Last Modified: August 17th, 2023
Aylo Social Ltd (hereinafter “we”, “us”, or “our”) operates the website mydirtyhobby.com (hereinafter “MyDirtyHobby” or the “Website”) and is the controller of the information collected or provided via this Website.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
- on this Website,
- in e-mail, text and other communications between you and this Website,
- through mobile applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website, or
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified by (“Personal Information”). It does not include data that has been anonymized or pseudonymized.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Identifiers and Biometric Information. When registering for certain features of the Website we collect identifiers you submit to us, allowing us to verify your identity. We also collect biometric information in order to verify the authenticity of the identifiers you provide to us while registering for such services, as further explained in the section “Biometric Information” below.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased or received from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our Website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Information you provide through support channels. You may provide information or content to us through electronic correspondence when attempting to reach our support staff. When you engage with support staff, in addition to your account information, we may ask you to provide additional information about your issue/request, which may include, but not be limited to, information about your hardware/software, additional account information, or we may ask you to provide screenshots.
We may also collect, use, and share your data to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. We may also aggregate your usage data to calculate the percentage of users accessing a specific Website feature. For example, we may use your data to generate statistics about our users, to calculate the percentage of users accessing a specific Website feature, to calculate ad impressions served or clicked on, or to publish visitor demographics.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, or information about your health). However, depending on how you use our Website and services, your Personal Information may include biometric information, or information that allows drawing conclusions about your sex life or sexual orientation (“Sensitive Personal Information”). The collection, use and disclosure of such Sensitive Personal Information is necessary to provide some of our service to you.
We cooperate with third-party service providers to help verify your identity and age and to check the authenticity of any identification documents you provide using facial recognition technology. The facial recognition technology creates a mathematical representation of your face and detects facial features from the live scan of your face, your selfie, and the government-issued ID you submit or have previously submitted to us. This mathematical representation, which is considered biometric information/identifier/data under the laws of certain states and countries, is not shared by our service providers with us, and is deleted by our service providers seven (7) days after its creation. Information derived from this mathematical representation, which may be considered biometric information/identifier/data under the laws of certain states and countries is shared by our service providers with us and is subsequently deleted by us, as further described below.
Your biometric information will be used to:
- verify you are a real, live person and to prevent the use of methods which would allow a user to identify as someone else.
- match your selfie with your government-issued ID which you will submit or have previously submitted to us to make sure that nobody is impersonating you.
- help confirm your age.
We may disclose your biometric information, face scan, selfie, and government-issued ID (including any government-issued ID or selfie you previously submitted to us) within members of our corporate group, and with third-party service providers. These entities may be located in jurisdictions that do not offer the same level of data protection as your jurisdiction. We, and any of these entities, may perform facial recognition and collect your biometric information from your face scan, selfie, and any government-issued ID, and use your biometric information for the above purposes.
Biometric information shared by our service providers with us will be stored for as long as you maintain an account on the Website. We will delete your biometric information within three (3) years of you deleting your account of the Website, or withdrawing your consent, subject to any legal obligations we may have.
You will be asked to provide your consent to biometric processing, which you may withdraw your consent to at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
How is Your Personal Information Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. Information that you provide when carrying out search queries on our Website or by filling in forms on our Website, in particular at the time of registering to use our Website, subscribing to our service, posting material, taking part in surveys, entering a contest or promotion sponsored by us, when reporting a problem with our Website. or requesting further services.
- Third parties or publicly available sources. We may receive personal data about you from various third parties, for example, other websites controlled by us or members of our corporate group, our business partners or other third parties and public sources.
Information Collected Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information.
We also use these technologies to collect information about your online activities over time and across third-party websites or other online services (“interest-based advertising”). See “Choices About How We Collect, Use and Disclose Your Personal Information” below for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). Cookies are small text files that are stored in your web
browser or downloaded to your device when you visit a website. Cookies are then sent back to the
originating website on each subsequent visit, or to another website that recognizes that cookie, and
allow a website to recognize a user’s device.
We currently use the following types of cookies:
- Cookies that are strictly necessary: These are cookies that are required for the operation of our Website. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.
- Analytical cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore our Website. These cookies help us to improve our Website, for example by ensuring that all users are able to find what they are looking for easily.
- Functionality cookies: These cookies are not essential but help us to personalize and enhance your online experience on our Website. This type of cookies allows us to recognize you when you return to our Website and to remember, for example, your choice of language.
- Targeting cookies: These cookies record the visit of a user on our Website, the pages a user has visited and the links a user has followed in order to enable us to make our Website more relevant to the users' interests.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Collect, Use and Disclose Your Personal Information”.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags, single-pixel gifs and web bugs) that are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in an email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages or opened an e-mail, to understand usage patterns and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Collect, Use and Disclose Your Personal Information”.
How We Use Your Personal Data
We will only use your personal data when the applicable local law allows us to. Most commonly, we will use your personal data in the following circumstances:
- For purposes of providing the services, customer management and functionality and security as is necessary to perform the services provided to you under our term and conditions and any other contract that you have with us.
- Biometric information and identifiers are processed based upon your consent for us to do so.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purposes for Which We Use Your Personal Information
In general, we use information that we collect about you or that you provide to us, including Personal Information and Sensitive Personal Information, for following purposes:
- Provision of services: to present our Website and its contents to you, including any interactive features on our Website, and to provide you with information, products or services that you request from us; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with contests and sweepstakes;
- Customer management: to manage a registered users’ account, to provide customer support and notices to the registered user about his account or subscription, including expiration and renewal notices, and notices about changes to our Website or any products or services we offer or provide through it; We also use biometric information and identifiers for the purposes of verifying your identity and the authenticity of the identifiers you provide or have provided to us while registering for certain services on the Website;
- Customization of content: to perform research and analysis about your use of, or interest in, our Website content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website and other websites;
- Advertising: to communicate with you about products or services that may be of interest to you either from us, our affiliates or other third parties (For more information, see “Choices About How We Collect, Use and Disclose Your Personal Information”);
- Analytics: to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns;
- Functionality and security: to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
- Compliance: to enforce our terms and conditions and to comply with our legal obligations;
Disclosure of Your Personal Information
We do not disclose your Personal Information except in the limited circumstances described here.
- We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
- Service providers. To our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, identity and document authenticity verification including biometric processing, processing credit card payments, risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, customization of content, analytics, security, supporting our Website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Website. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.
Financial information (including Personal Information) that you have provided to us will only be shared with our third-party processors in order to initiate and complete any orders placed on your account. All credit card transactions and such are processed with industry standard encryption through third party processors who only use your financial information and Personal Information for that purpose. All financial data and related Personal Information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions, and policies of a third party. All such information provided to a third party is subject to their terms and conditions.
Third Party Login Functionality
We may permit users with accounts on certain third-party services, including but not limited to, social networking, search, sharing, and other services delivered by third parties, to bypass the standard applicable registration process. If you connect through an authorized third-party service, you will be able to use your third-party login information to log in to your account or access our content and Website. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third party services that may be triggered by using these third-party login services. Please review their terms of service and privacy policies carefully before using third-party login functionality to access our Website.
Transfers of Your Personal Information to Other Countries
By using the Website, you consent to the transfer of information that we collect about you, including personal information, to any country in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.
Retention of Personal Information
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where permissible, we will also delete your Personal Data upon your request. Information on how to make a deletion request can be found under “Your Rights Related to Your Personal Information”.
If you have questions about our data retention practices, please send us an e-mail at email@example.com.
The period for which we keep your Personal Information that is necessary for compliance and legal enforcement purposes varies and depend on the nature of our legal obligations and claims in the individual case.
How We Protect the Security of Your Personal Information
We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
Choices About How We Collect, Use and Disclose Your Personal Information
We strive to provide you with choices regarding the Personal Information you provide to us.
- You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of our Website because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Website.
- You may opt out of the DoubleClick cookie or of Google Analytics by visiting the Google advertising opt-out page or by downloading and installing the browser plug-in available at Google Analytics opt-out page.
- When you register on our Website, you may be given a choice as to whether you want to receive email messages, newsletters or both about product updates, improvements, special offers, or containing special distributions of content by us. If you no longer want to receive commercial or promotional emails or newsletters from us, you will need to avail yourself of the unsubscribe mechanism set out in the applicable communication. It may take up to seven days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
- You may opt out of interest-based advertising on mobile devices by activating the “Limit Ad Tracking” or equivalent feature offered by your mobile platform. It will transmit a signal to us and to third parties that indicates your data should not be used for interest-based advertising.
- If you submit Personal Information, you may delete your account with us at any time. If you delete your account, your Personal Information and any and all other account related information including, but not limited to, user profile data, sharing data and any other data, or content specifically associated with your account will no longer be accessible by you. After deleting your account, if you choose to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
Your Rights Related to Your Personal Information
Subject to local law, you have certain rights regarding the Personal Information we collect, use, or disclose and that is related to you, including the right:
- to receive information on the Personal Information concerning we hold about you and how such Personal Information is used (right to access);
- to rectify inaccurate Personal Information concerning you (right to data rectification);
- to delete/erase your Personal Information (right to erasure/deletion, “right to be forgotten”);
- to receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability)
- to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object); and
- in some cases, to restrict our use of your Personal Information (right to restriction of processing).
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer able to use several functionalities of our Website and our services.
You may, at any time, send us an e-mail at firstname.lastname@example.org to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.
Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricable linked to the use of certain Personal Information (e.g., your e-mail address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
California Consumer Privacy Act Notice
As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this policy, and subject to the exceptions found under the CCPA, Consumers have the right to:
- Opt-out of the sale of their personal information, should we sell their personal information;
- Be informed of certain information concerning our collection and use of their personal information;
- Request that we delete certain personal information we collected from them;
- Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
- Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.
This Website does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information.
If the CCPA is applicable to you and you would like to exercise your rights, please contact email@example.com
Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid Court Order, Subpoena, Search Warrant or equivalent Legal or Official Administrative Document by respecting the following conditions:
The document(s) is/are uploaded, and all required fields have been filled out adequately on our Legal Service Process Platform, located at:
The document(s) you are serving is correctly issued by a valid Court of Law or equivalent legal or administrative authority to the right operating entity for the Site in question. (See Platform to find the operating entity);
The document(s) is also sent by mail at the following address:
195-197 Old Nicosia-Limassol Road,
Block 1 Dali Industrial Zone, Cyprus 2540
We reserve the right to refuse online service through our Platform, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
No Rights of Third Parties
Our Policy Towards Minors
Our Website is not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Website is accessed and we do not knowingly collect Personal Information from minors. If you become aware that your child has provided us with Personal Information, please contact us at firstname.lastname@example.org. If we become aware that a minor has provided us with Personal Information, we take steps to remove such information and terminate that person’s account.
No Error Free Performance
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address email@example.com.