Dichiarazione sulla Tutela della Privacy

Personal data you give to us

• When you create a customer account on our site

  When you create an account on our site, we require important details about you:
  • an email address;
  • a username;
  • a password.
  In order to give yourself more visibility and presence on our site, you can complete "My Profile" in your account settings. By doing so, you are free to give to us some additional information, such as:
  • a nickname;
  • your gender;
  • your age;
  • your location;
  • your sexual preferences;
  • your interests and hobbies;
  • your personality traits/character.

• When you contact our Billing & Customer Support

  We collect all information you choose to share with our Billing & Customer Support, like:
  • your personal e-mail;
  • the services, the Model or customer username associated with your request;
  • your comments or opinions about a Model;
  • your conversations with the Support Team.
  More generally, when you communicate with us in any other way, we will collect whatever information you provide us with.

• When you purchase credits

  When you purchase credits in order to participate on our site, depending on the payment method you choose, we may collect and process your identification information (first name, last name, country, ZIP code) and payment information.

Personal Information we get when you use our services

We collect certain information about you when you are using our services and navigate on our site.

Concretely, this means that, when you visit our site or use our services, even if you have not created an account or logged in, we collect certain information about you.

• Usage information

  We collect information about your activity on our site and about how you interact with the features of our site. Basically, we know:

  • your activity history on our site and the special features you used on the site, for example, if you voted in awards, sent a feedback after private chat, rated and/or put a Model in your list of favorites, made a Video/Voice Call to the Model, subscribed to Model’s MyStory, etc.;
  • the time you spend in private chat, who are the Models and categories of Models (for example, Asian girls, Latin women, black air) you watched;
  We also collect information about your communications with the Models, such as:
  • the username of the Model;
  • the time and date of your communications;
  • the type of communications (for example, a wall message, private chat, etc…).

• Content information

  For technical purpose, we store on our system content you create and/or post and/or transmit on/via our site (for example, pictures) and information about the content you create or provide.

  We also collect, any information you communicate to and/or share with Models on the site, such as the messages you send in private chat or during live shows.

  If you turn on your microphone in private chat, we may retain your audio feed for a limited period of 6 months in order to protect our rights or defend ourselves against any claims. Any such data retained shall be held in our secured records with restricted access. Please note that in case you turn on your camera in private chat, we never record or keep in any way your camera feed. We also do not allow our Models to record or capture your personal camera or audio feeds during private shows. Such action is prohibited on our site.

  If you use the Video/Voice Call feature on our site, we do not record or process your communication data with the Model. Your communication is private.

  We collect any other communication data such as telephone conversations, chat logs, text messages, faxes and letters you send to us.

• Log data and device information

  We automatically collect log data and information from or about your computer, phone, or other device you use to access our services or navigate on our site. This includes:

  • your IP address;
  • the date and time you logged into your account;
  • pages viewed;
  • types of features you use;
  • the hardware, software or internet browser you use;
  • information about your computer’s operating system, like application version;
  • your language settings;
  • your camera settings;
  • identifiers associated with cookies or other technologies that may uniquely identify your device or browser.
  If you are using a mobile device, we might also collect:
  • data that identifies your mobile device;
  • device-specific settings and characteristics;
  • location details;
  • app crashes and other system activity.

• Information collected by cookies and other technologies

  Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device.

  Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may negatively affect your use of the services on our site. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

Personal data we receive from third parties

• We collect information that users of the site, such as Guests, Members or Models provide about you in the course of the chat conversation or communication with our Billing and Support Team.
• The personal information we collect may also come from third parties, such as partners and service providers, to the site. These third parties assist us in maintaining data accuracy and providing and enhancing the services. We are also dealing with partner ad networks, which help us to promote our site. For example, we might receive information about your experiences and interactions from our partner ad networks.
• We are also managing an ad network and promotional tools ourselves and may receive information about your experiences and interactions with our ads and promotional tools published/used on third party or affiliated sites.

Personal data we collect from publically available sources

We collect publically available information about you only when it is necessary to prevent fraud and illegal activities on our site (for example, when we suspect that you are using a false or stolen credit card, when we witness child abuse cases, or pedophile activity, etc.).

This data may comprise publically available information you share on social media like Facebook, your blog and/or site, and any other public data available on the internet.

This information is always associated or combined with the data we collect through our site in order to finalize our investigation before reporting any fraud and illegal activities to authorities. We never use publically available data for any other purpose.

Special category of data

• Orientalcallgirls 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 when you watch live cam shows, 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 (e.g. Asian girls, White Ladies, Latin Women, etc…), 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.

Open your Member account and provide you with the services

Primarily, we use the personal data you give us when you create your account to open and administer your online account, to allow you to do a number of activities and to use features of our site. In addition, we use the information to allow you to purchase credits and benefit from paying and non-paying services.

Your account is also a way to exercise control over your personal data. In your account, you can manage your purchases, take advantage of special offers, and manage your account settings. You are in control of what you use to complete your profile, and can choose the information you wish to share with us.

We process this information given our legitimate interest in providing you the services you requested and creating your account.

If you fail to provide minimum details about you, the consequence will be that we will not be able to create an account and allow you to use our services.

Improve and promote our services

• We use your personal data for analytical and statistical purposes. We place great emphasis on the improvement of our services and on the enhancement of your experience as a Member or Guest.

  In order to better understand what your needs are and how we can improve our services, we compile the information you gave to us or that we collected about you when visiting pages on our site or while using our services, to detect general trends regarding the preferences/habits of our users. This helps us to generate statistical reports, for example, general statistics reports on our customers’ activity based on the categories of Models viewed, the countries, or the purchases.

  We are also using Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

  You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies by following this opt-out link.

• We also use your personal data for testing purposes, troubleshooting and improving the functionality and quality of our online entertainment services. Our main goal is to optimize our site and services to your needs, which makes them easier and more enjoyable to use.
• We share very limited characteristics about you with the Models registered on our site, so that they can deliver a service adapted to you. Please see point "With whom do we share your data?" to learn more.
• We use limited information to tailor our services for you. For example, when you visit and login on our site, we use your IP address to determine the country where you are from, and display our webpages in your language, so if you visit or login on our site from the United States, our site will automatically display content in English.
• We have affiliate programs through which webmasters or other third parties can help us to promote our sites, for example by creating reproduction of our well-known sites. Those sites can include only certain categories of Models.
  We share some limited information about you with the webmasters or other third parties participating to our programs, in order to help them to setup, maintain and optimize their marketing campaigns or promotional activities. This also allows them to track their income. Please see point "With whom do we share your data?" to learn more.
• Finally, please be aware that any information that you made public on our site, such as comments on the public wall of Models, may appear on search engines results, together with your username.

We process this information given our legitimate interest in developing and improving our site and our users’ experience, as well as to promote our services and our sites.

Customer relationship management and communication with you

• We provide Customer and Billing Support service 24 hours a day, 7 days a week. Sharing your personal details with our Customer and Billing Support Team allows us to respond to any question you might have about our services.

  All your communications with our Customer and Billing Support and all information you provide in the course of such communications, including any review or opinion about the services of a Model, are stored and reviewed so that we may respond to your request. We can also ensure this way full compliance of all users of our site with our terms and conditions.

  Some of the recorded communications with you are used for training purposes of our employees within the Customer and Billing Support, so that we can ensure customer service excellence.

  Finally, be aware that, when receiving a request or claim of a customer, our Customer and Billing Support Team can access all information you give to us and all usage information we collected about you. We want to make sure that our Customer and Billing Support has all information needed to appropriately and immediately respond to your request.

  Please note that the Customer and Billing Support may also communicate with you through emails or any other means, if appropriate.

• Please note that we may also communicate with you through emails or any other means, if appropriate, in order to inform you of certain changes regarding our site or of certain events, for example, when you successfully register on our site.

We process this information given our legitimate interest in improving our users’ experience and delivering appropriate customer services to you.

Payment

• Depending on the payment method you choose, we use your identification data and payment information to process transactions.
• The use of your personal information is necessary to perform the contract that you have with us. If you purchase credits, we will use your information to execute the payment and provide you with the services.

Ensure a safe and trustworthy environment

• Because we want to create and ensure a safe environment where you can peacefully enjoy our services, we use your personal data to detect and prevent fraud and other illegal activities on our site.
• We also use your data to detect potential breaches to the rules of our site. The rules of the site are explained in our terms and conditions.
• Finally, we use your personal information for security purposes and risk assessment, such as to authenticate you on our site and verify your identity.

We process this information given our legitimate interest in ensuring compliance with the rules of our site, fraud detection and prevention, as well as, information, system, network and cyber security.

Sending of customized marketing emails

This will allow you to be informed of new services/features or special offers.

If you accepted to receive marketing emails, we will use:

• the information you gave to us,
• the information we get about you when navigating on our site and using our services.

Based on this information, we will send you marketing emails tailored to your tastes or to certain of your characteristics (such as your country, the time you spend on the site, the amount of credit purchased).

The sending of marketing emails is based on your consent. However, be aware that you can very easily revoke such consent at any time in your “Consent Settings”. Revoking consent means you might miss out information on new services and special offers.

If you agreed to receive marketing emails, we may pseudonymize your email address and use it to generate statistical results. Such statistics are in the form of aggregated data and not personal information (for example, number of users per country who are receiving marketing communications).

Personalized content

We are using a software, which is learning about your behavior on our site (for example, when you are navigating on our site, viewing livestreams, looking at Models’ profiles or adding favorites to your lists) and able to predict the types of Models who could be of interest for you.

Thus, the webpage will adapt to your needs and you will quickly find content related to your preferences.

Whether you created an account or not, the software will display, at your next login or visit, a webpage based on your preferences from previous activity.

We rely on your consent to create a customized experience for you.

You may withdraw your consent at any time by opting-out in your Consent Settings or via email in case you are not a Member yet. Revoking your consent to content personalization may negatively affect your experience.

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data. For example, we retain your transaction information to maintain legally required accounting records.

We may also use your information to respond to requests of competent authorities or given our legitimate interest to establish, exercise or defend legal claims. We also use your data, if necessary, to investigate issues with the bank processing your payment or with a debt collector, in case of unpaid transactions, chargebacks or refunds.

We may combine your information with information lawfully obtained from other third party sources and use it for the above purposes.

With the Models

Your contract with us secures your ability to benefit from and purchase services relating to adult entertainment from Models.

• Regarding your profile information, by default, the only data element visible to the Model is your username.

  However, you may choose to share with a Model other information about you that you added to "My Profile" in your account settings, like your gender, age, location, interests, etc…; you may also connect your camera in private chat in order to visually communicate with the Model or just turn on your microphone. The Model is not allowed to record the visuals you provide.

  In any case, please keep in mind that you can manage the visibility of the information you added in "My Profile" by selecting the appropriate option in your privacy settings and therefore decide who can see the information you put on your profile.

  In case you decide to share additional content with the Models, such as pictures, please note that you are fully responsible of such sharing of information and that we cannot be held responsible of any disclosure you freely made.

• What else do we show about you to the Models?
  • As the Models are appearing on several sites at the same time (all our sites and affiliated sites), we show them from which site you are visiting from;
  • We show them a special icon, if you subscribed to their fan club;
  • We show them a special icon, if you added them in your favorites;
  • We show them a special icon, if you are a regular Member on a site and already purchased a certain number of credits, so that they know that you deserve extra attention and a good service. Please be aware that you can deactivate this feature, by contacting us to the email address or address indicated in point "How to contact us?".

With other users of the site and with the public

• When you chat with a Model in a free chat, other users of our site can see your username and the messages you write. In addition, other users can see in a free chat if you become a King of the Room and the number of credits you spent on surprises for said purpose.
• If you added information about yourself to “My Profile”, you may choose to disclose such information to other users, only to Models with whom you are in private chat or with no one, in your privacy settings. As indicated, please keep in mind that you can manage the visibility of the information you added in “My Profile” by selecting the appropriate option in your privacy settings and therefore decide who can see the information you put on your profile.
• In addition, if you post comments on a Model’s wall, other users will see your comments. Your comments and username may also be visible on the results of a search engine, like Google, for example. Therefore, if you do not want other users or the public in general to see your comments, please do not post comments on a Model’s wall.

When you initiate a private chat with a Model, apart from the Model, only limited staff within our organization can access on a "need to know" basis the communications and/or images (in case you turn on your webcam) you share. Be assured that other Guests or Members of Orientalcallgirls will not access any information about you from the moment you enter into a private chat.

Entities of our company’s group

We share your personal information with the following companies of our group based in Luxembourg, Hungary, and the US, as they are helping us to deliver the services to you:

• Jasmin IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Docler SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
• Docler Media LLC, 8000 Beverly Blvd, Los Angeles, CA 90048, USA;
• Escalion S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.

Webmasters participating to our affiliate programs

• We have affiliate programs through which webmasters and other third parties can help us to promote our sites, for example, by creating reproduction of our well-known sites. Those sites can include only certain categories of Models.

  Please be aware that by registering on one of our affiliated sites, you will also be considered as registered on our original sites, including notably livejasmin.com and others. You can therefore log in on these different sites with the same login credentials.

  Please note that, whether you registered directly on one of our sites or on one of our affiliated sites, we stay the controller of your personal data. For example, when you create an account or purchase credits, the personal information that you give for these purposes goes directly to us. The webmaster cannot see or access your personal data, and is only a technical operator and business partner helping us to promote our activity. In no event, you are a client/customer of a webmaster.

  We only share some limited information with them that however cannot lead to your direct identification. This minimum information helps them to setup, maintain and optimize their marketing campaigns or promotional activities. This also allows them to track their income. This information consists in your registration date, the site where you come from, register or purchase credits, your country, your username, the packages of credits bought (in case the webmaster was eligible for a commission) and certain device information (your operating system, your browser type and the type of device (e.g. tablet, mobile, desktop)).

  Please be aware that we will never share with them any information leading to your direct identification, for example, your real name, your address, your email address, your payment details or your IP address.

Service providers

We use carefully selected and trusted third parties, who act as service providers to our site.

We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our site, our third party service providers we are using may regularly change. Such entities mainly belong to the following areas: (a) business intelligence and analytics; (b) customer care; (c) marketing and sales; (d) fraud prevention.

Payment providers and financial institutions

When you purchase credits, depending on the payment method you choose, your payment may be processed by a third party bank or payment processor and you may share with this party certain details, as well as payment information for the purpose of completing a transaction.

You may receive transactional emails from this party confirming the order, including dispatch, possible refunds, and follow-up invitations to leave feedback for this party.

If you share information with third parties directly, this Privacy Policy does not govern the processing of your personal information by these third parties.

If you choose the payment method “Credit/Debit card”, your transaction will be handled by Escalion S.à r.l., which is part of our companies group and located in Luxembourg. For your information, you can find its privacy policy here.

When a chargeback is requested by you or by the holder of the credit card used to make the transaction, we have, in certain cases, to share some information about you and your use of the services with the processing bank.

We may furthermore share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.

Law enforcement agencies or governmental authorities

To the extent permitted by applicable laws, we may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our terms and conditions, and/or (d) protect our rights or defend ourselves against any claims.

Business transfers

Finally, please also note that your information may be transferred to another entity of our group following some internal reorganization or to another third party entity in case of sale, reorganization, restructuring, merger and/or acquisition or any other disposal whatsoever at group or company level resulting that part (more than 50%) or whole of our business (or related assets) is either directly or indirectly transferred or falling under control of a third party acquirer, provided the latter and/or the other group company in case of internal reorganization operates within same or similar line of business as ours and commits to comply with this Privacy Policy.

Data access and data portability

You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge through the "Data Download" section in your account settings.

Upon verification of your identity, your request will be sent to our Support Team.

If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period of time), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you the information.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). For this purpose, you can send an email to privacy@dditservices.com.

Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can send an email to privacy@dditservices.com.

Data retention and erasure

If you no longer want us to use your information, you can request that we erase your personal information and close your account. Request for account cancellation or closure will be considered as a request for erasure of your personal data. In such case, please select “Forget my Data” in the "Privacy Rights" section of your account settings.

Your request will be sent to our Support Team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time.

Please note that if you request the erasure of your personal information, we will retain your personal data for as long as we consider it necessary to:

• Comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that according to Luxembourg legislation financial related information shall be kept for a period of ten years.
• 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.

Right to object

• We process your data for a variety of reasons as explained in "Why do we process your personal data?". Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

  In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

  Please keep in mind that objecting to the use of your data might disable the use of your account.

• Please note that you may, at any time, ask us to stop sending you marketing emails by opting-out in your account settings.

Right to restriction of processing

You have the right to request that we hold your personal data in "limbo", while other challenges are resolved.

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.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority, (in particular in the Member State where you live, place of work or of an alleged infringement of the GDPR).