Privacy Policy for Models and Studios

This document was last modified at 25 May, 2018

We have recently updated our Privacy Policy to comply with the new requirements set out by the EU General Data Protection Regulation and to make it easier to read. The updated Privacy Policy automatically comes into effect for all existing users on May 25, 2018. Your continued use of our site from that day on will be subject to our new Privacy Policy.

SoulCams is an adult entertainment site, which offers live cam performances and other related adult services.

When you decide to register on SoulCams directly as a Model, under a Studio, or as a Studio, and provide live cam performances and other services, we will collect some of your personal information. Because we want you to use our site in a peaceful and trustworthy way, please be assured that we are fully dedicated to the protection of the information we get from you.

Because your privacy is so important to us, we provide you with this Privacy Policy, explaining how we collect, use and share your personal information, so that you can make informed choices about the use of your data.

Please read this Privacy Policy carefully, we have tried to write it in a way, which is free of long boring sentences and legal terms. You can contact us if you have any question about our privacy practices or about what we are doing with your personal information and we will be happy to provide you any assistance you may need.

WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The company, which decides how and why your personal data is processed, and which is called “Data Controller” is:

Fluffy Stone Media GmbH, a private limited liability company with the registered address at Klostergartenstrasse 14., 54340 Leiwen, Germany, with the registration number HRB 42.

What Personal Data do We Process?

We provide two possibilities to create account(s) on our site:

• Signing up as a single Model: you can register directly and individually as a Model;
• Signing up as a Studio: you can create a Studio account including several Models accounts. If you are the creator of the account, and therefore named “Studio”, you can either be (i) a Model yourself willing to provide services on our site and open a Model account under your Studio account, (ii) or a person (natural or legal) having contracted with Models and opening a Studio account to enable the provision of services by them.

This Privacy Policy applies to you, whether you are a Model who registers individually or under a Studio account, or if you are a Studio.

We collect, use, share, transfer, and store different types of your personal data as a result of your registration and provision of adult entertainment services or other services on our site.

The personal data we collect includes the following categories of data:

Personal data you give to us

If you create your Model account yourself, you will directly provide us with this information. If the Studio will create your Model account, then the Studio will provide us with some or all of the information below.

When you create a Model account on our site and complete your profile

When you create a Model account on our site, we require important details about you:

• your email address;
• your password;
• the category and characteristics (for example, girl,couple, blonde etc…) under which you wish to provide services;
• your performer username;
• your identification information, that is to say your full name, date of birth, gender, country, nationality and ethnicity. We will also request from you to upload an official document, such as your ID card, passport or driving license, for identity verification purpose;
• your physical characteristics;
• your sexual preference;

Once your account is created, you can, through your account settings:

• add any information about you, as well as about your preferences;
• you can select what you are willing to do in private;
• upload profile pictures and other pictures to your gallery

When you create a Studio account on our site and complete your profile

When you create a Studio account on our site, we require important details about you:

• your email address;
• your password;
• your identification information, that is to say your full name, date of birth, gender, country, nationality and ethnicity. We will also request from you to give details and upload an official document, such as your ID card, passport or driving license, for identity verification purpose.

Once your account is created, you can, through your account settings, add any information about you, including your age, your physical characteristics, or your preferences. This makes sense if you are yourself a Model willing to provide services on the site.

When you contact our Support

We collect all information you choose to share with our Support, like:

• your personal e-mail;
• the services, customers or other Models associated with your request;
• your comments or opinions about a customer or another Model and your conversations with Support.

More generally, when you communicate with us in any other way, we will collect whatever information you provide us with.

When you complete the payout page

When you complete the payout page in order to receive payment of your fees, we will collect the information that you enter on that page, that is to say:

• your billing address;
• depending on the payout method you choose (for example, wire transfer or by mean of a virtual account), your account information or other identification or payment information;
• the identification details and address of your beneficiary, if you have chosen one.

Please note that, if you choose to receive your money through a virtual account, we will not be responsible for the data you provide to this third party to create and manage your virtual account. Please check directly the privacy policy of the virtual account provider if you want to learn more.

If you wish to change your payout details, you can do so at any time by going to the Settings / Account and Payment settings menu in your account or by sending an email to support@soulcams.com from the email address you used to register on the site.

Personal Information we get when you navigate or offer services on the site

We collect certain information about you when you are navigating on the site, offering live cam performances and other related services on our site.

Concretely, this means that, when you are browsing on the site, go online, offer services, or take any action on our site, we collect certain information about you.

Usage information

We collect information about your activity on our site and about how you interact with the features of the site. Basically, we know:

• your activity history on our site;
• the time you spend in private chat;
• what kind of special features you used on the site, for example, if you uploaded content on your wall or fan club page or if you participated to a video contest.

We also collect information about how you communicate with guests or registered customers, such as:

• the time and date of your communications;
• the type of communications (for example, a comment, private chat, messages through the inner-messaging system).

Content information

We collect any content you share on our site, such as pictures you upload to your gallery, the text you publish, messages you send or receive in private chat or during live shows, and information about the content you create or provide. Finally, we collect communication data such as chat logs, text messages, emails you send to us.

Earnings

Based on your activity on our site and the amount paid by the customers to benefit from your services, we calculate what your earnings are on a given period.

You can access the details of your earnings in your account at 'Statistics' menu.

As a Studio, you can see the earnings of the Models under your Studio account. The display of income statistics to Models under a Studio account is optional.

Log data and device information

We automatically collect log data and information from or about your computer, or other device you use to access our services or navigate on our site. This includes:

• your IP address;
• the date and time you logged in;
• types of features you use;
• the hardware, software or internet browser you use;
• your camera settings;
• identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

If you are using a mobile device, we might also collect:

• data that identifies your mobile device;
• device-specific settings and characteristics;
• location details;
• app crashes and other system activity.

Information collected by cookies and other technologies

Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device.

Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may affect your use of our site. To learn more about how we use cookies and your choices, please check out our Cookies Policy

Personal data you give to us that we need to create an account

The personal information we collect may also come from third parties, such as partners and service providers, to the site. These third parties assist us in maintaining data accuracy and providing and enhancing the services. We are also dealing with partner ad networks, which help us to promote our site SoulCams.com. For example, we might receive information about your experiences and interactions from our partner ad networks.

We are also managing an ad network ourselves and may receive information about your experiences and interactions with our ad published on third party or affiliated sites.

Personal data we collect from publically available sources

We collect publically available information about you only when it is necessary to prevent fraud and illegal activities on our site (for example, when we witness child abuse cases, or pedophile activity, etc.).

This data may comprise publically available information you share on social media like Facebook, your blog or site, and other public data available on the internet.

This information is always associated or combined with the data we collect through our site in order to finalize our investigation before reporting any fraud and illegal activities to authorities. We never use publically available data for any other purpose.

DO WE PROCESS SENSITIVE PERSONAL INFORMATION?

We process the following sensitive information about Models:

Your sexual orientation and data about your sexual life

SoulCams is an adult entertainment site and we are processing data about your sexual activity, and possibly about your sexual orientation, unless you registered under a non-adult category. When you register as a Model on our site or when your Studio registers you on the site, you or the Studio choose the category under which you wish to provide services. Due to the explicit meaning of each category name, it is possible that the chosen category reflects your sexual orientation and sexual life. In the course of your registration, we also ask you to provide us with your sexual preferences. We understand that this may not explicitly reflect information about your life outside of the site. It may only be a role you choose to play for the provision of the services. However, in order to provide you with the highest level of data protection, we treat this information as sensitive.

In addition, given the nature of our site, and depending on what you decide to show to customers, we may have explicit sexual content (uploaded pictures) about you.

Information showing your racial or ethnic origin

When you register as a Model on our site or when your Studio registers you on the site, we ask you or the Studio to provide your race (for example, Awhite, latina, Asian etc). We understand that this data may not explicitly reflect information about your real origin outside of the site. It may only be a role you choose to play for the provision of the services. However, in order to provide you with the highest level of data protection, we treat this information as sensitive.

What are the most important consequences of the processing of your sensitive data?

Data relating to your sexual life and to your ethnicity are essential aspects of privacy, that you however decide to make public, under your screen name, when registering on our website for the purpose of provision of services. However, we are fully aware that any breach of security, which would allow a non-authorized third party to make a link between this data and your real identity, may considerably affect your privacy, including your family life, and possibly your reputation.

To prevent this from happening, we are maintaining very high IT security standards, and we are periodically proceeding with controls and assessments of our security measures, in order to guarantee a trustworthy environment.

What are Your Choices?

We will always ask you to agree to the use of your sensitive data. If your Studio has made your registration and creation of account, because we do not have direct relationship with you at that time, your Studio shall be responsible to ask your consent for the use of your sensitive information beforehand.

Please note that, due to the nature of our site, refusing to provide or revoking your consent to have this data collected and processed by us means that you will not be able to register as a Model or to log in your account.

Why do We Process Your Personal Data?

We use the information we collect for the following purposes:

Open your Model/Studio account and allow you to offer services

First and foremost, we use the personal data you or your Studio give us at the creation of your account to open and administer your online account and allow you to do a number of activities on our site.

Whether you are a Studio or a Model, your account is also a way to exercise control over your personal data. In your account, you can manage your category under which you are providing services, your physical and personality characteristics, what you are willing to do in private, and other personal settings. You are in control of what you use to complete your profile, and can choose the content you wish to share with us and with the guests and members.

We process this information given our legitimate interest in providing you the services you requested.

If you fail to provide minimum details about you, the consequence will be that we will not be able to create your account and/or allow you to offer your services on our site.

Improve and promote our services

We use your personal data for statistical and analytical purposes. We place great emphasis on the improvement of our services and on the enhancement of your experience.

For example, this helps us to generate statistical reports, such as statistics report on Studio and Model earnings per countries or categories.

We also process the personal data relating to your activity and income to provide you with a feedback on your performance, for example regarding your broadcasting time and earnings. Please note that we display income statistics and a payout overview in the payout section of your account.

We also use your personal data for testing purposes, troubleshooting and improving the functionality and quality of our online entertainment services. Our main goal is to optimize our site and services to your needs, in order to make them easier and more enjoyable to use.

We have affiliate programs through which webmasters can help us to promote our sites, you can find them here. Depending on the tools the webmasters subscribed to, we may share certain of your data with them in order to promote your services and our sites. Please see WHO WE SHARE YOUR DATA WITH? for more information.

We use limited information to tailor our site for you. For example, when you visit and login on our site, we use your IP address to determine the country where you are from, and display our webpages in your language, so if you visit or login on our site from the United States, our site will automatically display content in English.

Finally, please be aware that any information that you made public on our site may appear in search engines results.

We process this information given our legitimate interest in developing and improving our site and our users’ experience, as well as to promote your services and our site. This is in both of our interests.

Model/Studio relationship management and communication with you

Sharing your personal details with our Support team allows us to respond to any question you might have about our services.

All your communications with our Support Team and all information you provide in the course of such communications, including any review or opinion about a customer, guest or another Model are collected and analyzed so that we may respond to your request. We can also ensure this way full compliance of all users of our site with our terms and conditions.

Finally, be aware that, when receiving a request or claim from you, our Support Team can access all information you give to us and all information we collected about you within the course of your use of our site. We want to make sure that our Support team has all information needed to appropriately and immediately respond to your request, but also to be able to detect any fraudulent activity.

Please note that we may also communicate with you through emails or any other means, if appropriate, in order to inform you of certain changes regarding our site or of certain events, for example, when you successfully register on our site.

We organize contests from time to time and we use your e-mail address to invite you to participate in the said contests.

We process this information given our legitimate interest in improving our users’ experience and delivering appropriate services to you.

Payment and Accounting

We use your data for payment and accounting purposes, to process transactions and maintain legally required business records.

We also use your data, if necessary to investigate any issues we might encounter with your bank, for example, an impossibility to process any bank transfer on your account.

We process this information, as it is necessary for the adequate performance of the contract we have with you once you register on our site.

Ensure a safe and trustworthy environment

Because we want to create and ensure a safe environment where you can peacefully use our site and offer services, we use your personal data to detect and prevent fraud and other illegal activities on our site.

We also use your data to detect potential breaches to the rules of our site, as explained in the Services Agreement.

Finally, we use your personal information for security purposes and risk assessment, such as to authenticate you on our site, verify your identity, and ensure that you are above the age of majority in your country.

We process this information given our legitimate interest in ensuring compliance with the rules of our site, fraud detection and prevention, as well as, information, system, network and cyber security.

Marketing

This will allow you to receive newsletters and be informed of contests, promotions on the site.

Provided that you agree to receive such type of communications, we will send you marketing emails, however you can unsusbscribe from such emails any time by clicking on 'unsubscribe' at the bottom of the email or by going to menu 'Settings / Notifications' in your Performer/Studio account.

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data, such as for accounting purposes, to respond to requests of competent authorities or to establish, exercise or defend legal claims.

We may combine your information with information lawfully obtained from other third party sources and use it for the above purposes.

How do We Protect Your Personal Data?

We implement serious security measures to grant maximum protection to your personal information against unauthorized access, modification, disclosure or deletion. Your data is always protected by our highly sophisticated security systems.

We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our site and the entire IT infrastructure related to it are updated against the latest network security vulnerabilities. We periodically test our IT systems and do sophisticated penetration tests. Our site incorporates the most advanced security technologies available in order to ensure maximum safety of its users and the safekeeping of their related information.

WHO WE SHARE YOUR DATA WITH?

We share certain of your data with the following parties:

With the guests and/or customers

Please note that the data you use to complete your Model’s profile will be publicly visible to guests and/or customers (such as your screen name, your category, physical characteristics, etc…).

You are in control of what you choose to put in your profile and you may also freely choose to share additional information about you, including text, uploaded pictures

Be assured that we will never publish any identification details about you, which would permit to find your real identity (for example, you name and family name, your address, your birthdate, your ID card info, etc…).

Webmasters participating to our affiliate programs

We have affiliate programs through which webmasters can help us to promote our sites, by using different tools. Please find them here.

Please be aware that by registering and providing services on our site, you will appear on our site SoulCams.com

On a general basis, we will not share any of your personal data with webmasters of affiliated sites, who will only see the data that you made public and that are visible by guests or members, unless the webmaster subscribed to a specific promotional tool.

We offer to webmasters having a whitelabel site or a third party site a promotional tool called “Model Feed” in order to promote your activity and ours. If they subscribe to this tool, we will share the following information about you with them, so that they can make your promotion and ours by building their own list page:

Username Online status (free chat, private chat, offline) Ethnicity Category Country Banned country/ countries Direct link to your chatroom Model rating Pay per minute price Stream quality Biography/ turn ons/ turn offs (available on the public profile page) Languages Willingness list Gender Age Sexual preference(s) Physical characteristics Please note that if you indicated through the list of banned countries, the territories where you do not want to appear, the webmasters are of course responsible to take this list into account.

We also offer the option to webmasters to refer Models and receive referral commissions. As their commission is proportional to your earning, they can get an idea of what your earning are.

Entities of our company’s group

We share your personal information with certain companies of our group in Luxembourg, Hungary, and the US, as they are helping us to deliver the services to you:

Docler Holding S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg; Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg; Docler SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary; Docler Media LLC, 8000 Beverly Blvd, Los Angeles, CA 90048, USA. Please note that certain of our servers are located in the US and in Singapore. They contain limited information about you and help us to provide a good quality of transmission in other parts of the globe.

Service providers

We use carefully selected and trusted third parties, who act as service providers to our site.

We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

As we are constantly working on the development and enhancement of the technology to support our site, our third party service providers that are in use may regularly change. Such entities mainly belong to the following areas: (a) business intelligence and analytics; (b) customer care; (c) marketing and sales.

Payment providers and financial institutions

For payout purpose, we may share certain information with a third party bank or payment processor.

You may receive transactional emails from this party confirming the payment, including dispatch and follow-up invitations to leave feedback for this party.

We may furthermore share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.

If you share information with third parties directly, this Privacy Policy does not govern that information.

Law enforcement agencies or governmental authorities

We may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our Services Agreement, and/or (d) protect our rights or defend ourselves against any claims.

Business transfers

Finally, please also note that your information may also be transferred to another company in the event of sale of the whole or part of our business to a third party.

How do We Transfer Your Personal Data Outside of the European Economic Area?

As we are a Luxembourg based company, we comply with the EU Data Protection Regulation commonly called “GDPR” (If you want to learn more you can check: EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC), which provides a high level of protection of your personal data.

In the course of the operation and exploitation of the site and the provision of the services, your personal information may be transferred outside of the European Economic Area ("EEA") to our affiliated companies or to third parties data processors located in the US or Asia, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

What are Your Rights Regarding Your Personal Data?

We did our best to explain what your rights are and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, do not worry, our Support Team will provide you with all the assistance you need when exercising your rights. You may also contact us, at any time, before exercising any of your rights, and we will reply to your request as quickly as possible.

Please note that we created a specific interface called “Privacy Rights” in your account settings in order for you to be able to easily exercise certain of your rights.

Our Support Team will provide you with information on actions taken within one month of the day of receipt of your request. Only in exceptional circumstances, when we face complex or a high number of requests, we may extend this period of response up to 60 days.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Data access and data portability

You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge through the “Data Download” section in your account settings.

Upon verification of your identity, your request will be sent to our Support Team.

If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period of time), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you the information.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). For this purpose, you can send an email to support@soulcams.com

Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can send an email to support@soulcams.com

Data retention and erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations.

If you no longer want us to use your information, you can request that we erase your personal information and close your account. In such case, please select “Forget my Data” in the “Privacy Rights” section of your account settings.

Your request will be sent to our Support Team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time.

Please note that if you request the erasure of your personal information:

We might retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we close or suspend your account for fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information shall also be kept available in case of ongoing judicial proceedings and/or investigations.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that according to Luxembourg legislation financial related information shall be kept for a period of ten years.

Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.

In order to protect our site and your personal information from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Right to object

We process your data for a variety of reasons as explained in “4. WHY DO WE PROCESS YOUR PERSONAL DATA?”. Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to the use of your data might disable the use of your account.

Please note that you may, at any time, ask us to stop sending you marketing emails by opting-out in your account settings.

Right to restriction of processing

You have the right to request that we hold your personal data in “limbo”, while other challenges are resolved.

Basically, you can ask us to put on hold the use of your data in 4 cases:

If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.

You have objected to a processing activity based on legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.

You consider that the processing is unlawful but you object to erasure and request restriction, instead.

We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority, (in particular in the Member State where you live), place of work or of an alleged infringement of the GDPR.

Changes to Our Privacy Policy

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the relevant site and/or contact you using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force. Your continued use of our site from that day on will be subject to the new Privacy Policy.

How to Contact Us?

If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to support@soulcams.com or via mail to the address indicated below, and we will get quickly back to you. We are always glad to talk about our privacy practices.

Duodecad IT Services Luxembourg S.à r.l. 44, Avenue John F. Kennedy L-1855, Luxembourg Grand Duchy of Luxembourg