Last modified: April 2023

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

When you decide to register on LiveJasmin directly as a model (“Model”), under a studio (“Studio”), or as a Studio, and provide live cam performances and other services (hereinafter, the “Services”, as defined in the Services Agreement), we will collect some of your personal data.

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 your personal data. 

We operate our site and our services in compliance with applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”). For more information, please see Section 7 “Your Rights Under GDPR”. If you are a California resident, please also see Section 8 “Information for California Residents.”

Your privacy is important to us. We provide you with this Privacy Policy, so that you can make informed choices about the use of your data. This Privacy Policy describes how we collect, use, share, and store the personal data of Models and Studios. Please note that this Privacy Policy only applies to the personal data of Models and Studios. Personal data of guests (“Guests”) and members (“Members”) is governed by a separate Privacy Policy. 

As used in this Privacy Policy, the term “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Please read this Privacy Policy carefully. This Privacy Policy forms a part of and is incorporated into the Services Agreement. By using the LiveJasmin website and providing your Services you agree that the Services Agreement, including this Privacy Policy, forms a binding legal contract with you. You can contact us if you have any question about our privacy practices or about what we are doing with your personal data and we will be happy to provide you any assistance you may need.

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

The following companies decide how and why your personal data is processed, and for GDPR purposes, are “Joint Controllers”:

JWS Americas S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249539.

JWS International S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249566.

JWS Americas S.à r.l. and JWS International S.à r.l. jointly determine the purposes and means of the processing of your personal data. Both entities collaborate in joint processing activities related to the purposes mentioned in this Privacy Policy.

We have put in place a joint controllership agreement (according to article 26 GDPR) in order to determine the respective roles and responsibilities of the Joint Controllers, in particular, as regards the exercise of data subjects’ rights and the duties to provide information. You can notably contact us through a single contact point as mentioned in Section 9 of this Privacy Policy.

Please note that, irrespective of this arrangement, you are free to exercise your rights (as described in the Privacy Policy) in respect of and against each of the Joint Controllers. You also have the right to contact us and request to be informed about how the responsibilities are allocated between the two companies.

2. WHAT PERSONAL DATA DO WE PROCESS?

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

• A single account: you can register directly and individually as a Model;
• A Studio account: 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 them to provide Services on our site.

 This Privacy Policy will apply to you regardless of what kind of account you decide to create/register.

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:

2.1. Personal data you provide

Please note that if your account has been created as part of a Studio, the Studio will provide us with some, or all the information indicated below.

• Model account

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

• your email address;
• your password;
• the category (for example, hot flirt category, nude category, etc…) and characteristics (for example, boy, girl, gay, fetish woman, transgender, etc…) under which you wish to provide Services;
• your screen name;
• your display name;
• your identification information, that is to say, your full name, date of birth, gender, country, nationality, and We will also request that you 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 videos or pictures on your ”My Content” page;
• provide your “My Story” content to the site.

Providing this information about you is optional, and you may choose to do so to increase your earnings by providing more Services. You can delete this data from your profile at any moment, which will not affect your use of the site.

When a Member send you a gift (hereinafter “Jasmin Gift”), our Model Support will contact you in order to inform and ask you if you want to receive it. If you give your consent to receive it, we will collect:

• your delivery address
• your size

Accepting and providing the above information about you is optional and you may choose to receive the Gift item or not. You can also choose to provide the information each time a Member is sending you a Gift or, if you prefer, you can give your consent also for the future Gifts. Once you accepted to provide the consent also for future Gifts, if you do not want to receive anymore them, you can withdraw your consent at any moment.

Please also be aware that any content you provide to the site is subject to intellectual property protection. Read the Terms and Conditions for the specifics of how you are affected.

• Studio account

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 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.

• Billing support & Model support

We collect all information you choose to share with our Billing support & Model support, including, without limitation:

• your personal e-mail;
• the Services, Members or other Models associated with your request;
• your comments or opinions about a Member or another Model and your conversations with the relevant support team.

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

• Getting assistance from our Business Development Team and/or enrollment in a business development program

We collect all information you choose to share with our Business Development Team, such as:

• additional contact information, such as a phone number or a skype ID;
• professional background and current position/title;
• interests;
• social media account;
• name and contact details of a person you are referring.

• Pay-Out page

When you complete the pay-out page to receive payment of your earnings, we will collect the information that you provide via that page, including:

• your billing address;
• depending on the pay-out 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 applicable).

If you are a company, we will ask you to provide the identification details of the managing director or representative of your company.

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 the privacy policy of the virtual account provider directly if you want to learn more.

Please note that depending on your payout method, your payout will be processed by affiliates of our group or third parties payout processors/service providers as explained in Section 6.5. “Payment providers and financial institutions”.

If you wish to change your pay-out details, you can do so at any time by sending an email to payinfo@livejasmin.com from your registered email address and providing us with the following minimum documents:

• A scanned copy of your photo ID;
• A photo from you holding your ID next to your face.

2.2. Personal Information from Site Use

We collect and process certain information about you when you navigate on the site, offer live cam performances and other related services on our site.

This means that, when you browse 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, including:

• your activity history;
• the time you spend in private chat;
• the special features used (e.g. uploading content, video contest participation)

We also collect information about how you communicate with Guests or Members, such as:

• the time and date of your communications;
• the method of communication (e.g., a wall message, private chat).

• Content information

We collect any content you share on our site, such as pictures or videos you upload on your ”My Content” page, text you publish, messages you send or receive in private chat or during live shows, and information about the content you create or provide. We also know who purchased any specific content.

A few seconds of your live cam performances might also be recorded for quality and compliance check purposes. We will only keep these recordings for a maximum period of two weeks.

Finally, we collect communication data such as telephone conversations, chat logs, text messages, faxes and letters you send to us.

• Earnings

We calculate your earnings by given period based on the following:

• Your activity;
• Time spent online in a given period;
• Amount paid by Members.

You can access the details of your earnings via your account settings in the pay-out section.

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, phone, or other device you use to access or navigate on our site. This includes:

• your IP address;
• the date and time you logged in;
• the time spent online;
• pages viewed;
• features used;
• the hardware, software or internet browser used;
• information about your computer’s operating system, like application version;
• your language settings;
• 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.

Cookies / Other Technologies

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

We rely on your consent to use these technologies. Please keep in mind that removing or choosing not to accept cookies may negatively affect your use of the services on our site/app.

You can withdraw your consent or modify your cookies settings through the settings of your web browser or device.

To learn more about how we use cookies, and your choices, please check out our Cookies Policy.

HOTJAR

Hotjar is a 3rd party technology service that helps us better understand our users (e.g. which pages they spend the most time on, which links they click on, what they do and don’t like, etc.), enabling us to build and maintain our service with user feedback.

Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (e.g., IP address, device screen size, device type, browser information, geographic location (country only), preferred language, etc.). They store this information in a pseudonymized user profile.

Neither Hotjar nor we will use this information to identify individual users or to match it with further data on an individual user.

For further details, please see Hotjar’s privacy policy here.

You can opt-out of a user profile on Hotjar and Hotjar’s use of tracking cookies by following this opt-out link.

2.3. Personal data collected by third parties

• We collect information that users of the site, such as Guests, Members or other Models provide about you in the course of chat conversation or conversation with our Billing support and Model support
• If your registration on our site has been made by a separate organization/person, and that we call “Studio”, then be aware that the Studio may provide us with certain or all of the registration details mentioned in Section 2.1. “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 sites. 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.

2.4. Personal data we collect from publicly available sources

We collect publicly 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.), as well as to perform a general background check on you for KYC purposes in databases aggregating publicly available information.

This data may comprise publicly 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 publicly available data for any other purpose.

2.5 Notice Regarding Processing of Biometric Data for ID Verification

We would like to inform you that in accordance with the General Data Protection Regulation (GDPR), your explicit consent is required to process images of you for the purpose of verifying your identity. 

Indeed, as a company, we must double check your identity and not being able to do it would prevent us from creating your account on our website.

Please note that the images being processed may be considered as ‘biometric data’ (being a special category of personal data under the GDPR). As such, your explicit consent is necessary for us to be able to process this information.

The purpose of collecting this information is to ensure that you are registering under your genuine identity and that you are of legal age in your country (18 years old or over). By providing your explicit consent, you are allowing us to use the images you are providing to us (picture of your face and of your identity document(s)) for the purpose of identity verification.

We are using a third-party provider solution that is performing automated checks to verify that your ID is “valid” and has a sufficient quality for the purpose of verifying your identity.

3. DO WE PROCESS SENSITIVE PERSONAL INFORMATION?

3.1. We process the following sensitive information about Models:

• Your sexual orientation and data about your sexual life

LiveJasmin 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 certain category names, 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, 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 the Members, we may have explicit sexual content (uploaded content, stored live cam performances, or pictures) about you.

3.2. 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 ethnicity (for example, African American, Asian, Hispanic, 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, to provide you with the highest level of data protection, we treat this information as sensitive.

Data relating to your sexual life and 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. 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 high IT security standards, and we are periodically proceeding with controls and assessments of our security measures, to guarantee a trustworthy environment.

3.3. 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 created your account, because we do not have a direct relationship with you at that time, your Studio shall be responsible for asking 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.

4. WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect for the following purposes:

4.1. Account activation

• We use the personal data you or your Studio give us when creating your account to open and manage this account. The account then allows you to do several activities on our site, notably to provide the Services.
• Whether you are a Studio or a Model, your account is also a way to exercise control over your personal Through 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 to perform the contract that we have with you and provide you with the platform you can use to provide your Services.

If you fail to provide minimum details required, we will not be able to create your account and allow you to offer your Services.

4.2. Improve and promote our services

To understand how we can improve our services and to promote them to others, we collect your personal data for the following purposes:

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

For example, this helps us to generate statistical reports, such as the statistics on Studio and Model earnings per countries or categories. The information in these reports is in aggregate form and cannot be used to identify individuals.

• Feedback: We also process the personal data relating to your activity and income to provide you with feedback on your performance, for example, regarding your broadcasting time and earnings. Please note that we display income statistics and a pay-out overview in the pay-out section of your account.
• Improvements: We use your personal data for testing, 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, to make them easier and more enjoyable to use.
• Contests, games, events & awards: We organise contests, games and events occasionally, in order to allow you to increase your visibility and/or your earnings.

As regards the awards, we will process your total earning on a given period in order to establish your ranking and your total reward amount (if applicable).

We can also process your time spent online in order to calculate and establish an extra income for you as better specified in the Service Agreement.

In case any other game/contest is organized, we will process your results in order to provide you with the defined reward (if applicable).

The ranking of Models following the contests, games, awards may also be published on the site.

• Promotion of the Model’s Services and of the site

In case your earnings (or the earnings of a Model of your Studio) are amongst the top earnings in a given period, we may publish such information along with your display name and profile picture, as the case may be.

• Affiliate programs: We have affiliate programs through which webmasters or other third parties 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 to promote your Services and our sites. Please see Section 6 “WHO WE SHARE YOUR DATA WITH?” for more information.
• Tailored service: 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.
• Search engines: 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 promoting the services and our site. This is in both of our interests. When we use cookies or similar technologies for the same purpose (i.e., product enhancement and improvement), we rely on your consent to the use of cookies, including third-party cookies. To learn more about how we use cookies and your choices, please check out our Cookie Policy.

 4.3. Model/Studio relationship management

Model/Studio management is key to our service. The following are related instances where we collect and process your personal data:

• Model Support: Model support operates 24/7. By sharing your personal data with our Model support team, we will be able to provide you with your answers, and any help you may require, more efficiently.

All your communications with our Model support Team and any information you provide, including any comments/reviews of Members, Guests or another Model, are stored and reviewed so that we may respond to your request. This way we can also ensure the full compliance of all users of our site with our terms and conditions.

Some of these communications will be used for training purposes within the Model support team, so that we can provide you with an excellent service.

Please be aware that our Model support team will have access to all information that has been collected about you (on a need to know basis). By having this access, we ensure that our support team has everything they need to give you an appropriate and efficient response. This will also allow our support team to detect any fraudulent activity.

• Business Development team: Our Business Development team may also assist you in your activity. Sharing your personal details with our Business Development team allows this latter to help you in the development of your activity and/or to enroll in business development programs.

• General exchanges: Please note that we may also communicate with you through emails or other appropriate means, to inform you of any changes regarding our site or announcements relating to your account (e.g. successful registration).
• Contests, games: We organize contests and games occasionally, in order to allow you to increase your visibility and/ or your earnings. We may use your e-mail address to invite you to participate and inform you of the results.

We have a legitimate interest in improving our users’ experience and delivering appropriate support services to you.

4.4. Payment and Accounting

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

We also use your data, if necessary to investigate any issues we might encounter with your bank (e.g. bank transfer issues with your account).

The use of your personal data is strictly necessary in this instance in order to execute any payments for the adequate performance of the contract we have with you once you have registered on the site.

 4.5. Ensure a safe and trustworthy environment

To protect you and our business, we use your personal data in the following ways:

• To detect and prevent fraud/illegal activities;
• To detect potential breaches to the Services Agreement or to the rules of our site;
• For security & risk assessment (e.g. authentication & verification of identity).

We have a legitimate interest in keeping you and our business safe and ensuring compliance with the Services Agreement/rules, which attempt to guarantee this.

4.6. Sending of messages and marketing e-mails

• This will allow you to receive newsletters and be informed of workshops or events, which could help you to improve your Services or develop your activity.
• We will send you marketing emails, which could be tailored to your characteristics (such as your country).
• We also use your e-mail address to send you invitations to participate in our surveys to understand your opinion about our business and/or brand or otherwise with the aim to improve our services.

The sending of messages and marketing emails is based on our legitimate interest.

Be aware that you can very easily revoke your consent to receive such emails at any time in your “Consent Settings”. Revoking your consent means you might miss out interesting newsletters, workshops, and events, which could have helped you to develop your activity.

We may pseudonymize your email address and use it to generate statistical results. Such statistics are in the form of aggregated data and not personal information (for example, number of Models per country who are registered on our site).

4.7. Personalization of our Guests’ and Members’ experience

The Guest and the Members have the option to have their homepage personalized based on their previous visit and/or activity on the site.

We are using a software, which is learning about the behavior of Guests and Members on our site (for example, when they are navigating on our site, viewing livestreams, looking at Models’ profiles or adding favorites to their lists) and able to predict the types of Models who could be of interest for them. They will thus see a homepage showing them first Models that could be of interest for them based on their last visit and previous activity.

For this purpose, we will use your profile information and filter your details based on Guests’ and Members’ activity, to be able to display your profile picture on the homepage of Guests or Members who could be interested in you.

We have a legitimate interest in using your information this way. Indeed, this helps to improve our Guests and Members’ experience, but also your Services provision. Indeed, this allows our Guests and Members to find you easily if they are interested in your characteristics and therefore to make our site interesting and adapted to our Guests and Members.

4.8. Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data. For example, we must retain your transaction information to maintain legally required accounting records.

We may also use your information to respond to requests from competent authorities or given our legitimate interest 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.

 5. HOW DO WE PROTECT AND HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We implement various security measures, technical and organizational, to ensure the protection of your personal data against unauthorized access, modification, disclosure or deletion.

We periodically test our IT systems, conduct penetration tests, and implement data loss prevention systems against leakage, theft and data breach.

Our site incorporates reasonable security technologies in order to ensure the safety of its users and the safekeeping of their related information.

We will retain your personal data for as long as we consider it necessary for:

• Performance of the contract we have with you

To perform the contract we have with you, including maintaining your Model/Studio account.

• Legal Obligation Compliance

For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that in accordance with Luxembourg legislation, financial information will be kept for a minimum period of 10 years.

• Legitimate Interests and Business Conduct

Including:

• Establishing, exercising or defending legal claims
• Fraud/illegal activity detection and prevention
• Support training
• Quality check
• Enhancing safety

For example, if we suspend or close your account due to fraud or illegal activities, we may retain data about you to prevent you from opening a new account in the future. Such data will also be kept available in case of ongoing judicial proceedings and/or investigations. 

Please also note that in order to prevent frauds related to promotions addressed to new Models, when you ask for the erasure of your accounts we might keep your ID card to prevent new subscriptions. The retention will be in an anonymised form so we will not have access to the data but the system will be able to recognise that the new subscription should not have access to the promotions.

• Security

As we have said, the protection of your information from accidental or malicious loss and destruction is one of our top priorities.

Residual copies of some of your personal information will be kept on our backup systems for 30 days.

Some anonymized copies of your information (e.g. log records) may also remain in our database.

If you have a question about any specific retention periods of certain personal data, please contact us via the contact details provided in Section 10 “HOW TO CONTACT US?”

6. WITH WHOM DO WE SHARE YOUR DATA?

6.1. Guests and/or Members

Please note that the data you use to complete your Model’s profile will be publicly visible on the site (e.g. 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 or videos, on your wall or ”My Content” page.

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

6.2. Webmasters participating in 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 all our sites, including notably livejasmin.com, but also on all our affiliated sites that we call “whitelabels”, if the webmaster operating the affiliated site chose to display your category.

We will not share any of your personal data with webmasters of affiliated sites, unless the webmaster subscribed to a specific promotional tool (see below).

• 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.

6.3. Entities of our company’s group

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

• Jasmin IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Jasmin Holding SA, 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Docler Services 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;
• Jasmin SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
• Docler Services Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
• Jasmin IP S.à r.l. Hungary Branch, Expo tér 5-7, H-1101, Budapest, Hungary;
• Duodecad IT Services S.à r.l., ., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.

6.4. Service providers

We use carefully selected and trusted third parties, who act as data processors.

We ensure that they are contractually obligated 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; (d) fraud prevention.

6.5. 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.

This Privacy Policy does not govern the processing of your personal information by third parties if it was shared directly with them.

6.6. Law enforcement agencies or governmental authorities

To the extend permitted by applicable laws, 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 other rules applicable to our site, and/or (d) protect our rights or defend ourselves against any claims.

6.7. Business transfers

Your information may be transferred to another entity of our group following some internal reorganization or to another third party entity in case of sale, reorganization, restructuring, merger and/or acquisition or any other disposal whatsoever at group or company level resulting that part (more than 50%) or whole of our business (or related assets) is either directly or indirectly transferred or falling under control of a third party acquirer, provided the latter and/or the other group company in case of internal reorganisation operates within same or similar line of business as ours and commits to comply with this Privacy Policy.

 7. YOUR RIGHTS UNDER GDPR

7.1. Information on the transfer of your personal data outside of the European Economic Area

As we are a Luxembourg based company, we comply with the EU Data Protection Regulation, “GDPR”. Regardless of whether you are located in Europe or elsewhere, our own location in Europe requires us to comply with GDPR. You can read the entire Regulation here.

During 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 United States or other countries, 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.

7.2. 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 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 Model 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 for you to be able to exercise certain of your rights easily.

Our Model 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 for up to two additional months.

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.

Please also understand that, because your privacy is so important for us, our support team may need to duly verify your identity and ask you to provide additional information before executing your request.

7.2.1. Data access and data portability

You have the right to access the personal data 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 Model 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), 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 privacy@livejasmin.com.

7.2.2. 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 privacy@livejasmin.com.

7.2.3. Data retention and erasure

If you no longer want us to use your personal data, you can request that we erase it and close your account. In such case, please select “Forget my Data” in the “Privacy Rights” section of your account settings. Your request for the erasure of your personal data will be considered as a notice for termination of the Services Agreement. 

Your request will be sent to our Model 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 will retain some of it for as long as we consider it necessary for compliance with our legal obligations or other legitimate interests as explained above in Section 5 “HOW DO WE PROTECT AND HOW LONG DO WE RETAIN YOUR PERSONAL DATA?”

7.2.4. Right to object

• We process your data for a variety of reasons as explained in Section “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.

7.2.5. Right to restriction of processing

You have the right to request that we stop processing your personal data, while we resolve any issues.

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

• Accuracy: If you contest the accuracy of your personal data, while we verify your claim.
• Legitimate interest: If you object to a processing activity based on a legitimate interest, you can require the processing operation to be put on hold while we verify your grounds for objection.
• Unlawful processing: You can request the restriction of data process if you consider your data is being processed unlawfully, but do not wish for your data to be immediately erased.
• Data storage: We have no further need for the data, but you require it to establish, exercise or defend legal claims.

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

To exercise this right, you can send an email to privacy@livejasmin.com.

7.2.6. 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 (i.e. your local authority or the CNPD).

8. INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, you have the following special rights under the California Consumer Privacy Act (“CCPA”) in addition to any other rights outlined in this Privacy Policy.

Please note that we do not “sell” your personal data, as that term is defined in CCPA.

8.1. Your Right to “Know” and to Request Deletion

You have the right to know the categories and specific pieces of personal data we have collected about you. You have the right to know the categories of sources from which the personal data has been collected, the business or commercial purpose for collecting or selling personal data, and the categories of third parties with whom we share personal data.

You also have the right to request deletion of personal data we’ve collected or maintain. Please note this right is subject to certain exceptions, including without limitation our retaining information as necessary to protect against malicious, deceptive, fraudulent, or illegal activity, to comply with our legal obligations, and for other internal purposes.

To exercise these rights contact us as provided in Section 10 “HOW TO CONTACT US?” below. You can also exercise your right to deletion by selecting “Forget my Data” in the “Privacy Settings” section of your account settings. Please note that any requested disclosures in connection with a request to know will only apply to the 12-month period preceding the request, and you are entitled to request disclosure twice in any 12-month period. You may also download your data as provided on our website or exercise your right to delete by deleting your account as provided in your account settings.

8.2. Personal Information Disclosed

You also have the right to know what categories of personal data we’ve disclosed for a business purpose, and the third parties to whom that information was disclosed.

In the past 12 months, we’ve disclosed for a business purpose the following categories of information to the following parties: Usage/device information (including, without limitation, your IP address, as the case may be) to our business intelligence and analytics service providers (e.g., Hotjar, Google Analytics); Payment/transaction data to our customer/payment service providers; Contact information, device/usage information (including, without limitation, your IP address), information relating to your Services, certain profile information (as the case may be), and information as regards your interactions with the emails we sent to our marketing and sales partners (e.g. Emarsys, marketing partners promoting our site); identification information, contact information, device, usage information and content, payment information (as the case may be) to our antifraud service providers and auditing service providers.

8.3. Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please note, however, that the exercise of some of your rights (e.g., to delete your data) may render it impossible for us to continue to deliver services to you.

8.4. Your Right to Use an Authorized Agent

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section 10 “HOW TO CONTACT US?” below. In order to verify you have authorized an agent we may require a signed, written authorization from you.

8.5. Do Not Track

Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will however treat any “do not sell” or similar signals as opt-out requests under CCPA.

 9. 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. 

10. 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 privacy@livejasmin.com or via mail to the address indicated below, and we will get back to you quickly. We are always glad to talk about our privacy practices.

JWS Americas S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249539.

JWS International S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249566

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at dpo@livejasmin.com or mail to the following address:

To the attention of the DPO

JWS Americas S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249539.

Or

To the attention of the DPO

JWS International S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249566