Privacy Policy
This is the Privacy Policy for the HotCrush application, which is incorporated into and subject to our Terms of Use, which can be found here.In this Privacy Policy, we refer to our products and
services as the “Service.” Please read on to learn more about our data handling
practices. We respect your privacy and want you to understand how we collect,
use, and share data about you. This Privacy Policy covers our data collection
practices and describes your rights to access, correct, or restrict our use of
your personal data; in plain language, keeping legal and technical jargon to a
minimum. Your privacy is at the core of the way we design and build our
Services and products you know and love so that you can fully trust them and
focus on building meaningful connections. Unless we link to a different policy
or state otherwise, this Privacy Policy applies when you visit or use the
Service. Your use of the Service signifies that you agree with the terms of
this Privacy Policy. If you do not agree with the terms of this Privacy Policy,
do not use the Service.
Table of
Contents
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1.Controller
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2.What Data We Get
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3.What We Use Your Data For
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4.How We Share Information
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5.Your Rights
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6.Data Retention
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7.Data Protection and Security
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8.Children’s Privacy
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9.International Transfer Policy
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10.Privacy Policy Changes
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11.Contact Us
1. Controller
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Controller: The controller of data processing
is HotCrush. You can contact us via e-mail under the Email Address.
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Data Protection Officer: Our data protection
officer can be contacted under the Email Address. Should you have any questions
regarding the processing of your personal data, please do not hesitate to
contact him/her.
2. What Data We
Collect
This Privacy Policy applies to websites,
apps, and other services operated by us. We process personal data that you as a
user of the Products make available to us, for example by using our Products
and that users provide to us (“Data”).We can’t help you develop meaningful
connections without some data about you, such as basic profile details and the
types of people you’d like to meet. We also collect information generated as
you use our services, for example, access logs, as well as information from third
parties, like when you access our services through a social media account. We
also collect some data automatically, like information about your device and
what parts of our Services you interact with or spend time using.
2.1 Data You
Provide to Us
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Account Data: In order to use certain features
(registering for an account), you need to create a user account. When you
create or update your account, we collect and store the data you provide,
like your name, gender, and date of birth, and assign you a unique
identifying number (“Account Data”).
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Profile Data: You can also choose to provide
profile information like a photo, info, name, sexual interests, or other
data. Your Profile Data will be publicly viewable by others unless you
delete your account. To add certain content, like pictures or videos, you
may allow us to access your camera or photo album. Some of the information
you choose to provide us may be considered “special” or “sensitive” in a
certain jurisdiction, for example, your racial or ethnic origins, sexual
orientation, and religious beliefs. By choosing to provide this
information, you consent to our processing of that information.
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Usage Data: When you use our Services and
features, we collect certain data including; messages, follow information,
photos, videos, gifts, and other user data. Of course, we also process
your chats with other users as well as the content you publish, as part of
the operation of the Services.
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Shared Content: Parts of the Services let you
interact with other users or share content publicly, including by gifts
you receive, videos you post and the data you provided in your profile.
Such shared content may be publicly viewable by others depending on where
it is posted.
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Promotions: When you choose to participate in
our promotions, events, or contests, we collect the information that you
use to register or enter. If you won a prize, we would collect the
financial information to reward you.
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Data About Your Accounts on Other Services: We
may obtain certain information through your social media or other online
accounts if they are connected to your account in our Services. If you
login to our Services via Facebook or another third-party platform, we ask
for your permission to access certain information about that other
account. For example, depending on the platform or service we may collect
your name, profile picture, gender, info, and birthday.
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Those platforms and services make information
available to us through their APIs. The information we receive depends on
what information you (via your privacy settings) or the platform or
service decide to give us.
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If you access or use our Services through a
third-party platform or service, or click on any third-party links, the
collection, use, and sharing of your data will also be subject to the
privacy policies and other agreements of that third party.
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Data About Paid Service: All our paid service
is through iOS or Android platforms. We only receive a receipt of your
transaction provided by these platforms. For security reasons, we do not
collect or store sensitive cardholder data, such as full credit card
numbers or card authentication data.
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Communications and Support: If you contact us
for support or to report a problem or concern (regardless of whether you
have created an account), we collect and store your contact information,
messages, and other data about you such as your name, email address,
location, operating system, IP address, and any other data you provide or
that we collect through automated means (which we cover below). We use
this data to respond to you and research your question or concern, in
accordance with this Privacy Policy. If you ask us to communicate with or
otherwise process information of other people (for example, if you ask us
to send an email on your behalf to one of your friends), we collect the
information about others that you give us in order to complete your request.
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Sensitive Information: Please be careful about
posting sensitive details about yourself on your Profile such as your
religious denomination and health details. While you may voluntarily
provide this information to us when you create your Profile, including
your sexual preferences and ethnic background, there is no requirement to
do so. Please remember that photographs or any video clips that you post
on our Services may reveal these kinds of sensitive personal data. Where
you do upload and choose to tell us sensitive data about yourself, you are
explicitly consenting to our processing your information and making this
public to other users.
* The data listed above is stored by us and
associated with your account in our Services.
2.2. Data From
Others
In addition to the information you provide
us directly, we receive information about you from others or by automated
means, including:
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System Data: Technical data about your
computer or device, like your IP address, device type, operating system
type and version, unique device identifiers, device language, browser,
browser language, and other systems data, and platform types (“System Data”).
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Usage Data: We collect information about your
activity on our Services, for instance how you use them (e.g., date and
time you logged in, features you’ve been using, search preferences,
clicks, and pages which have been shown to you, referring web page address,
advertising that you click on) and how you interact with other users
(e.g., users, you connect and interact with, time and date of your
exchanges, number of messages you send and receive, number of content you
post).
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Device Information: We collect information
from and about the device(s) you use to access our Services, including:
hardware and software information such as IP address, device type,
device-specific and apps settings and characteristics, app crashes,
advertising IDs (such as Google’s AAID and Apple's IDFA, both of which
are randomly generated numbers that you can reset by going into your
device’ settings), browser type, version and language, operating system,
time zones, identifiers associated with cookies or other technologies
that may uniquely identify your device or browser.
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Other information with your consent: If you
give us permission, we can collect your precise geolocation (latitude and
longitude) through various means, depending on the service and device
you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection
of your geolocation may occur in the background even when you aren’t
using the Services if the permission you gave us expressly permits such
collection. If you decline permission for us to collect your geolocation,
we will not collect it. Similarly, if you consent, we may collect your
photos and videos (for instance, if you want to publish a photo, video or
streaming on the Services).
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Approximate Geographic Data: An approximate
geographic location, including information like country, city, and
geographic coordinates, calculated based on your IP address.
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Other Partners: We may receive information
about you from our partners, for instance where our ads are published on a
partner’s websites and platforms (in which case they may pass along
details on a campaign’s success).
3. What We Use
Your Data For
The main reason we use your information is
to deliver and improve our Services. Additionally, we use your info to help
keep you safe. Read on for a more detailed explanation of the various reasons
we use your information, together with practical examples.
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To administer your account and provide our
Services to you
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Create and manage your account
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Provide you with customer support and respond
to your requests
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Complete your transactions
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Communicate with you about our Services,
including order management and billing
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To help you connect with other users
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Analyze your profile and that of other users
to recommend meaningful connections
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Show users’ profiles to one another
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To improve our Services and develop new ones
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Administer focus groups and surveys
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Conduct research and analysis of users’
behavior to improve our Services and content (for instance, we may decide
to change the look and feel or even substantially modify a given feature
based on users’ behavior)
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Develop new features and services (for
example, we may decide to build a new interests-based feature further to
requests received from users).
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To prevent, detect and fight fraud or other
illegal or unauthorized activities
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Address ongoing or alleged misbehavior on and
off-platform
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Perform data analysis to better understand and
design countermeasures against these activities
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Retain data related to fraudulent activities
to prevent recurrences
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To ensure legal compliance
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Comply with legal requirements
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Assist law enforcement
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Enforce or exercise our rights, for example,
our Terms
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To process your information as described
above, we rely on the following legal bases:
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Provide our service to you: Most of the time,
the reason we process your information is to perform the contract that you
have with us. For instance, as you go about using our service to build
meaningful connections, we use your information to maintain your account
and your profile, to make it viewable to other users and recommend other
users to you.
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Legitimate interests: We may use your
information where we have legitimate interests to do so. For instance, we
analyze users’ behavior on our Services to continuously improve our
offerings, we suggest offers we think might interest you, and we process information
for administrative, fraud detection and other legal purposes.
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Marketing:
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Push Message Marketing: With your explicit
consent, we will send you marketing push messages.
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Retargeting: You might see marketing messages
on the platforms listed below. In addition, other users who have similar
characteristics to you on those platforms could see marketing messages on
those platforms as well (i.e., Facebook Lookalike audience). An opt-out is
possible at any time via our customer support. It may take a few days
after the opt-out until you are removed from all audiences.
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List of other platforms: Facebook, Google,
Twitter, UnityAds, Snapchat, and Bytedance
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Consent: From time to time, we may ask for
your consent to use your information for certain specific reasons. You may
withdraw your consent at any time by contacting us at the address provided
at the end of this Privacy Policy.
4. How We Share
Information
4.1 With Other
Users:
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You share information with other users when
you voluntarily disclose information on the service (including your public
profile). Please be careful with your information and make sure that the
content you share is the stuff that you’re comfortable being publically
viewable since neither you nor we can control what others do with your
information once you share it.
4.2 With Our
Service Providers and Partners:
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We use third parties to help us operate and
improve our Services. These third parties assist us with various tasks,
including data hosting and maintenance, analytics, customer care,
marketing, advertising, payment processing, and security operations. These
service providers may access your personal data and are required to use it
solely as we direct, to provide our requested service.
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We may also share information with partners
who distribute and assist us in advertising our Services. For instance, we
may share limited information on you in hashed, non-human readable form to
advertising partners.
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We follow a strict vetting process prior to
engaging any service provider or working with any partner. All of our
service providers and partners must agree to strict confidentiality
obligations.
4.3 When
Required by Law:
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We may disclose your information if reasonably
necessary: (i) to comply with a legal process, such as a court order,
subpoena or search warrant, government/law enforcement investigation or
other legal requirements; (ii) to assist in the prevention or detection of
crime (subject in each case to applicable law); or (iii) to protect the
safety of any person.
4.4 To Enforce
Legal Rights:
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We may also share information: (i) if
disclosure would mitigate our liability in an actual or threatened
lawsuit; (ii) as necessary to protect our legal rights and legal rights of
our users, business partners or other interested parties; (iii) to enforce
our agreements with you; and (iv) to investigate, prevent, or take other
action regarding illegal activity, suspected fraud or other wrongdoing.
4.5 Monitor:
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Moderators to monitor activity on the
site/apps and approve content. Fraud prevention and anti-spam providers to
protect the service from criminal activity.
4.6 Change of
Control:
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In the event that our Services or any of its
affiliates undergoes a business transition or change of ownership, such as
a merger, acquisition by another company, reorganization, or sale of all
or a portion of its assets, or in the event of insolvency or administration,
we may be required to disclose your personal data.
5. Your Rights
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You have certain rights around the use of your
data, including the ability to opt-out of cookies, and the collection of
your data by certain analytics providers. You can update or terminate your
account from within our Services, and can also contact us for individual
rights requests about your personal data. We want you to be in control of
your information, so we have provided you with the following tools:
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Access / Update tools in the service: Tools
and account settings that help you to access, rectify or delete
information that you provided to us and that’s associated with your
account directly within the service.
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Device permissions: Mobile platforms have
permission systems for specific types of device data and notifications,
such as phone book and location services as well as push notifications.
You can change your settings on your device to either consent or oppose
the collection of the corresponding information or the display of the
corresponding notifications. Of course, if you do that, certain services
may lose full functionality.
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Deletion: You can delete your account by using
the corresponding functionality directly on the service.
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We want you to be aware of your privacy
rights. Here are a few key points to remember:
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Reviewing your information: Applicable privacy
laws may give you the right to review the personal information we keep
about you (depending on the jurisdiction, this may be called right of
access, right of portability or variations of those terms). You can
request a copy of your personal information by sending us an email at
feedback@hotcrush.vip.
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Updating your information: If you believe that
the information we hold about you is inaccurate or that we are no longer
entitled to use it and want to request its rectification, deletion or
object to its processing, please contact us via
feedback@hotcrush.vip.
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For your protection and the protection of all
of our users, we may ask you to provide proof of identity before we can
answer the above requests.
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Keep in mind, we may reject requests for
certain reasons, including if the request is unlawful or if it may
infringe on trade secrets or intellectual property or the privacy of
another user. If you wish to receive information relating to another user,
such as a copy of any messages you received from him or her through our
service, the other user will have to contact our Privacy Officer to
provide their written consent before the information is released.
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Also, we may not be able to accommodate
certain requests to object to the processing of personal information,
notably where such requests would not allow us to provide our service to
you anymore. For instance, we cannot provide our service if we do not have
your date of birth.
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Uninstall: You can stop all information
collected by an app by uninstalling it using the standard uninstall
process for your device. If you uninstall the app from your mobile device,
the unique identifier associated with your device will continue to be stored.
If you re-install the application on the same mobile device, we will be
able to re-associate this identifier to your previous transactions and
activities.
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Accountability: In certain countries,
including in the European Union, you have a right to lodge a complaint
with the appropriate data protection authority if you have concerns about
how we process your personal information. The data protection authority
you can lodge a complaint with notably may be that of your habitual
residence, where you work or where we are established.
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If you want to exercise any of your rights
listed above please visit our feedback form or email us at
feedback@hotcrush.vip.
6. Data
Retention
We keep your personal information only as
long as we need it for legitimate business purposes and as permitted by
applicable law. To protect the safety and security of our users on and off our
Services, we implement a safety retention window of six months following
account deletion unless there is a technical difficulty. During this period,
some of your account information will be retained although the account will of
course not be visible on the Services anymore. In practice, we delete or
anonymize your information upon the deletion of your account (following the
safety retention window) or after 5 years of continuous inactivity. An account
is considered inactive when the Application of the Member has not established
contact with HotCrush’s servers (including due to deactivation of the
geolocation process), and the Member has not used the Application. In any
event, the Account of a Premium Member is not considered inactive.
Unless:
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we must keep it to comply with applicable law
(for instance, some “traffic data” is kept for one year to comply with
statutory data retention obligations) as well as to prevent bot systems
that are abusing the system;
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we must keep it to evidence our compliance
with applicable law (for instance, records of consents to our Terms,
Privacy Policy, and other similar consents are kept for five years);
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there is an outstanding issue, claim or
dispute requiring us to keep the relevant information until it is
resolved; or
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the information must be kept for our
legitimate business interests, such as fraud prevention and enhancing
users' safety and security. For example, information may need to be kept
to prevent a user who was banned for unsafe behavior or security incidents
from opening a new account.
Correspondence with our Customer Support
team will be retained for longer to allow us to deal with any subsequent
queries you may have but will usually be deleted within 6 years if there are no
queries.
Anonymized information about activity on
our Services is retained for longer periods of time for statistical and product
research purposes but this is not attributable to an individual once the
profile has been deleted.
Keep in mind that even though our systems
are designed to carry out data deletion processes according to the above
guidelines, we cannot promise that all data will be deleted within a specific
time frame due to technical constraints.
7. Data
Protection and Security
We work hard to protect you from
unauthorized access to or alteration, disclosure or destruction of your
personal information. As with all technology companies, although we take steps
to secure your information, we do not promise, and you should not expect, that
your personal information will always remain secure. Your password is an
important part of our security system, and it is your responsibility to protect
it. You should not share your password with any third party, and if you believe
your password or account has been compromised, you should change it immediately
and contact feedback@hotcrush.vip with any concerns.
We regularly monitor our systems for
possible vulnerabilities and attacks and regularly review our information
collection, storage, and processing practices to update our physical, technical
and organizational security measures.
We may suspend your use of all or part of
the Services without notice if we suspect or detect any breach of security. If
you believe that your account or information is no longer secure, please notify
us immediately. We are not responsible for virus protection outside our service
network. We are also not responsible for the damage or destruction of user
data. We will pursue every detected attack by hackers, etc. under civil law
and, if necessary, by the prosecution.
In case of a breach, we will notify; the EU
representatives, our DPO and our users who were or potentially were affected by
the breach within 72 hours of the attack. We will announce it on our webpage.
8. Children’s
Privacy
Our Services are restricted to users who
are 18 years of age or older. We do not permit users under the age of 18 on our
platform and we do not knowingly collect personal information from anyone under
the age of 18. If you suspect that a user is under the age of 18, please use
the reporting mechanism available through the service. If we become aware that
a child, minor or anyone under the age of 18 has registered with us and
provided us with personal data, we will take steps to terminate that person’s registration
and delete their profile information from our Services. If we do delete a
Profile because you violated our no children rule, we may retain basic account
and profile information to ensure that you do not try to get around our rules
by creating a new profile.
9. International
Transfer Policy
In order to provide the Services to you, we
must transfer your data to our servers and process it there. By visiting or
using our Services, you consent to the storage of your data on servers. If you
are using the Services, you consent to the transfer, storage, and processing of
your data. Specifically, personal data collected in Switzerland and the
European Economic Area (“EEA”) is transferred and stored outside those areas.
That data is also processed outside of
Switzerland and the EEA by our HotCrush companies, or our service providers,
including to process transactions, facilitate payments and provide support
services as described in Section 4 & 5. We have entered into data
processing agreements with our service providers that restrict and regulate
their processing of your data on our behalf. By submitting your data or using
our Services, you consent to this transfer, storage, and processing by HotCrush
and its processors. We operate a global network of servers including in
Germany, Netherlands, Turkey, and Canada. We ensure that the data is adequately
protected by ensuring that valid, legal mechanisms are in place. If you want
more information relating to the nature of the safeguards we have in place
please email feedback@hotcrush.vip.
10. Privacy
Policy Changes
we’re always looking for new and innovative
ways to help you build meaningful connections, this policy may change over
time. We will notify you before any material changes take effect so that you
have time to review the changes.
11. Contact Us
If you have any questions regarding this
privacy statement, the processing of your personal data, you can contact us
directly. We are also available to you in the case of requests for information,
requests or complaints:
E-MAIL: feedback@hotcrush.vip