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*AvTech will not sell any data that is created with our relationship with Gatsby Enterprises, Inc.
AdultVI.com
Privacy Policy
Last Modified: March 21, 2022
AV Tech Global LLC (“AV Tech”) respects your privacy and is committed to protecting it through our compliance with the practices described in this privacy policy.
In this privacy policy, we explain how and on what grounds we collect, store, and Process Personal Data of Data Subjects, i.e., our Client’s representatives, Users, and Visitors. We also explain what Data Subjects’ rights are and our obligations and liabilities.
AV Tech mainly Processes Users’ information as directed by our Clients for providing our Services. Our Clients are the data controllers who determine the purpose of Processing Personal Data and, accordingly, AV Tech is a Data Processor of User information for those services. In other cases, AV Tech is a Data Controller of User information (e.g., for Visitors of the Website). We may also Process certain Data Subjects’ information in anonymized form to develop and improve our Services and in other forms and purposes set out in this privacy policy.
To fully understand how Personal Data is Processed, Data Subjects should review privacy notices shared with the Users by AV Tech and privacy policies of those Clients’ for whose services they are getting identified for.
Please review this privacy policy carefully and contact our privacy offer at privacy@adultvi.com if you have any questions, comments, or concerns.
1. Definitions
In this privacy policy, the following definitions apply:
- Agreement—the service agreement entered into with the Client.
- Client—the legal entity to whom we provide our Services under the Agreement, AV Tech’s customer.
- Data Controller—a legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data and gives instructions regarding processing activities to AV Tech, unless AV Tech is acting as the Data Controller.
- Data Processor—AV Tech Processes Personal Data for the Data Controller, unless AV Tech is acting as the Data Controller.
- Data Subject / you—a natural person about whom we have information or data enabling the identification of the natural person. Data Subjects are our Client’s representatives, Users, our (potential) employees, Visitors, natural persons who provide us feedback (including other research and inquiry-related data), and other natural persons whose Personal Data we might process (if those natural persons are aware or made aware of that processing).
- EEA—European Economic Area (the European Union Member States, Norway, Iceland, and Liechtenstein).
- GDPR—EU General Data Protection Regulation No. 2016/679.
- Personal Data—any information relating to an identified or identifiable natural person (the Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier including a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- Processing—any operation or set of operations that is performed on Personal Data or on sets of Personal Data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing might be done manually or using automated systems.
- Processor / our / us / we—AV Tech Global LLC, a Kansas limited liability company, 11934 S. Monroe Street, Olathe, Kansas 66061, privacy@adultvi.com.
- Service(s)—personal identity verification service and connected services provided by us.
- User—the natural person about whom we provide the Service at the request of the Client and natural person who contacts us as the Client’s representative before conclusion of the Agreement.
- Visitor—is any person using the AV Tech Website.
- Website—https://www.adultvi.com.
2. Personal Data we Process
Personal Data we Process about Users. We provide personal identity verification services to Clients. This means we verify Users and for that you (i.e., the User) have acknowledged data Processing according to the Client’s privacy policy and data Processing by us under this privacy policy. We may collect and Process, among other data, the following Personal Data:
- Personal information about the User, which mainly consists of information extracted from the User’s content, for example, sex, eye color, weight, and height, as well as historic data of that User that might have been stored with us during previous interactions within the retention periods;
- Facial recognition data, including photos, videos, and sound recording;
- Contact details, including email address and IP address;
- Technical data, including but not limited to information about the date, time, and your activity in the Services, your IP address and domain name, your software and hardware attributes, and your general geographic location (e.g., city, state, and country);
- Biometric data, including facial identifiers;
- Personal information provided by the User, e.g., data from communications with us, feedback data;
- Personal information provided by natural persons who have participated in our product and market research initiatives;
- Personal information that we have received from the Client, e.g., contact details; and
- In cases where having a legal basis, e.g., a consent or a written release, for Processing certain Personal Data about a User is a prerequisite for providing the Services, then evidence and records, including connected Personal Data, that the legal basis has been obtained by us.
Personal Data we Process about the Client’s representative. To enter into the Agreement, to provide our Service, to communicate with the Client’s representative, and for other lawful reasons we need to Process the data of Client’s representative. This means we may Process, among other information, the following Personal Data of the Client’s representative:
- Personal information of the Client’s representative, including name, job title, position, and contact information;
- Personal Information for providing the Service, including data from communication with us;
- Technical data, including but not limited to information about the date, time, and your activity in the Services, your IP address and domain name, and your software and hardware attributes as well as your general geographic location (e.g., city, state, and country); and
- Publicly available relevant data.
Personal Data we Process about Visitors to our Website or Users of our Service. We may collect data when you visit our Website or Service by using cookies (see Cookie Policy) or other similar technologies (e.g., IP address, equipment information, location information, beacons) and Process the data gathered by them. This data, among other information, may be as follows:
- Personal information, including IP address, time, and location;
- Information on usage of the Website or Service and other web log data, including the pages you visit on the Website, the date and time of your visit, the files that you download, and the URLs from the websites you visit before and after navigating to the Website;
- Technical data, including but not limited to information about your IP address and domain name, your software and hardware attributes (including device IDs), and your general geographic location (e.g., city, state, and country); and
- Email addresses, when you subscribe to AV Tech’s newsletters or download AV Tech’s content.
3. How we obtain Personal Data
How we obtain User’s Personal Data. We use different methods to collect Personal Data from and about Users including through:
- We may obtain Personal Data directly from you as well as from the Client.
- As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions, and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and automatic data collection technologies).
- We may receive Personal Data about you if you visit other websites employing our cookies or from third parties including, for example, business partners; subcontractors in technical, payment, and delivery services; advertising networks; analytics providers; search information providers; data brokers; or data aggregators.
- Clients may have access to your Personal Data. We may share your Personal Data, foremost the biometric data and facial recognition data with the Client through which you used our identity verification service.
- Please note that providing your Personal Data is voluntary. However, the decision not to do so may mean that we are not able to verify your identity.
How we obtain Client’s representative’s Personal Data. We collect this data either from you directly when you communicate with us directly, e.g., by sending us an email, providing us with your Personal Data on the phone or through our customer support tools. We may also collect some of your Personal Data while providing Service to your employer. We also check information about the Client (including about relevant representatives of the Client) from publicly available sources. We only gather relevant and necessary data to validate the right of representation, e.g., this may include verification of your identity, Processing of your Personal Data for introducing the Service, etc. Again, providing Personal Data is voluntary. However, if you do not provide your Personal Data, the Client might not be able to use the full range of our Services.
Purpose of Processing with the held of cookies and similar technologies. We use the collected data to enable providing the Service according to the habits of a Visitor / User, to ensure the best Service quality, to inform the Visitor about the contents and give recommendations, and to update advertisements and make marketing efforts more efficient. The collected data will also be used for counting the Visitors / Users and recording their habits. Read more from the Cookie Policy.
4. Legal Grounds and Purposes of Processing
Provision of Services. For Personal Data about Users, AV Tech’s main purpose for processing is to verify your identity for our Clients, and for this purpose we capture biometric data (i.e., identifiers and information).
We or our Client may ask you to grant us consent for Processing. Please note that we cannot provide the Service for an anonymous User, and thus using our Service is subject to disclosing Personal Data to us and consenting to the Processing of Personal Data by the Client and us. However, giving consent is voluntary, but failing to do so might mean that we might not be able to provide you with the Service. For example, we will not be able to verify your identity. In some circumstances, e.g., for automated decision-making, you might be asked to provide us with explicit consent. If you have granted the Client or us a consent to Process Personal Data, the details of that processes and purposes of it will be outlined in the consent itself.
We mainly Process your Personal Data as a Processor for the Client’s benefit to fulfill the Agreement entered into with the Client for:
- performing the Agreement (including for providing the Service);
- performing the obligations arising from the Agreement (including realizing rights arising from providing the Service);
- for realizing rights and fulfilling obligations deriving from legal acts; and
- processing your inquiries and requests.
We also Process your Personal Data if Processing is necessary in our legitimate interests, meaning our interest in the management and direction of our business to be able to offer the best possible services on the market. For our legitimate interest, we may Process data for the following purposes:
- for analyzing the use of our Service, and using research and analysis results, among other methods, for carrying out satisfaction surveys, feedback questionnaires, and developing our products and services, including development of autonomous and automated decision-making processes;
- for transmitting information about our Service;
- for sending out newsletters, for marketing and developing and promoting our Services, for organization of campaigns, including personalized and targeted campaigns, and measuring the effectiveness of the performed marketing activities. Please note that for sending out newsletters, we only Process your contact details;
- for ensuring a trust-based relationship with Clients and Users;
- for administration and analysis of the Client base to improve the availability, selection, and quality of Services and products, and to make our Services more personalized and the best possible;
- for analysis of identifiers and Personal Data collected on using websites, mobile applications, and other Services. We may use the collected data for web analysis or for the analysis of mobile and information society services, for ensuring and improving functioning, for statistical purposes and for analyzing Visitor and Client representative behavior, and for improving the experience of Visitors and Client representatives and for providing better and more personalized Services;
- for monitoring the Services. We may record the messages and instructions given by means of communication (email, telephone, etc.), as well as information and other operations carried out by us, and will use those recordings as needed to evidence instructions or other operations;
- for network, information, and cyber security considerations, for example, for fighting against piracy and for ensuring the security of the Website and Service, as well as for the measures taken for making and storing backup copies;
- for establishing, exercising, or defending legal claims;
- for conducting product and market research for quality assurance, product improvements, developments, and assessing its market fit, this includes contacting and communication, interviews, making conclusions, recording of those communications for a limited period, etc. with Users, Client’s representatives, and other relevant data subjects. This includes creating anonymized or aggregated overviews and summaries of these;
- for obtaining the, and retaining Personal Data to prove the obtaining of, relevant legal basis for Processing certain Personal Data (e.g., biometric information and identifiers) concerning certain Users, as required under laws applicable to those Users (e.g., Users originating from the states of Illinois, Texas, and Washington). Obtaining and maintaining records that the legal basis has been obtained by us is important for us to be able to prove that we comply and adhere to our legal obligations outside of and in the European Union;
- for fraud prevention and detection purposes; and
- for machine learning purposes, as specified below.
In addition, we may provide status information on our web pages and Service with the held of a third-party service provider.
We only Process Personal Data on this legal basis (legitimate interest) after careful assessment to ascertain that the legitimate interest is in compliance with the interests and rights of a Data Subject.
Processing for a new purpose. When Personal Data Processing is carried out for a new purpose different from those for which the Personal Data was originally collected or is not based on the consent given by the Data Subject, we will carefully assess the permissibility of that new Processing. To determine whether the Processing for the new purpose follows the purpose for which the Personal Data was originally collected, AV Tech will consider the following:
- any link between the old and new purposes for which the Personal Data was collected and the intended further purposes of Processing;
- the context of collecting the Personal Data, in particular about the relationship between the Data Subject and us;
- the nature of the Personal Data, in particular whether any special categories of Personal Data are processed;
- possible consequences of the intended further Processing for the Data Subjects; and
- existence of appropriate protection measures that might consist in, for example, encryption and pseudonymization.
5. Service development, process, and provision (Automated Processing and decision making)
Machine learning helps to recognize specific patterns in information and make predictions about new sets of information based on those patterns. Algorithms are built, trained, and tested on training sets, which comprise of real data. No biometric data including “biometric identifiers” or “biometric information” is used to train AV Tech’s machine learning training. That processing is only done for internal use to improve and develop our services and done only based on the contractual mandate received from our Clients under the precondition that a valid legal basis has been obtained.
AV Tech also uses machine learning to provide Services to our Client. AV Tech stands for the concept that machine learning is conducted in an ethical and trustworthy way that respects human rights and freedoms. Machine learning as a tool will enable Users to receive better, more secure and faster services provided by AV Tech’s Clients and help to prevent and detect fraud. Datasets used to develop, test, and train are kept in separate, monitored, and highly secure data research environments. Machine learning is also the driving engine for AV Tech’s innovation when improving our Services, testing new features, and ensuring quality Services.
For fraud prevention and detection purposes, AV Tech also checks whether facial images show signs of fraud. To provide this check quickly, in a secure and accurate way, numerical biometric data is extracted from previously collected facial images and device and network information is retained for a limited amount of time as agreed with AV Tech’s Clients. For each verification session, AV Tech captures a new facial image from the User and compares the data derived from the capture to the data we have retained for them.
For further improvement of our Services, Service performance and features testing (A/B tests) is used to analyze the User experience and response regarding changes to the structure, text, or any other feature of AV Tech’s Service.
The verification process is either automated or semi-automated:
- Semi-automated verification process. A human will be involved if the automated verification tool (the Robot) is not able to reach a decision on its own. This might occur, when the picture is blurry, or the Robot runs into some other difficulty in analyzing the verification session. The Robot is constantly learning to correctly give meaning to information and to detect identification. We hope that together with the combined power of the Robot and humans, we can make your identification and verification process as easy and safe as possible.
- For fully automated decision-making, where the decision has a significant effect on you, we will be transparent about that processing. When performing fully automated decision-making, our Client asks for your explicit consent to do this and informs you of the automated processing. In some cases, where the Client has other legal grounds for that Processing, e.g., obligations under law, consent might not be needed. You may ask for information and an explanation about the logic behind the decision the Robot has made; at any time, you may request human intervention or object to the decision made on grounds relating to your particular situation.
The decision on whether the Client provides its service to the User is made by the Client. Meaning, even if the verification flow has been fully automated, the Client will take the verification result into account in decision on whether to provide its service or not. The verification results itself are not determinative for whether the Client’s service is provided to the User.
6. Disclosure of Personal Data
We may disclose aggregated information about our Users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we Process or you provide as described in this privacy policy:
- To our subsidiaries and affiliates.
- To Data Controllers for whom we are Data Processors (e.g., Clients).
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of AV Tech’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by AV Tech about our Users and Visitors is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the data.
- With your consent.
- We will not sell any data that is created with our relationship with Gatsby Enterprises, Inc.
We may also disclose your Personal Data:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AV Tech, our customers, or others. This includes exchanging information with other companies and organizations for cybersecurity, fraud protection, and credit risk reduction purposes.
7. Transfer of Personal Data
We are based in the United States of America. For operational reasons we may Process, store, and transfer the Personal Data we Process, in and to a country outside your own, with different privacy laws that might or might not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your Personal Data receives an adequate level of protection where it is processed, including, but not limited to, relying on adequacy decisions issued by or standard contractual clauses approved by the European Commission. In cases where AV Tech acts as the Data Controller, we will make available further information on the safeguards applied (if relevant) on your request.
If you are a Canadian resident or otherwise located in Canada, please note that Personal Data transfers outside of Canada might result in your data becoming accessible to foreign jurisdiction’s law enforcement or other authorities.
8. Your Personal Data use choices
We strive to provide you with choices about the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your data:
- Tracking technologies and advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website might then be inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.
- Promotional offers from AV Tech. If you do not wish to have your email address used by AV Tech to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to privacy@adultvi.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to AV Tech as a result of a purchase, service experience, or other transactions.
We do not control third parties’ collection or use of your Personal Data to serve interest-based advertising. But these third parties may provide you with ways to choose not to have your information collected or used in this way.
9. Accessing and correcting your Personal Data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your Personal Data changes. You may request access to and to correct the Personal Data that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of (if allowed by the law of your jurisdiction) your Personal Data, you may send us an email at privacy@adultvi.com to request access to, correct, or delete any Personal Data that you have provided to us. Please note that if you withdraw your consent, we might not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. In some circumstances, we cannot delete your Personal Data except by also deleting your account. We will not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect. Unless prohibited by law, we may charge you a fee to access your Personal Data, however, we will notify you of any fee in advance.
We may request specific information from you to help us confirm your identity and your right to access and to provide you with the Personal Data that we hold about you or make your requested changes. Law may allow or require us to refuse to provide you with access to some or all the Personal Data that we hold about you, or we might have destroyed, erased, or made your Personal Data anonymous under our record retention obligations and practices. If we cannot provide you with access to your Personal Data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
10. Data security
The security of your Personal Data is very important to us. We do our best to protect Personal Data in our hands.
We use physical, technical, and organizational safeguards designed to protect your Personal Data from unauthorized or arbitrary modifications, disclosure, acquisition, destruction, loss, theft, misuse, alteration, or unauthorized access.
Unfortunately, the transmission or storage of information through the internet is not completely secure. Thus, despite the security measures that we have put in place to protect Personal Data about you, we cannot guarantee that loss, misuse, or alteration of data will never occur. If you have any information about an actual or suspected data breach, please inform us immediately at privacy@adultvi.com.
11. Data retention
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data and the purposes for which we Process it. We must also consider periods for which we may need to retain Personal Data to meet our legal obligations or to deal with complaints or queries and to protect our legal rights in the event of claims being made. Any data retention periods referenced here that would be more than three years are not applicable to Personal Data qualified as biometric identifiers or biometric information for Illinois law. For Texas, the preceding is limited to one year, dated from the collection of that information.
We will store your Personal Data for as long as required by law or in accordance with the law, or for the purposes stated in this privacy policy.
We store the data of Users during the period set out in the Agreement (we may have different data retention periods agreed on with the Client lasting up to three years) or as long as it is necessary for possible establishment, exercise, or defense of legal claims of Users, Clients, or ourselves.
We may store your Personal Data, for a longer period than the Agreement duration if we have a lawful basis do to so, e.g., you have given us consent to use your Personal Data for the development of our Services or we have assessed that we have legitimate reason to do so, e.g., in pseudonymized form or for the Service history log.
After the Personal Data storage period expires, we will anonymize or permanently erase your Personal Data.
12. Children’s Personal Data
Our Website and Service is not intended for persons under 18-years old. No one under 18-years old may provide any Personal Data to or on the Website. We do not knowingly collect Personal Data from persons under 18-years old. If you are under 18, do not use or provide any Personal Data on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any scree name or username you might use. If we learn we have Processed Personal Data from a person under 18, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at privacy@adultvi.com.
13. Do Not Track policy
Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information it collects and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information about DNT, visit www.allaboutdnt.com.
14. Notice to Illinois, Texas, and Washington residents
The Illinois Biometric Information Privacy Act, the Business Code of Texas on the Capture or Use of Biometric Identifiers, and the Washington Biometric Privacy Law regulates the collection, storage, use, and retention of “biometric identifiers” and “biometric information.” “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions including height, weight, hair color, or eye color. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.
AV Tech collects certain biometric identifiers and biometric information, namely face scan information (face geometry information and information based on that), during the identity verification process. Collection of this information is required to verify your identity or authenticate your identity against data already obtained about you based on instructions from AV Tech’s Client. This information is only retained for the period required for the verification and authentication process or for the period required by the Client, but this data will not be retained for more than three years after your last interaction with AV Tech for the residents of the State of Illinois and more than one year after your last interaction with AV Tech for the residents of the State of Texas. By providing your consent for the verification process, you consent to providing AV Tech with biometric information and identifiers and for AV Tech to use and store that information for verifying and authenticating your identity and as otherwise required by the Client and disclosure of your biometric information to its service providers to provide the Service.
AV Tech uses the reasonable standards of care within its industry to store, transmit, and protect from disclosure your facial scan information, in a manner that is the same as or more protective than the manner in which it stores, transmits, and protects other confidential and sensitive information. AV Tech will not sell, lease, trade, or otherwise profit from the biometric information and identifiers than to provide the Services to its Client.
For disclosures of the preceding information, please see paragraph 6 of this privacy policy.
15. Your California privacy rights
If you are a California resident, California law may provide you with additional rights about our use of your personal data. To learn more about your California privacy rights, visit this link. As a “Service Provider” as defined in the California Consumer Privacy Act (CCPA), AV Tech will not sell, retain, use, or disclose personal information for any purpose other than as set out in the Agreement or as otherwise permitted or required by the CCPA.
California’s “Shine the Light” law (Civil Code Section 1798.83) permits Users and Visitors of our Website who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make that request, please send an email to privacy@adultvi.com.
16. Your Nevada privacy rights
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@adultvi.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
17. Your EEA and UK privacy rights
If you live in the EEA or UK, under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Your rights may include the following:
- Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we might not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
- Request restriction of processing your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above or ask questions about the privacy policy, please contact us at privacy@adultvi.com. We will respond to your request by email as a rule within one month. Before we can provide you with the requested information regarding your Personal Data, we may need to verify your identity. If your request concerns data we have Processed as a Processor (i.e., while providing Services), you must submit your request to the Client who is the Data Controller of Processing of your Personal Data who might fulfill the request. We will inform you if this is the case. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If you live within the EEA, you have the right to make a complaint at any time to the appropriate supervisory authority for your country of residence. See http://ec.europa.eu for those details.
If you live in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance.
18. Changes to our privacy policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat Personal Data, we may notify Clients and Users whose contact information we have or through a notice on our Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
19. Contact information
To ask questions or comment about this privacy policy and our privacy practices, contact us at privacy@adultvi.com. We have procedures in place to receive and respond to complaints or inquiries about our handing of Personal Data, our compliance with this policy, and our compliance with privacy laws. To discuss our compliance with this policy, please contact us.