Privacy & Behavior
the do's and don't's as laid down by Pandemos
Last modified: March 11, 2019
CC Media Network Ltd (the “Company”, “we”, “us”, “our”) operates this website (the “Website”) and in the context of the EU’s General Data Protection Regulation (the “GDPR”) is the responsible data controller with regards to the processing of personal data in connection with the Website. The Company is registered in the British Virgin Islands with company number 1804119, and its registered address is Woodbourne Hall, Romasco Place, Road Town, Tortola, VG1110, British Virgin Islands.
2. Personal Data That We Process
We collect, use, share, transfer and store your personal data as a result of your access to and use of the Website. Personal data means any information relating to an identified or identifiable natural person. It does not include information that has been anonymized or pseudonymized.
Information You Give to Us
When you create an account on our site you provide us with some or all of the following information:
- Email address
- User name
- Date of birth
- Phone number
Information We Collect When You Use Our Services
When you log in to your account on the Website and use the services provided by the Website we will collect information resulting from your activity:
- Your IP address (and any proxy IP service you utilize)
- Your browser settings and monitor size
- Your device type, operating system, and details of other software running on your device, and the time zone your device is set to
- Identifiers associated with cookies or other technologies that may uniquely identify your device
- If applicable, the affiliate or referrer that introduced you to the Website
- The dates and times of your visits
- The pages of the Website you visit
- The list of your favorite chathosts (as specified by you)
- The chathosts you have video sessions with and all data relating to those video sessions, including the time, duration, billing rate and cost of those video sessions, and the rating you give the chathost
- Any Gifts (using the Gift functionality on the Website) that you send to chathosts
- All conversations you have using text chat
- Feedback you leave for chathosts
- Notes chathosts make about you within their own accounts on the Website
- Notes made on your account by us
- Emails you send using the Website’s internal email system, including any documents or pictures you attach to those emails
- Posts you make to the Website’s forum pages and community chat page
- Emails you send to our customer service team
- Your payment card information – this information is encrypted and sent to our payment processors and we retain only the last four digits of your payment card number and its expiry date
- Full details of your billing transactions from all video sessions and Gift Box top-ups, as well as card pre-authorization checks and any other ad hoc charges
- The status of the credit cards you have registered to use on your account
- The reasons you give us for closing your account
Information We Collect From Third Parties
We collect information that users of the Website, such as other members, guests and chathosts, provide about you when they use text chat, the Website’s internal email system, the forums and community chat pages, and when they contact our customer support team.
Information We Collect from Publicly-Available Sources
We collect publicly available information about you when it’s necessary to prevent fraud and other illegal activities on the Website. The data may comprise publicly available information you share on social media websites, such as Facebook, Instagram, Twitter and LinkedIn, on your employer’s or your own business’s website, on any blog you maintain, and any other publicly available data on the internet.
Special Category Of Information
Due to the nature of the services provided by the Website when you are using the Website’s services you will provide us with certain information about your sex life and your sexual preferences.
When you have video sessions with chathosts we collect the details of the chathost, including which category within which the chathost has chosen to operate.
We collect all of the information you include when you use any of the text-based communication methods available to you on the Website. These include messages you send to chathosts directly, posts you make in the forums and in community chat, information in emails you send using the Website’s internal email system, feedback you leave about chathosts, and emails you send to our customer service team.
We collect the all the information in any notes made by chathosts about you within their own accounts on the Website.
We understand that this information may not accurately reflect your actual life outside of the Website. It may reflect only the role or roles you choose to play when using the Website. However, in order to provide you with the highest level of data protection we treat this data as a special data category.
We treat all your information, including the information that falls into the special category as described, absolutely confidentially and subject to the highest levels of IT security standards. We constantly review and assess our IT controls and security and update and upgrade them as necessary.
You always have the choice regarding the collection of your data, including your data that falls into the special category. If you do not consent to us collecting your data then you can tell us at any time. However, please note that refusing to provide or revoking your consent to allow such information to be collected by us, or requesting deletion of such information, may mean that you will not be able to log in to your account on the Website and you will not be able to use any of the services provided by the Website.
3. What We Use Your Information For
We process your information based on our legitimate interest in providing you the services you have requested and on the legal basis created when you contract with us by explicitly accepting our terms and conditions each time you access the Website and each time you use the fee-based services offered by the Website.
Primarily we use your personal data to open and administer your account on the Website, to allow you to use the services and features provided by the Website, including purchasing services that are fee-based, to allow you to communicate with other users of the Website, and to provide you with high-quality customer service.
We also use your information to improve and promote our services, for analytical and statistical purposes, and for testing and trouble-shooting to enhance the experience of all the users of the Website.
In order to better understand what your needs are and how we can improve our services we compile the information to detect general trends regarding the preferences and habits of our users. This helps us generate statistical reports.
Please be aware that any information you make publicly available on the Website, such as through the forums, including individual chathost forums, and community chat, may as a result appear on third party websites and search engines together with your user name.
We use your personal data, including your payment information, to process your billing transactions, to maintain our accounting, tax and legal records, and for the purposes of audit.
We will use your data to investigate and resolve issues with you, our payment processors and your payment card issuer (which may be your regular bank) in respect of any payment or charging disputes, chargebacks initiated by you with which we disagree, or any amounts owed by you. This may involve sharing your data with lawyers, debt collection agencies and other professionals we deem it necessary to involve in order to resolve any situations that arise.
We use your personal data to help us maintain a friendly, trustworthy and safe environment on our Website. We will use your data, if it becomes necessary, to investigate issues raised by you or other users who have interacted with you, or to resolve any disputes between you and us or between you and any other users.
We will use your personal data to prevent, detect and resolve fraud, infringement of intellectual property rights, or any other illegal activities on the Website, or any breaches of our rules, which are explained in full detail in our terms and conditions.
We use your personal data for security purposes and risk assessment, such as to authenticate you on the Website, to verify your identity, and to protect your account and your information.
If you have accepted to receive one or more categories of marketing emails from us we will use your information in deciding what marketing emails to send you. We will send you marketing emails tailored to your personal data.
You can opt out of all marketing emails at any time by emailing our customer support team or by logging into your account and visiting the section called Manage Email Subscriptions.
We use software to learn about your activity on the Website to help us predict the types of chathosts who might be of interest to you and you will therefore see pages that are adapted to your anticipated preferences.
4. How Do We Protect Your Personal Data
We implement and operate the highest standard of security measures and IT controls to provide the maximum protection possible for your personal information against unauthorized access, modification, disclosure or deletion.
We actively implement data loss prevention systems against leakage, theft, data breach and other hacking in order to ensure that the Website and the related IT infrastructure are updated against the latest network security vulnerabilities. We periodically subject our IT systems and security measures to intensive penetration testing. Our Website incorporates industry-standard security technologies, such as SSL encryption, secure network topology (including intrusion prevention and firewalls), and authentication and access control, in order to ensure the maximum protection for all users and the safekeeping of personal information.
We restrict access to your personal information to employees, contractors and agents who need to know that information in order to process it and who are subject to strict contractual confidentiality obligations.
You are responsible for maintaining the secrecy of your password and other account information at all times. If you do not take such responsibility we cannot be responsible for any of your personal information that becomes available to anyone else as a result.
5. Who We Share Your Data With
Chathosts are able to see your user name but we do not share any other information about you. Of course, chathosts can see any information you provide during text chats with them, or post on the forums or in community chat, or send to them via our internal email system.
When you are in a chathost’s room and you’re not in a private One2One session with the chathost then other Website users can see your user name and any text messages you write.
When you post on forums, including individual chathost forums, and in community chat, other Website users can see your user name and any text messages you write (except for private messages in community chat, when only the recipient can see your message).
We share your personal information with other companies in our group of companies as they help deliver the services associated with your use of the Website, including payment processing, customer service, IT services, security, compliance, and analytics.
We have an affiliate program to allow webmasters and other third parties to introduce new users to our Website. We share some limited information with such webmasters and other third parties in order to help them set up, maintain and optimize their promotional activities and to allow them to track the income they generate from their introductions of new users to the Website.
We share the information necessary to collect payments from you with third party payment providers. If you do a chargeback with which we disagree then we may share your personal information with your card issuer (which may be your regular bank).
We will share information with our payment processors and any other financial institutions where we deem it necessary for fraud prevention or to prevent other illegal activity.
We share your information to the extent necessary to meet our financial, legal, tax and audit obligations and requirements.
We will share your personal information with law enforcement agencies if that’s reasonably necessary to comply with our legal obligations, to respond to information requests in respect of fraud and other illegal activity, to enforce our terms and conditions, and to protect our rights and defends ourselves against any claims.
6. Transfers Of Your Personal Information To Other Countries
The Company is located outside of the EU but if you are located within the EU then the Company is obligated to comply with the GDPR with respect to your personal information.
By using the Website you consent to the transfer of your information to any country in which we, members of our corporate group, and our service providers are located.
7. What Are Your Rights Regarding Your Personal Data?
All your rights as described below can be exercised by emailing our customer support team at firstname.lastname@example.org. There is usually no charge made by us for dealing with your requests. However, if you make an unreasonable or excessive number of requests then we reserve the right to charge a reasonable administration fee.
We will deal with your requests within 60 days, and usually much more quickly.
Because we are extremely careful with your personal data and take the protection of your information very seriously we will need to verify your identity properly before we comply with any request from you, especially a request for you to receive copies of your personal information or for your information to be sent to another data controller. This identification process will probably include sending us a copy of your photo ID (usually your passport or driving license) and a photograph of you holding your photo ID up against your face. We may also ask for photographs of your payment cards that you are using or have used on the Website, and we reserve the right to ask for any other information required to identify you if we are in any doubt as to your identity.
You have the right to access your personal information that we hold. You have the right to have your personal data submitted to you by us in a structured, commonly-used and machine-readable format (where reasonably technically feasible), and you have the right to ask us to submit your personal data to another data controller.
You have the right to request that we correct any inaccuracies in your personal data.
We generally retain your personal information only for as long as is necessary for the performance of the contract between you and us and to comply with our legal, financial and tax obligations. If you no longer want us to hold your personal information you can ask us to delete it. If we delete all of your data then you will no longer be able to have an account on the Website and you will not be able to access the Website and its services in future. In such cases we retain enough information to be able to identify you in order to prevent you from opening new accounts on the Website. We will also need to retain enough information to comply with our legal, financial and tax obligations.
If you want only some parts of your personal information deleted then although your account will not be available to you anymore we may be able to allow you to open a new account on the Website. Our customer service team will be able to discuss this further with you.
We process your information for a number of reasons as described above. Applicable laws entitle you to require us not to process your personal information for certain specific purposes where such processing is based on a 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 your request – for example, if we have legitimate grounds, such as a legal basis, to continue such processing or if we have to establish, exercise or defend legal claims. Also, objecting to the processing of your data will likely mean that we will have to close your account on the Website and prevent you from opening new accounts in future.
You can ask us at any time to stop sending you marketing emails or you can log in to your account on the Website and adjust your email marketing preferences.
You can ask us to put a hold on the use of your personal data in the following situations:
- If you dispute the accuracy of the personal data we hold about you;
- If you object to data processing based on legitimate interests;
- If you consider that the data processing in unlawful but you object to erasure and request restriction instead; or
- We have no further need for your data but you require us to retain it so you can establish, exercise or defend legal claims
Despite your request we may still continue the processing or your personal data if we have a legal basis for processing or to establish, exercise or defend legal claims.
If you are located in the EU and consider that our processing of your personal data infringes any applicable data protection laws you have the right to lodge a complaint with a supervisory authority.
To the extent permitted by applicable law such changes will be applicable from the time they are published on the Website, unless we specify a different applicable date.
9. How To Contact Us
If you prefer to send mail then please address it to:
CC Media Network Ltd
British Virgin Islands