information requested by them.

Note: Users may not be able to operate their account and/or receive the services provided to Members if they don’t agree to provide the requested information.

Management of Members

Personal data may be collected and processed where it is needed to manage Members’ accounts, and to provide notices and customer support to Members about their subscription and account, including renewal and expiration notices, and inform them about any changes to the Website or any services offered or provided.

Management of Studio Operators and Models

Personal data may be collected and processed where it is needed to administer our relationship with users, manage their accounts and provide customer support to Studio Operators and Models, including renewal and expiration notices, and inform them about any changes to the Website or any services offered or provided.

Consent has been provided

Consent will be asked from Browsers when we want to provide marketing information to them about services which we deem may be of benefit and of interest to them.

Consent will be asked from Members and Models before collecting sensitive data as described in this privacy policy.

Although consent may be revoked at any time, any personal data processed before the receipt of the revocation will not be affected.

Legal obligation compliance

When users visit and/or use and/or register on the Website, and throughout the mutual relationship, certain regulatory and legal obligations need to be complied with which may involve personal data being processed. This may include:

performing checks and complying with laws related to fraud;
identifying Terms of Use infringements;
managing contentious regulatory litigation, investigations and matters.

8. Who personal data is shared with

As per our policy, personal data will not be shared in ways not related to those described in this privacy policy, without providing our users with the opportunity to opt out or object to these unrelated uses. Personal data or information regarding the use of the Website or services may however be disclosed to third parties for any reason set out herein, or when we are required to do so by law, or when we are authorized to do so under our statutory and contractual obligations. When personal data is disclosed to service providers, they will be bound by a contract to comply with their obligations in terms of GDPR. Under the conditions mentioned above, personal data may for instance be received by:

service providers such as Webbilling, CentroBill, SegPay, and Epoch;
corporate group members which manage partner websites like www.StripChat.com, for the purposes described in this privacy policy and to enable users to access specific features;
purchasers or other legal beneficiaries in the case of a divestiture, merger, reorganization, restructuring, dissolution or other transfer or sale of all or some of our assets, whether as part of liquidation, bankruptcy, or similar proceeding, or as a going concern, in which personal information held about the Website’s Studio Operators, Models, Members, and Browsers is among the assets transferred. Should such a transfer or sale happen, reasonable efforts will be used to ensure that the entity to which personal data is transferred will use it in a way that is in line with this privacy policy;
regulatory and governmental bodies, including law enforcement agencies, relating to investigations, proceedings or enquiries by these parties or to enable us to comply with our regulatory and legal requirements. The right to disclose all and any information to law enforcement is specifically reserved in cases where a crime is suspected or committed, or when the Company is compelled to do so by lawful administrative, civil or criminal processes, subpoenas, discovery requests, writs or court orders;
other professional consultants, including legal.

Aggregated user information and information that doesn’t identify an individual may be disclosed without restriction. Aggregated information may also be shared with third-parties to conduct general business analysis. As this information doesn’t contain personal data, it may be used to develop new services and content that users may find of interest.

Personal data will never be sold to third parties.

9. Profiles of Members and Models

All information provided by Members and Models directly to the Website when an account is created is public and may be viewed by other Website Browsers and Members, unless specified otherwise. Even if profiles of Members and Models don’t contain personal information, it is possible they may be identified by others via other information on the profiles. Members and Models should therefore be aware that they control the information uploaded to the Website and what is displayed on profiles and are thus responsible for all consequences resulting from such information.

10. Personal data security

Appropriate security measures, including procedural, electronic and physical measures are taken to safeguard personal data from unauthorized disclosure and access. Only authorized employees are for example allowed access to personal data, and they may only do so for legitimate business reasons. We also encrypt the transmissions of personal data between our system and yours, and firewalls are used to prevent unauthorized persons from accessing personal data. It should however be noted that security risks associated with the transmission and storage of personal data can’t be fully eliminated as there is no guarantee that any security measures will in fact prevent hackers from obtaining this information illegally.

Users are responsible for maintaining the secrecy of their account information and unique password at all times. The Company is not responsible for any security measures or privacy settings contained on the Website being circumvented.

11. Transfer of information

As we use several external third parties located outside the European Economic Area (“EEA”), processing of personal data involves data being transferred outside the EEA.

When data is transferred outside the EEA, a similar degree of protection is implemented to ensure at least one of the following safeguards is in place:

Personal data is transferred to countries that are deemed by the European Commission to provide adequate protection for personal data.
When service providers outside the EEA are used, we use European Commission approved contracts that provide personal data the same degree of protection as applied in the European Union.
When providers based in the US are used, data is transferred only if they are part of the Privacy Shield, which means they are required to provide similar personal data protection as is shared between the US and the European Union.

Personal data may also be transferred to a party outside the EEA in rare occasions where the user has given us explicit consent to do so, or where such a transfer is required to provide our services.

12. Information used for marketing

Personal data may be processed to inform users about current and/or future services that may interest them by sending sporadic announcements with details of current programs and/or new services.

Users may object at any time to their personal data being processed for marketing purposes by sending an email to help@StripChat.com, or by clicking on the opt-out link contained in all marketing emails being sent.

Personal data only be used to promote services if explicit consent to do so has been given, or in specific cases where we determine that it is in our legitimate interest to do so. Marketing communications may also occasionally be sent by our affiliates, but only if explicit consent has been given for receiving such communications.

Even if users have indicated that they wish to not receive marketing information, system notices and other information specifically related to accounts will still be sent from time to time.

13. Duration of keeping personal data

Personal data will only be kept for as long as is required to fulfill the purposes it was collected for, including for satisfying any reporting, accounting or legal requirements. Personal data may be retained for longer periods to resolve complaints or if there is a reasonably prospect of litigation.

The appropriate retention period for personal data is determined by considering the sensitivity, nature and amount of personal data, the potential risk of harm from unauthorized disclosure or use of personal data, the purposes for which personal data is processed and whether those purposes can be achieved through other means, and the legal requirements applicable.

When personal data no longer needs to be processed for purposes as described in this privacy policy, all personal data will be deleted from our systems. Personal data may however be kept for longer if it cannot be deleted for technical, regulatory or legal reasons. If this is done, we will ensure privacy is protected and that the data is used only for those purposes.

To resolve questions about our data retention policies, we may be contacted by sending an email to help@StripChat.com.

14. Data protection rights

To ensure users are aware of their rights as it relates to the personal data we process, those rights and the circumstances in which they apply are described in detail below.

Access: Users may access or obtain a copy of personal data held by us to check the legality of us processing it.
Modification: Users have a right to request that inaccurate personal information be corrected if they believe that any of the information being held is incomplete or inaccurate.
Deletion: Users may request that personal information be deleted if they believe that:
the information no longer needs to be processed for the purposes for which it was provided;
permission to process personal information has been requested and users want to withdraw that consent;
information is not used in a lawful manner.
Right to object: Users have the right to object to their personal data being processing where the Company relies on a legitimate interest and there is something about the user’s particular situation which makes them want to object to processing on these grounds. If the right to object is exercised, personal data will no longer be processed unless the Company is able to demonstrate compelling legitimate grounds for the processing which overrides the user’s freedom, rights and or interests for establishing, exercising and defending legal claims.

Users also have the right to object where personal data is being processed for direct marketing purposes. This includes profiling that relates to direct marketing.

If users object to processing for the purpose of direct marketing, personal data will no longer be processed for such purposes.

Processing of personal data may be restricted or ceased altogether where requested, or personal data may be deleted, depending on the circumstances. It should be noted that if processing of personal data is objected to, the services provided may have to be suspended.

Restrictions: Users have the right to request that processing of personal data be restricted. Restriction of personal data processing may be requested if:
data has been used unlawfully but should not be deleted; or
data is inaccurate; or
a request to stop using personal data has been submitted, but we need to confirm if we have legitimate grounds to use the personal data; or
data is not relevant anymore, but needs to be kept for possible legal claims.

It should be noted that if processing of personal data should be restricted, the services provided may have to be suspended.

Right to portability: Where permission has been requested to process personal data or information has been provided for the purpose of entering into a contract with us, users have the right to receive the personal data provided by them in a portable format. Users may also request that this be provided directly to a third party, if this is technically feasible. We take no responsibility for a third party’s use of account information, as this will be governed by their agreement with you and any privacy statement they provide.

If the use of personal data has been consented to, this consent may be withdrawn at any time. It should be noted that if consent is withdrawn, the services provided may have to be suspended.

It should be noted that certain requests for deletion of personal data will necessitate the removal of your account as a Member and/or Model and/or Studio Operator as the provision of these accounts is inextricably linked to the use of specific personal data. Additional information may also be required to verify a user’s authority to make the request and to honor the request.

Rights may be exercised, or questions posed regarding the use of personal data by sending an email to help@StripChat.com or by post at StripChat.

15. Accessing or modifying personal data

We are dedicated to protect your data and want to be clear about which information we collect, to help you make good privacy choices. You may:

select whether your profile and/or uploaded content is visible only to friends, or only to Members and/or Models, or to everyone by changing your profile settings;
access and/or modify information provided during registration for your profile;
control who information is disclosed to through PMs, comments, or social networks and on the Website;
Models may choose whether the albums, videos and photos they upload are visible to friends only, or to Members and/or Models or to everyone by changing their profile settings;
block cookies by deactivating or activating the related cookies on the browser. It should be noted that disabling all cookies may limit access to part or all of the Website.

16. Communications

Questions about our information-handling practices or this privacy policy can be sent via email to help@StripChat.com or by post to StripChat.

17. Complaints

Complaint about how personal data is used by the Company may be lodged via email to help@StripChat.com or by post to StripChat.

Complaints are investigated upon receipt and responded to within a reasonable time.

Users may also lodge complaints with the data protection supervisory authority of their country, providing that the country is located within the EEA, or is a Member State of the EU.

18. Minors

The Website is not aimed at individuals younger than eighteen (18) or the applicable majority age in the jurisdiction from which users access the Website, and the Company does not collect minors’ personal data knowingly. Parents that become aware that their child has provided personal data to us should contact us via email at help@StripChat.com. We will remove a minor’s information and terminate their account immediately if we become aware that a minor’s personal data has been provided.

19. Links to third-party websites

The Website may link to third-party applications, plug-ins and websites. When a user clicks on those links or enables those connections, it may allow third parties to share or collect personal data. As we don’t control those third-party websites, we are not responsible for their privacy policies. Responsibility is specifically disclaimed for their terms of use, privacy practices and content, and we don’t endorse or represent their thoroughness, content or accuracy. When leaving the Website, users are encouraged to read the privacy policy of other websites visited.

20. Privacy policy changes

The company reserves the right to modify, amend, revise, and/or update this privacy policy at any time to reflect any changes to the manner in which personal data is processed or changed legal requirements.

Although users will be notified when major changes to this privacy policy are made, they should periodically review the latest version published at StripChat.com/privacy to be aware of changes. The latest privacy policy version’s date will be shown at the top of the policy webpage.

21. Cookies

The website uses small files called cookies to make it operate better to improve the user experience as briefly mentioned in this privacy policy.