Privacy Notice

Last Modified: December 6, 2024

Introduction

Aylo Social Ltd (hereinafter “we”, “us”, or “our”) operates the website mydirtyhobby.com (hereinafter “MyDirtyHobby”) and is the controller of the information collected or provided via MyDirtyHobby.

Please read this Privacy Notice carefully, as your access to and use of MyDirtyHobby signifies that you have read, understand, and agree to all terms within this Notice. We respect your privacy and are committed to protecting your personal data.

If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.

1. Scope

For the purposes of this Privacy Notice, “process”, “processed” or “processing” means any operation or set of operations performed on personal data or on sets of personal data (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction. Information on disclosure of personal data or of sets of personal data may be found in the section “Disclosure of Your Personal Information” section below.

We collect, process, and retain personal data to the extent necessary to provide users with our service. This Privacy Notice applies to information we collect:

• on MyDirtyHobby,

• in e-mail, text and other communications between you and MyDirtyHobby,

• through mobile applications you download from MyDirtyHobby, which provide dedicated non-browser-based interaction between you and MyDirtyHobby, 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 MyDirtyHobby. 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.

2. The Data We Process About You

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified by. It does not include data that has been anonymized. 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 and tax identification number.

• Identifiers and Biometric Information. When registering for certain features of MyDirtyHobby we collect identifiers you submit to us, allowing us to verify your identity. We also collect biometric information 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.

• Online Form and Communications Data: We process Identity Data and other information that you submit through online forms provided on the Website or send us via email, such as information provided in the context of support requests or any other inquiries, the content reporting and moderation of content, and our internal complaint handling system. 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.

• Transaction Data. If you make a purchase or receive payments from us, we collect bank account details and related information necessary to process payments. We also collect details about payments to and from you and 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 MyDirtyHobby products, and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Sensitive data: Depending on how you use MyDirtyHobby, we might collect special categories of personal information including your biometric information, ethnicity, or information concerning your sex life (“sensitive personal information”). We also collect certain sensitive personal information, such as your sexual orientation, when you provide it upon the completion of your profile page on MyDirtyHobby. By completing and saving such information in your profile, you consent to its processing. You can revoke your consent by removing this information from your MyDirtyHobby profile.

We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information. We may also aggregate your usage data to calculate the percentage of users accessing a specific MyDirtyHobby feature. For example, we may use your data to generate statistics about our users, to calculate the percentage of users accessing a specific MyDirtyHobby feature, to calculate ad impressions served or clicked on, or to publish visitor demographics.

3. The Sources from Which We Process Personal Information

We use different methods to collect personal data, including through:

• Direct interactions. Information that you provide when carrying out search queries on MyDirtyHobby or by filling in forms on MyDirtyHobby, in particular at the time of registering to use MyDirtyHobby, subscribing to our service, posting material, taking part in surveys, entering a contest or promotion sponsored by us, when reporting a problem with MyDirtyHobby or requesting further services.

• Automated technologies or interactions. See “Cookies and Automatic Data Collection Technologies” for details of how we may automatically collect your personal data.

• Third-Party Single Sign-on: We may obtain information if you create or sign-in your account through a third-party platform (such as Google), we will have access to certain information from that platform such as your name, email address or such other information you may have submitted and allowed this third party to share.

• Third parties. 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.

4. User Contributions

We may provide areas on MyDirtyHobby where you can post information about yourself and others, communicate with others, upload content (e.g., pictures, videos, audio files, etc.), and post comments or reviews of MyDirtyHobby content. Such postings are governed by MyDirtyHobby’s Terms of Use.

If you use a forum, blog, user commenting features, community or other interactive sharing or social features that may be offered through MyDirtyHobby, you should be aware that any personal information you submit or publish there is considered publicly displayed and can be read, collected, used, and disclosed by other users, by us, and by third parties without restriction, except to the extent limited access features are available, if any. Such information may also appear on other websites or search engines. If you post your email address, you may receive unsolicited messages. We cannot control who reads or what other parties may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. It might not be possible to edit or delete information once it is posted.

For information on how to request the removal of your personal data from MyDirtyHobby, please visit the section ‘Manage Your Personal Data’ below or send an e-mail at support@mydirtyhobby.com to help you initiate the process. In some cases, we may not be able to remove your personal information, in which case we will inform you accordingly.

5. Purposes for Which We Process Your Personal Information

We process personal information for the purposes described below:

• Provision of services: to present MyDirtyHobby and its contents to you, including any interactive features on MyDirtyHobby, 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 MyDirtyHobby 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 or age and the authenticity of the identifiers you provide or have provided to us while registering for certain services on MyDirtyHobby.

• Customization of content: to perform research and analysis about your use of, or interest in, MyDirtyHobby content, products, or services, to develop and display content and advertising tailored to your interests on MyDirtyHobby and other websites.

• Communications and handling of requests: We process Online Form and Communications Data and other information as necessary to respond to and resolve any of your requests, including where this is required to ensure compliance with our legal obligations.

• 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 “Your Choices About Your Personal Information” below).

• Analytics: to determine whether users of MyDirtyHobby are unique, or whether the same user is using MyDirtyHobby 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.

• Platform Safety: To promote safety and security of our platform. We use the information we collect to help protect people from harm and provide safe, secure product.

• Hash values: We may create hash values from any of the categories of data we process, such as infringing or illegal content to train our models to detect, prevent, and combat illegal activities including fraud, sexual assault, or exploitation. We reserve the right to share any hashes with law enforcement agencies.

• Compliance: to enforce our terms and conditions, to comply with our legal obligations, including responding to your data subject requests, to respond to content reports, and to comply with applicable content moderation and complaint handling obligations. In certain jurisdictions, this includes our legal obligation to verify the age of users having access to MyDirtyHobby.

• Information you provide: In any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this Privacy Notice.

6. Our Legal Bases Under Canadian and European Union (EU) Privacy Law

To the extent required by applicable law, we rely on several legal bases to use your data in these ways. This means we process your personal data only where:

• You provide your consent to do so for a specific purpose: for example, when you allow us to show you personalized ads or to send you e-mail marketing. Sensitive personal information, including biometric information, is also processed based on your consent. You may withdraw your consent at any time with effect for the future. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.

• It is necessary to perform our contract with you: for example, to create your account and provide our services.

• It is necessary to comply with our legal obligations: for example, we may be required to collect, use or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters or litigation.

• It satisfies a legitimate interest (which is not overridden by your data protection interests): for example, to keep MyDirtyHobby safe and secure from fraud and illegal activities.

• It is used to protect your or others’ vital interests: for example, in case of emergency or to prevent a crime or fraud.

• It is used for tasks carried out in the public interest: for example, to combat unlawful behaviour where it is in the public interest to do so and where the public interest is laid down by applicable law.

Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.

7. Disclosure of Your Personal Information

We disclose your personal information when necessary to perform the services or for other purposes set out in this Privacy Notice. When we disclose your personal information, we usually rely on the performance of our contract with you, our legal obligation to do so, our legitimate interest (e.g., operating MyDirtyHobby), so long as it doesn’t outweigh your interests or your consent, except when expressly stated otherwise below in the paragraph “To comply with the law or protect our rights or the rights of third parties”. Disclosure of your personal information may also involve transfers of your personal information outside the EEA. To the extent that we need to transfer personal information outside the EEA, we will do so according to the section “Transfers of Your Personal Information to Other Countries” or when necessary for the performance of the contract between us. The parties to whom we may disclose your personal information include:  

• The public: When you submit user contributions including audio/video content, certain information about you will be publicly displayed on MyDirtyHobby, such as your uploaded content, information about you, etc. You can choose to make certain information and activities private through your profile settings. This information might be accessible to various locations worldwide from which MyDirtyHobby can be accessed.

• Our contractors and/or employees: To provide our services to you, our employees and/or contractors may receive access to your personal data only on a need-to-know basis. Such employees and contractors abide by confidentiality obligations.

• Our corporate group 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 described in this Privacy Notice, and generally to operate our business, which includes: identification and age verification purposes, transaction monitoring and payment processing, customer support, facilitate business development, administer user accounts or provide IT, technical and engineering support. You acknowledge that in some cases, members of our corporate group might be established or run their services outside the EEA.  

• Linked Third-Party Websites or Single Sign-On Services: You may choose to sign-in, connect or register an account using an external third-party platform, or Single Sign-On (SSO) if available. If you choose to connect your account to a third-party platform, the providers of this platform may receive information about you. When you use third-party platforms, their own terms and privacy policies will govern their use.

• Service providers: We disclose certain categories of personal information to our authorized service providers to enable us to provide our services to you pursuant to our Terms & Conditions. These service providers may use your information only to perform these tasks on our behalf, such as identity and document authenticity verification including biometric processing, age verification, risk and fraud detection and mitigation, customer service, marketing and advertising, customization of content, analytics, security, hosting or supporting Pornhub’s functionality. These service providers have limited access to personal information needed to perform their functions and are not permitted to process such information for any other purposes. Where required under applicable laws, we have entered into data processing agreements with such service providers to ensure that personal information is only processed securely within our instructions.  

• Legal successors: We may disclose all categories of personal information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Such transactions may be in our legitimate interest, particularly our interest in making decisions that enable our business to develop.  

• To comply with the law or protect our rights or the rights of third parties: We access, preserve and share personal information with regulators, public authorities, law enforcement, government agencies, out-of-court dispute settlement bodies or others where we reasonably believe such disclosure is needed to:

1. comply with any applicable law, regulation, court order, legal process, government or public authority requests

2. enforce applicable Terms & Conditions, including prevention of potential violations thereof. This also includes our Trust and Safety initiative, in the scope of which we may disclose some information to several recipients.

3. detect, prevent, or otherwise address illegal or suspected illegal activities, security, or technical issues.

4. protect against harm to the rights, property or safety of our company, our users, our employees, or others; or

5. maintain and protect the security and integrity of MyDirtyHobby or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose your information to third parties for the above purposes where necessary to comply with our legal obligations, to perform a task in the public interest (where the public interest is laid down by applicable law), or under our legitimate interests and the interests of the public, including as part of investigations or regulatory enquiries to detect, investigate and prosecute illegal activity.

8. Cookies and Automatic Data Collection Technologies

As you navigate through and interact with MyDirtyHobby, we use cookies and other similar 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”).

The technologies we use for this automatic data collection may include:

Cookies

A cookie is a small piece of data that, when browsing a website, will ask your browser to collect and store on your computer or internet-compatible end user devices for example, smartphones and tablets (collectively “Computer”) in order to remember information about you, such as your language preference, online activity, or login credentials (collectively “cookies”).  

First and Third-Party Cookies. The cookies set by us are called first party cookies. We also use third-party cookies, which are cookies from a domain different than MyDirtyHobby. Both types of cookies are text files made up of bits of information that websites use to collect your user data. First-party cookies are mostly used to improve your user experience by remembering user preferences and settings, also used to store information, such as usernames, passwords, and language preferences. Third-party cookies track your browsing history and activities so that we can show you targeted or personalized ads and marketing related to our content, products, and services.  

Session and Persistent Cookies. Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you quit your browser. A persistent cookie will be saved on your computer until it expires, or until you delete your cookies. Each cookie has a different expiration date; some may expire after a few minutes while others after some years.

We currently use the following types of cookies:

Essential cookies

These are cookies necessary for the functioning of MyDirtyHobby and cannot be switched off in our systems as they enable core website functionality They are used to carry out the transmission of a communication (e.g. load balancing cookies), provide you with the requested services or are set in response to actions made by you,  such as setting your privacy preferences, logging in or filling in forms (UI customization cookies). You can set your browser to block these cookies, but that will cause some parts of MyDirtyHobby to not work.  

Functional cookies

These cookies are set to implement additional functionalities or to enhance features and website performance. These cookies help us personalize and enhance your online experience on MyDirtyHobby. This type of cookies also allows us to recognize you when you return to MyDirtyHobby and to remember your choices.  

Analytics cookies

These cookies allow us to recognize and count the number of users and to see how users use and explore MyDirtyHobby, for example they allow us to carry out statistical analysis of page use, interactions, and paths a user takes through MyDirtyHobby to improve the performance of MyDirtyHobby. This is known as ‘digital analytics,’ where this information allows us to know what content on MyDirtyHobby is the most and least popular.  Additionally, we use third party session recording technologies that help us better understand our users’ experience, however, the recording data is pseudonymized.  

Targeting/Advertising cookies

These cookies enable us to make MyDirtyHobby more relevant to your interests and to help us serve ads that might be of interest to you. MyDirtyHobby and our advertising partners set these cookies to provide behavioural advertising and define the number of ads that will be displayed to you. Under this category, are also cross-site tracking cookies, which monitor and record users' online activities as they navigate across different websites and online platforms. Collected data can be any type of browsing information necessary to understand your browsing habits. If you choose to disable this type of cookies, you will still see advertisements, but they will be less relevant and will not be tailored to your interests.

Customize your cookie preferences

You can customize your cookie preferences via our cookie banner. The cookie banner will record when you have consented to our cookies. For logged in users, we will ask for consent once a year or when we have major changes to our cookies, to ensure you stay up to date with changes to our cookie and Privacy Notice. For non-logged in users, your cookie selection will be saved only during the specific session.

The cookie banner specifically controls the Functional, Analytics, and Advertising cookies set by using MyDirtyHobby and can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of MyDirtyHobby. If you decline these cookies, some functionalities of MyDirtyHobby may be disabled and your access to certain parts of MyDirtyHobby may be interrupted. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from MyDirtyHobby.

Web Beacons 

Pages of MyDirtyHobby and our e-mails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags) 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). 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.

Google Analytics

We use third party analytics tools and technologies, in particular Google Analytics provided by Google, Inc., USA (“Google”). These tools and technologies collect and analyse certain types of information, including IP addresses, device, and software identifiers, referring and exit URLs, onsite behaviour and usage information, feature use metrics and statistics, usage and purchase history, media access control address (MAC Address), mobile unique device identifiers, and other similar information via the use of cookies. The information generated by Google Analytics about your use of the Website (including your IP address) may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). Because we activated IP anonymization for Google Analytics Google will anonymize the last octet of a particular IP address. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity. You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.

9. Third-party Cookies and Other Tracking Technologies

Third party cookies originate from a domain different to MyDirtyHobby. For example, when you visit MyDirtyHobby, some content or applications, including advertisements, may link to a third-party website.  

These third parties may set cookies on your Computer to collect information about you, such as your IP address or location, when you click to view, access, or use any of their features on MyDirtyHobby. Unless expressly stated otherwise, we do not share any personal information with these third parties or control how these third parties use their cookies, so we suggest you check their website to see how they're using them and how you can manage them. You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent. Our systems do not recognize browser “Do Not Track” signals.

10.  Your Choices About 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 MyDirtyHobby because such information may be required 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 MyDirtyHobby.

• You can opt out of receiving marketing emails from us using the opt-out link provided in our emails or by changing your preferences in your account settings. We may continue to send you transactional emails reflecting the state of your accounts and transactions.

• Where we provide personalised services, we may analyse the information you supply, as well as your activity on MyDirtyHobby, so that we can offer a more relevant, tailored service. For instance, we could use your favourites list or your purchased content to provide personalised content recommendations or ads. If you don’t want to receive these services, you can disable personalisation via your Privacy Settings. For more information on how we use recommendations, please click here.

11. California Rights and Choices

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 Privacy Notice, 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.

MyDirtyHobby does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable consideration. We may however disclose certain personal information to third parties, service providers and entities within our corporate group to enable them to perform certain services on our behalf and namely to make MyDirtyHobby function properly, as further described in the section above titled “Disclosure of Your Personal Information”.

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 you are a Registered User and the CCPA is applicable to you and you would like to exercise your rights, please use the buttons at the bottom of this page or email us at support@mydirtyhobby.com with the email subject line “CCPA Request”.

In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.

You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.

12. Resident’s Rights – Jurisdictions in the United States, Where Applicable 

We do not sell, trade, or exchange the users’ personal information with anyone for money. 

13. Biometric Information

We cooperate with third-party service providers to help verify your identity and age, when needed, 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. Information derived from this mathematical representation, which may be considered biometric data under the laws of certain states and countries, is shared by our service providers with us and is 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 will store your biometric information according to the section “Retention of Personal Information” below.

14. 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:

1. The document(s) is/are uploaded, and all required fields have been filled out adequately on our Legal Service Process Platform, located at: http://legalservice.aylo.com/legal/datarequest

2. The document(s) you are serving is/are correctly issued to Aylo Social Ltd by a valid Court of Law or equivalent legal or administrative authority.

3. The document(s) is also sent by mail at the address mentioned under Contact Information below.

We reserve the right to refuse online service through MyDirtyHobby, 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.

15. Transfers of Your Personal Information to Other Countries

We share the information we collect globally, both across our corporate group and data centres, and externally with our service providers and other third parties. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms of Use and this Notice or so that we can fix, analyse and improve our products. Whenever we transfer personal information to countries outside the EEA and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Notice, as permitted by the applicable laws and based on appropriate mechanisms.

Where available, we rely on decisions of the European Commission, known as “adequacy decisions,” recognising that certain countries offer a level of protection of personal data that is essentially equivalent to the EEA.

In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.

16. Retention of Personal Information

We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed 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 several factors, including what personal data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, we will delete your personal information from our systems.

For more information on data retention periods, please contact us by using the information in the section “Contact Information” below.

Where permissible, we will also delete your personal information upon your request as explained in the section “Your Rights Related to Your Personal Information”.

17. 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 note, however, that we cannot fully eliminate security risks associated with the storage and transmission of personal data. You are responsible for always maintaining the secrecy of your unique password and account information. We are not responsible for circumventions of any privacy settings or security measures contained on MyDirtyHobby.

18. Third-Party Links and Sites

If you click on a link to a third-party website, you will be taken to websites we do not control. This Privacy Notice does not apply to the privacy practices of these websites. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.

19. Changes to Our Privacy Notice

We may modify or revise our Privacy Notice from time to time. If we change anything in our Privacy Notice, the date of change will be reflected in the “last modified date”. We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our Privacy Notice, which will be posted at this location, so you are aware of any changes.

20. Our Policy Towards Minors

MyDirtyHobby is forbidden of access to persons under the age of 18 or the applicable age of majority in the jurisdiction from which MyDirtyHobby is accessed (“minors”), and we therefore prohibit minors from using MyDirtyHobby. As indicated throughout this Privacy Notice, some users may be asked to provide some information to us and our service providers to verify that you are over the age of majority required to have access to MyDirtyHobby and to view the content. We do not knowingly process personal information from minors.

If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at support@mydirtyhobby.com to have that minor’s personal information deleted. 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.

21. Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us at privacy@mydirtyhobby.com.

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 dpo@mydirtyhobby.com.

22. Your Rights Related to Your Personal Data

Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your personal data:

• Right of Access: you have the right to receive information on the personal data we hold about you and how such personal data is used;

• Right to Rectification: you have the right to rectify inaccurate personal data concerning you;

• Right to be Forgotten: you have the right to delete/erase your personal data;

• Right to data portability: you have the right to receive the personal data provided by you in a structured, commonly used and machine-readable format and to transmit this personal data to another data controller;

• Right to Object: you have the right to object to the use of your personal data where such use is based on our legitimate interests or on public interests;

• Right to Restriction of Processing: you have the right in some cases, to restrict our use of your personal data.

• Right to File a Complaint: If you are located in the EEA, you also have a right to lodge a complaint with your local data protection authority.

If we ask for your consent to process your personal data, you have the right to withdraw your consent at any time. Note that, in that case, you may no longer able to use several functionalities of MyDirtyHobby or access MyDirtyHobby in some cases.

You can exercise your Rights of Access or Deletion by following the dedicated links in the section “Manage Your Personal Data” below. You can send an e-mail at support@mydirtyhobby.com to exercise your rights to Rectification, Object, Restriction of Processing, or to request us to help you with the process. Please note that we have one (1) month to respond to your request.

Prior to processing a request, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that personal data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.

Some requests to delete certain personal data will require the deletion of your user account as user accounts are inextricably linked to certain personal data (e.g., your e-mail address). If you delete your account, your personal data and all account related information including, but not limited to, user profile data, sharing data and any data or content specifically associated with your account will no longer be accessible by you. If, after deleting your account, you wish 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.

23. Manage Your Personal Data

Registered Users may request a copy of their personal data or request the deletion of their personal data via the links below. Please note that the below website is governed by the present Privacy Notice.

• Request a Copy of my Data

• Request Deletion of my Data

To exercise your Rights to Rectification, to Object or to Restriction of Processing you can send an e-mail at support@mydirtyhobby.com.

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