Privacy and Cookie Policy

1. INTRODUCTION

This Privacy and Cookie Policy explains how personal data is collected, used, stored, protected and disclosed when you visit or use alexsisfaye.com, create an account, purchase a Premium Membership or Credits, access photographs or videos, request custom content, contact us, participate in the affiliate programme or otherwise interact with the Website and its services.

In this Policy:

• “Website” means alexsisfaye.com;
• “Services” means the accounts, Premium Memberships, Credits, galleries, videos, custom-content services, communications, affiliate features and other services available through the Website;
• “Alexsis Faye,” “we,” “us” and “our” refer to the operator of the Website under the Alexsis Faye name;
• “Personal Data” means information relating to an identified or identifiable individual;
• “Sensitive Data” means Personal Data receiving additional legal protection, including data concerning a person’s sex life, sexual orientation, health, biometric identifiers or other special categories of Personal Data.

This Policy should be read together with the Website’s Terms and Conditions of Use, cookie controls, checkout disclosures and any specific notice displayed when Personal Data is collected.

The Terms and Conditions govern your contractual use of the Services. This Policy explains how Personal Data is processed. Accepting the Terms does not automatically constitute consent to optional cookies, direct marketing or the processing of Sensitive Data where separate consent is legally required.

By using the Website, you acknowledge that you have been provided with this Policy. Where processing requires consent, we will request that consent through a separate positive action.

2. DATA CONTROLLER AND CONTACT

The controller of Personal Data processed through the Website is the person or entity operating alexsisfaye.com under the Alexsis Faye name.

The controller’s legal identity and business information are provided in the Legal Notice available through the Website footer.

For privacy questions, data-protection requests, account requests, safety reports and complaints, contact:

contact@alexsisfaye.com

Do not send full payment-card numbers, card security codes, passwords, identity documents or unnecessary Sensitive Data by ordinary email.

3. SCOPE OF THIS POLICY

This Policy applies to Personal Data collected:

• through the Website;
• during account registration and login;
• through free or paid access to photographs and videos;
• during Premium Membership and Credit transactions;
• through custom-content requests;
• through comments, messages and contact forms;
• through customer-support, billing, cancellation or complaint communications;
• through the affiliate or webmaster referral programme;
• through cookies, logs, security systems and similar technologies;
• from payment processors, age-assurance providers, affiliates and other service providers involved in delivering the Services.

This Policy does not control an independent third-party website or service merely because the Website links to it. Independent payment, live webcam, social-media, age-verification or other third-party services may process Personal Data under their own privacy policies.

4. ADULTS ONLY AND PERSONAL DATA OF MINORS

The Website contains sexually explicit material and is intended exclusively for persons who are at least 18 years old and have reached the legal age of majority applicable in their location.

The Website is not directed to minors, and we do not knowingly offer Services to or intentionally collect Personal Data from minors.

Parental or guardian consent does not authorise a minor to access this Website.

If we learn that a person using the Website is underage, we may:

• immediately restrict or terminate access;
• cancel or suspend the relevant account;
• remove Personal Data that is not required for legal, safety or evidentiary purposes;
• preserve a limited record where necessary to prevent repeated underage registration, investigate circumvention, protect a child or comply with law;
• report suspected exploitation, grooming, child sexual abuse material or other unlawful conduct to the competent authorities.

A parent, guardian or other person who believes that a minor has accessed the Website or provided Personal Data should immediately contact contact@alexsisfaye.com.

A report should include enough information to identify the account or incident, but should not include unlawful sexual material involving a minor unless specifically requested through a lawful and secure reporting channel.

5. PERSONAL DATA WE MAY COLLECT

We collect only Personal Data that is reasonably necessary for the purposes described in this Policy.

5.1 Account and registration data

When you register or use an account, we may collect:

• username;
• email address;
• password in securely transformed or hashed form;
• account creation date;
• account status;
• login and session information;
• language and account preferences;
• Premium Membership status;
• Credit balance;
• purchase and access entitlements;
• cancellation, suspension or account-closure information;
• age declaration and age-assurance status;
• country or region information where needed for legal, payment or access-control purposes.

The ordinary free-account registration process does not require you to provide marital status, gender, occupation or other unrelated profile information.

You should use an alias rather than your legal name where a real name is not required.

5.2 Age-gate and age-assurance data

When you enter the Website, we may record:

• confirmation that you declared yourself to be at least 18 and legally eligible to access the Website;
• date and time of the declaration;
• age-gate cookie or local preference;
• IP address and basic security information connected with the declaration;
• age-verification result or token if an age-assurance system is used;
• the country, region or age threshold applicable to the request;
• failed, expired or suspicious verification attempts.

Where an independent age-assurance provider is used, the provider may collect additional information directly from you under its own privacy notice.

Where reasonably possible, the Website will receive only confirmation that the required age threshold has been met, rather than your complete date of birth, identity document or other unrelated identity information.

5.3 Transaction and payment data

When you purchase a Premium Membership, Credits, a gallery, a video, custom content or another paid Service, we may process:

• account identifier;
• product or Service purchased;
• number of Credits purchased, spent, returned or remaining;
• amount, currency and applicable tax information;
• transaction date and status;
• payment-processor transaction or subscription identifier;
• recurring billing status;
• renewal and cancellation information;
• refund, reversal or chargeback status;
• billing country or region;
• fraud, payment-risk and verification results;
• limited payment information supplied by the processor, such as the payment method type or masked details.

Payments are processed through CCBill or another payment processor identified at checkout.

When you enter payment details through a CCBill-hosted or CCBill-controlled checkout, the full payment-card information is submitted directly to CCBill. We do not normally receive or store your complete card number or card security code.

CCBill processes payment information under its own privacy policy and legal obligations. We may receive sufficient transaction information from CCBill to activate access, manage subscriptions, provide support, prevent fraud, handle cancellations, resolve disputes and satisfy legal or accounting obligations.

5.4 Content access and usage data

When you use the Website, we may collect information such as:

• pages and sections visited;
• photographs, previews, galleries or videos opened;
• content purchased or unlocked;
• dates and times of access;
• video playback and technical delivery information;
• authorised download events;
• search terms entered on the Website;
• comments or interactions submitted;
• referral source;
• session duration;
• errors, interrupted playback and performance information;
• account, device and browser information associated with the activity.

Because the Website provides adult content, content-access and purchase history may reveal or allow inferences about intimate interests, sex life or sexual orientation. We therefore treat such information as confidential and apply additional safeguards.

We do not make an individual user’s viewing history, purchase history or custom requests publicly available.

5.5 Custom-content request data

When you request custom or on-request content, we may collect:

• account and transaction identifiers;
• requested name or alias;
• script, instructions and preferences;
• selected category, duration, quality or delivery options;
• requested clothing, setting, language or scenario;
• exclusivity selection;
• tip information;
• messages exchanged concerning the request;
• delivery and completion status;
• lawful files or reference material submitted by you;
• consent records connected with the request;
• information necessary to assess whether a request complies with the Terms and Conditions.

Custom instructions may contain Sensitive Data or information that allows conclusions about sex life or sexual orientation.

You are not required to provide your legal name for inclusion in custom content. Where privacy is important, use an alias.

Do not provide another person’s name, photograph, voice, private information or intimate material unless you have a lawful basis and clear permission to do so. Do not submit any information or material involving a minor.

If you ask for a name or alias to be spoken or displayed in a custom video, that information may become permanently embedded in the completed video. Removal may not be technically possible without altering or destroying the finished work.

5.6 Communications and customer-support data

When you use the contact form or communicate with us, we may collect:

• name or alias;
• email address;
• subject;
• message;
• attachments;
• account and transaction identifiers;
• correspondence history;
• date and time of communications;
• IP address and security information associated with form submission;
• information required to respond to interviews, photoshoots, special requests, support matters, complaints or legal notices.

We may retain a record of communications to resolve the request, maintain service history, establish what was agreed, prevent abuse and protect legal rights.

5.7 Comments and other user submissions

If comments or other public-submission features are available, we may collect:

• username;
• comment or submission content;
• date and time;
• associated content identifier;
• moderation status;
• reports or complaints relating to the submission;
• technical and security information.

A comment submitted to a public area may be visible to other users together with your username. Do not publish your legal name, address, payment information, contact details or other information that you do not want others to see.

We may review, moderate, hide or remove submissions in accordance with the Terms and Conditions.

5.8 Affiliate and webmaster programme data

If you participate in or interact with the affiliate programme, we may process:

• CCBill affiliate or sponsor identifier;
• username and account reference;
• referral links and campaign identifiers;
• clicks, referrals and conversion events;
• qualifying purchases and recurring transactions;
• commission calculations and payment status;
• fraud, duplicate, self-referral or chargeback indicators;
• communications relating to the affiliate relationship;
• technical information needed for attribution and security.

Tracking and affiliate payments are managed in conjunction with CCBill.

Affiliates generally receive attribution and commission information and do not receive a customer’s private viewing history, custom instructions, complete payment details or private messages.

CCBill account passwords must not be sent to us by email. Where credentials are entered through a connection intended to retrieve CCBill affiliate information, they must be used only for that connection and must not be stored in readable form or included in logs, analytics or support messages.

5.9 Technical, device and security data

We may automatically collect:

• IP address;
• browser type and version;
• operating system and device type;
• screen, language and time-zone settings;
• approximate country or region derived from an IP address;
• referring and exit pages;
• session identifiers;
• login time and activity;
• cookie identifiers and consent choices;
• failed login attempts;
• captcha and anti-bot results;
• suspected automated or malicious activity;
• server, application and security logs;
• error, crash and performance data;
• information needed to detect account sharing, scraping, circumvention, fraud or unauthorised access.

An IP address and online identifier may constitute Personal Data and are treated accordingly.

5.10 Marketing and communication-preference data

Where marketing is offered, we may collect:

• whether you subscribed or unsubscribed;
• date, time and method of consent;
• categories of communication selected;
• email delivery, bounce and complaint information;
• email opening or link-interaction information where lawfully enabled;
• a suppression record showing that you opted out.

Transactional messages concerning registration, security, purchases, subscription renewal, cancellation, delivery or changes to a Service are not promotional messages and may still be sent when necessary to provide the Service or comply with law.

5.11 Copyright, abuse, safety and legal-report data

If you submit or are involved in a report, complaint, takedown request or legal dispute, we may process:

• identity and contact details of the reporter;
• authority to act for another person or rights holder;
• URLs and content identifiers;
• description and evidence of the alleged infringement or abuse;
• account, transaction and technical records relevant to the report;
• correspondence and investigation notes;
• legal notices, decisions and authority communications;
• records concerning suspected piracy, deepfakes, unauthorised distribution, threats, fraud, minors or non-consensual material.

We may preserve relevant information where reasonably necessary to establish, exercise or defend legal claims or comply with a lawful preservation request.

5.12 Aggregated and anonymised data

We may produce statistics or reports from Personal Data, such as the total number of visitors, purchases, active accounts, popular features, technical errors or aggregate geographic distribution.

Where information has been irreversibly anonymised so that no individual can reasonably be identified, it is no longer Personal Data. We may use anonymous information for analytics, security, service development and business planning.

We do not attempt to re-identify properly anonymised data.

6. SENSITIVE DATA AND ADULT-CONTENT PRIVACY

The nature of the Website means that account activity, content selections, purchases, searches, messages or custom requests may reveal or allow conclusions about a person’s sex life or sexual orientation.

We process this information only where necessary and lawful, including:

• to provide content or a Service specifically requested by you;
• to fulfil a custom-content order;
• to maintain your private access history and entitlements;
• to protect the Website and its users from fraud or abuse;
• where you have provided explicit consent when such consent is legally required;
• where processing is necessary for the establishment, exercise or defence of legal claims;
• where another lawful exception applies.

Where explicit consent is legally required, it will be requested separately and will not be hidden inside general acceptance of the Terms.

You may withdraw consent at any time. Withdrawal does not affect processing lawfully carried out before withdrawal and may prevent us from continuing a Service that necessarily depends on the relevant information.

We do not use private custom instructions, viewing history, age-verification data or payment information for unrelated targeted advertising.

We do not sell Sensitive Data for monetary payment.

We do not use private messages, custom requests, identity documents or age-assurance information to train general-purpose facial-recognition or generative artificial-intelligence systems unless a separate, specific notice and legally valid permission are provided.

You should avoid submitting information about health, identity, sexual orientation, other individuals or other Sensitive Data unless it is genuinely necessary for the Service you requested.

7. HOW WE COLLECT PERSONAL DATA

We collect Personal Data through the following sources.

7.1 Directly from you

This includes information you provide when you:

• enter the Website;
• register or update an account;
• purchase a Membership or Credits;
• unlock or download Content;
• submit a custom request;
• post a comment;
• contact us;
• subscribe to marketing;
• request cancellation, a refund or account closure;
• exercise a privacy right;
• submit a complaint, copyright notice or safety report;
• join or use the affiliate programme.

7.2 Automatically through the Website

We collect technical, security, cookie and usage information when your browser or device interacts with the Website.

7.3 From CCBill and other payment providers

We may receive transaction, subscription, renewal, cancellation, refund, chargeback, affiliate and fraud-prevention information.

7.4 From age-assurance and security providers

We may receive an age-threshold result, verification token, timestamp, fraud signal, captcha result or similar eligibility and security information.

7.5 From affiliates and referral sources

We may receive referral identifiers, campaign information and information needed to attribute a qualifying transaction.

7.6 From service providers and public sources

We may receive information from hosting, security, email, analytics or professional-service providers, competent authorities, legal representatives, rights holders and publicly available sources where necessary for security, legal compliance or dispute resolution.

8. PURPOSES AND LEGAL BASES FOR PROCESSING

We process Personal Data only when we have an applicable legal basis.

8.1 Performance of a contract or steps requested before a contract

We rely on contractual necessity to:

• create and operate your account;
• authenticate you;
• provide free or paid Content;
• maintain your Premium Membership and Credits;
• process and confirm purchases;
• deliver custom content;
• respond to service-related requests;
• provide downloads or streaming access;
• manage subscription cancellation and refunds;
• operate an affiliate relationship;
• send transactional communications.

8.2 Compliance with legal obligations

We may process Personal Data to:

• comply with tax, accounting and consumer-protection requirements;
• comply with age-restriction and child-protection obligations;
• respond to lawful requests from courts, regulators or law-enforcement authorities;
• maintain records required by payment, performer-protection or other applicable laws;
• handle legally valid rights requests;
• report or address illegal material;
• comply with sanctions, anti-fraud or payment obligations where applicable.

8.3 Legitimate interests

Where your rights and freedoms do not override those interests, we may process Personal Data for legitimate interests including:

• operating, maintaining and improving the Website;
• securing accounts, systems and Content;
• preventing fraud, chargeback abuse, scraping, piracy and unauthorised access;
• detecting account sharing and technical circumvention;
• protecting copyright, performer rights, privacy and safety;
• responding to questions and complaints;
• maintaining evidence of transactions and communications;
• enforcing the Terms and Conditions;
• establishing, exercising or defending legal claims;
• measuring Website performance using non-invasive or consented technologies;
• maintaining affiliate attribution and preventing referral fraud;
• creating anonymous statistics;
• protecting minors and non-consenting persons.

Where we rely on legitimate interests, we consider the nature of the data, the reasonable expectations of users, the necessity of the processing and the possible effect on individual rights.

8.4 Consent

We rely on consent where required for:

• optional analytics cookies;
• advertising or cross-site tracking cookies;
• promotional emails;
• processing Sensitive Data voluntarily supplied in custom requests where explicit consent is legally required;
• any new purpose that is not compatible with the original purpose and requires consent.

Consent may be withdrawn without affecting the lawfulness of earlier processing.

8.5 Establishment, exercise or defence of legal claims

Where permitted by law, we may retain and process relevant account, transaction, communication, technical or Sensitive Data to investigate a dispute or establish, exercise or defend a legal claim.

9. DATA REQUIRED TO PROVIDE THE SERVICES

Certain information is required to create and operate an account or complete a transaction.

For example:

• a username and valid email address are required for registration and account communications;
• age eligibility is required to access the Website;
• account and transaction information are required to provide purchased access;
• payment information must be supplied to CCBill to complete a paid transaction;
• custom instructions are required only to the extent needed to fulfil a custom request;
• security information may be required to protect accounts and prevent fraud.

If you do not provide required information, we may be unable to create an account, complete a purchase, deliver a custom order, verify eligibility or respond to a request.

Marketing consent and optional analytics or advertising cookies are not required to create a basic account or purchase a Service.

10. AGE ASSURANCE AND PRIVACY

The Website may use different age-assurance measures depending on law, risk, location and available technology.

These may include:

• an adult-age declaration;
• account-based age confirmation;
• payment-related adult verification;
• verification through an independent provider;
• privacy-preserving proof that the user is over 18;
• additional checks where fraud or circumvention is suspected.

Age assurance will not be used to obtain unrelated identity information or build an advertising profile.

Where technically and legally possible, we seek to receive only:

• confirmation that the applicable age threshold has been met;
• an anonymous or pseudonymous verification token;
• the date and validity status of the verification;
• limited security information needed to prevent reuse or fraud.

We do not ask users to email identity documents for ordinary access.

If an exceptional manual review lawfully requires identity evidence, a secure method will be provided. Only information necessary for the review should be submitted, and unnecessary details should be concealed where permitted.

Identity images or facial information processed by an independent age-assurance provider are governed by that provider’s privacy notice. The Website will not intentionally retain a copy unless it is necessary and lawful.

Age-assurance information will not be used to identify your adult-content preferences, target advertising or create a biometric profile.

11. PAYMENTS AND CCBILL

CCBill provides payment-processing and affiliate services for the Website.

When you enter payment information through CCBill, CCBill may process information such as:

• name and billing details;
• payment-card or alternative-payment information;
• transaction and subscription details;
• IP address and device information;
• fraud and risk indicators;
• customer-support and chargeback information.

CCBill may act as an independent controller for aspects of payment processing and applies its own privacy policy.

The Website generally receives limited information needed to:

• identify the transaction;
• activate or renew access;
• add Credits;
• confirm payment status;
• process a cancellation or refund;
• respond to a billing question;
• manage chargebacks;
• detect fraud;
• comply with accounting and legal obligations.

We do not intentionally store your complete payment-card number or card security code.

Deleting your Website account does not necessarily cancel an active recurring CCBill subscription. Recurring billing must be cancelled using the method described in the Terms and Conditions, CCBill confirmation or customer-support process.

12. COOKIES AND SIMILAR TECHNOLOGIES

12.1 What cookies are

Cookies are small text files stored by a browser or device. Similar technologies include local storage, pixels, tags, software-development tools, session identifiers and other mechanisms that remember information or recognise a browser or device.

We do not use Flash Cookies.

12.2 Strictly necessary cookies

Strictly necessary technologies support functions such as:

• recording the age-gate decision;
• recording cookie choices;
• maintaining a secure session;
• account registration and login;
• fraud prevention;
• captcha or bot protection;
• maintaining access to purchased Content;
• processing purchases and Credits;
• load balancing and network security.

These technologies are used because they are necessary to provide a requested service, maintain security or comply with law. Disabling them may prevent the Website from functioning correctly.

12.3 Preference and functionality cookies

With consent where required, these technologies may remember:

• language;
• display preferences;
• previous settings;
• playback preferences;
• other optional functionality.

12.4 Analytics cookies

With consent where required, analytics technologies may collect information about:

• visitor numbers;
• page visits;
• referral sources;
• session duration;
• feature use;
• browser and device type;
• technical errors;
• general geographic region.

The Website may use Google Analytics or similar measurement services when enabled. Such providers may receive cookie identifiers, IP information, device information, page addresses and interaction events.

Because the Website provides adult content, page addresses and interaction events may reveal adult-content interests. Analytics tools must not intentionally receive passwords, complete payment details, private messages, custom-request text, identity documents or complete age-verification records.

Optional analytics technologies are not intended to be activated before legally valid consent is obtained.

12.5 Advertising and affiliate technologies

With consent where required, advertising, referral or affiliate technologies may be used to:

• attribute a visitor or purchase to an affiliate;
• calculate affiliate commissions;
• prevent referral fraud;
• measure advertising performance;
• limit or evaluate advertisements;
• understand whether an advertisement led to a registration or purchase.

Google advertising or measurement services, CCBill affiliate technologies and other providers may process their own identifiers under their privacy policies.

We do not provide advertisers or affiliates with the text of custom requests, private messages, full payment information or a personally identified detailed viewing history for their own independent marketing.

12.6 Email tracking

Where legally permitted, a promotional email may contain a technology that indicates whether the message was delivered, opened or clicked. This information is used to measure communications and maintain mailing lists.

You may opt out of promotional emails through the unsubscribe mechanism in the message.

12.7 Cookie choices

The Website’s cookie-control mechanism allows you to accept or reject optional cookies.

Rejecting optional cookies does not remove strictly necessary technologies. It may reduce optional personalisation, analytics or embedded third-party functionality.

You may withdraw consent by reopening the Website’s cookie settings where available, changing your choice through the cookie banner or clearing Website cookies and making a new selection.

Browser controls may also block or delete cookies, but browser settings may affect login, age-gate memory, purchases or other necessary functions.

Withdrawing consent does not affect processing lawfully carried out before withdrawal.

Consent records may be retained for a limited period to demonstrate and respect your selection.

13. MARKETING COMMUNICATIONS

We send promotional email only where we have an appropriate legal basis, including consent where required.

Promotional communications may include:

• new Content announcements;
• Membership offers;
• Credit promotions;
• Website updates;
• other Alexsis Faye offers.

You may unsubscribe at any time by:

• using the unsubscribe link in a promotional email; or
• contacting contact@alexsisfaye.com.

Unsubscribing from marketing does not stop necessary account, payment, security, cancellation, renewal, delivery or legal communications.

We may retain a minimal suppression record containing your email address and opt-out status to ensure that you are not added back to the marketing list without a new valid request.

We do not sell email lists or provide private custom-request information to unrelated businesses for their own direct marketing.

14. HOW WE DISCLOSE PERSONAL DATA

We disclose Personal Data only where necessary, proportionate and lawful.

14.1 Payment and affiliate providers

We may disclose or receive data from CCBill and other processors involved in payments, subscriptions, refunds, chargebacks and affiliate attribution.

14.2 Hosting, storage and delivery providers

Hosting, cloud, content-delivery, backup and technical providers may process limited data to operate, secure and deliver the Website and its Content.

14.3 Email and customer-support providers

Providers may process email addresses, messages and delivery information to send account, transactional, support or consented marketing communications.

14.4 Age-assurance, captcha and security providers

These providers may process eligibility, device, IP, fraud or verification information to confirm age, prevent bots, detect abuse and secure the Website.

14.5 Analytics and advertising providers

Where the required consent has been given, optional analytics, advertising or measurement providers may process identifiers and usage information for the purposes described in the cookie section.

14.6 Professional advisers

Lawyers, accountants, auditors, insurers, security specialists and other advisers may receive Personal Data where reasonably necessary and subject to confidentiality or professional duties.

14.7 Authorities and legal recipients

We may preserve or disclose Personal Data where reasonably necessary to:

• comply with applicable law, regulation, court order or lawful authority request;
• investigate fraud, exploitation, threats, piracy, non-consensual material or unlawful access;
• protect minors;
• protect the rights, property, safety or security of the Website, Alexsis Faye, users or others;
• establish, exercise or defend legal claims.

We assess requests where legally permitted and disclose only information reasonably relevant to the request.

14.8 Business transfers

If the Website or relevant business assets are transferred, merged, reorganised or sold, Personal Data may be disclosed to advisers and a lawful successor.

The successor must process Personal Data consistently with applicable law and provide notice of material changes where required.

14.9 With your instruction or consent

We may disclose information where you specifically request or consent to the disclosure.

15. SERVICE PROVIDERS AND CONFIDENTIALITY

Providers processing Personal Data on our behalf are expected to:

• process information only for documented purposes;
• protect confidentiality;
• implement appropriate security;
• assist with legal compliance where applicable;
• delete or return information at the end of the service, subject to lawful retention;
• notify us of relevant security incidents.

Some providers, including payment processors and certain age-assurance or analytics providers, may determine their own processing purposes and act as independent controllers for those activities.

Their own privacy notices apply to their independent processing.

16. INTERNATIONAL DATA TRANSFERS

The Website may use providers or infrastructure located outside Romania, the European Economic Area, the United Kingdom or your country of residence.

Where Personal Data is transferred internationally, we use a lawful transfer mechanism where required, such as:

• a decision recognising an adequate level of protection;
• approved standard contractual clauses;
• contractual and technical supplementary safeguards;
• another transfer mechanism permitted by applicable law;
• an applicable legal exception for a specific transfer.

Depending on the provider, Personal Data may be processed in the United States or another country whose laws differ from those in your location.

You may contact contact@alexsisfaye.com for information about safeguards applicable to a relevant transfer, subject to confidentiality and security limitations.

17. SALE, SHARING AND TARGETED ADVERTISING

We do not sell Personal Data in exchange for monetary payment.

Certain privacy laws may use broad definitions of “sale” or “sharing” that include disclosure through optional advertising, analytics or cross-site tracking technologies.

Where such technologies are used:

• they are subject to consent or opt-out controls where required;
• you may reject them through the cookie controls;
• Sensitive Data is not intentionally used for targeted advertising;
• private custom instructions, full payment details and age-verification documents are not intentionally disclosed for targeted advertising.

Residents of jurisdictions providing a right to opt out of sale, sharing or targeted advertising may exercise that right through the cookie controls or by contacting contact@alexsisfaye.com.

18. DATA RETENTION

We retain Personal Data only for as long as reasonably necessary for the relevant purpose, including legal, accounting, security and dispute-resolution requirements.

Retention depends on the category of information and the context.

18.1 Account data

Account information is generally retained while the account remains active.

After closure, limited account information may be retained for a reasonable period to complete deletion, resolve disputes, prevent fraud, enforce restrictions and comply with law.

18.2 Transaction and payment records

Transaction, subscription, Credit, refund and chargeback records are retained for the periods required by tax, accounting, consumer, payment and legal-claim rules.

Complete payment-card details are retained by the payment processor under its own policy rather than by the Website.

18.3 Custom-content and communication records

Custom instructions, order communications and delivery records may be retained while the order is processed and afterwards for a reasonable period to demonstrate what was requested and delivered, resolve complaints and defend legal rights.

Where a name or alias has been embedded in completed Content, it may remain part of the produced file and secure production records. Account deletion does not necessarily alter or destroy a completed work where continued retention is lawful.

18.4 Age-assurance data

Age-verification status or a proof token may be retained while access remains valid and for a limited period needed to demonstrate compliance, prevent repeated circumvention and resolve verification disputes.

Where we receive identity evidence during an exceptional manual review, it will be deleted or securely restricted when no longer necessary, unless longer retention is legally required.

18.5 Security and technical logs

Ordinary security and server logs are kept for a limited period proportionate to operational and security needs.

Relevant records may be retained longer where they are connected with fraud, underage access, security incidents, piracy, legal claims or a lawful preservation requirement.

18.6 Marketing data

Marketing data is retained until consent is withdrawn or the marketing purpose ends.

A minimal suppression record may be retained afterwards to respect an opt-out.

18.7 Complaints and legal records

Privacy requests, copyright reports, abuse reports and legal correspondence may be retained until the matter is resolved and for any applicable legal-claim or compliance period.

18.8 Backups

Deleted information may remain in encrypted or restricted backups until those backups are rotated or securely overwritten.

Backup data is not returned to ordinary active use unless recovery is necessary and remains subject to this Policy.

When retention ends, Personal Data is deleted, anonymised or securely restricted.

19. SECURITY OF PERSONAL DATA

We use technical and organisational measures appropriate to the nature and risks of the processing.

Measures may include:

• encrypted transmission;
• password hashing;
• account authentication;
• access controls and least-privilege permissions;
• confidentiality obligations;
• network and application security;
• firewalls and anti-abuse controls;
• monitoring and logging;
• secure backups;
• fraud and bot detection;
• provider due diligence;
• incident-response procedures;
• testing and maintenance.

No Website, transmission or storage system can be guaranteed to be completely secure.

You are responsible for:

• choosing a strong and unique password;
• not sharing your account;
• protecting your email account;
• signing out of shared devices;
• preventing minors and unauthorised persons from accessing your device or downloaded Content;
• notifying us promptly of suspected unauthorised access.

We will never ask you by unsolicited email to provide your complete card number, card security code or account password.

Suspicious messages should be reported to contact@alexsisfaye.com.

20. YOUR DATA-PROTECTION RIGHTS

Depending on applicable law and the circumstances, you may have the following rights.

20.1 Right of access

You may request confirmation of whether we process your Personal Data and receive a copy together with information about the processing.

20.2 Right to rectification

You may request correction of inaccurate information and completion of incomplete information.

20.3 Right to erasure

You may request deletion of Personal Data where there is no continuing lawful reason to retain it.

The right to erasure is not absolute. Information may be retained where required for legal compliance, payment records, safety, fraud prevention, freedom of expression, intellectual-property enforcement or legal claims.

20.4 Right to restriction

You may request that processing be temporarily limited in certain circumstances.

20.5 Right to data portability

Where processing is based on consent or contract and carried out by automated means, you may request eligible Personal Data in a structured, commonly used and machine-readable format.

20.6 Right to object

You may object to processing based on legitimate interests because of your particular situation.

You may object to direct marketing at any time.

20.7 Right to withdraw consent

Where processing is based on consent, you may withdraw it at any time.

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

20.8 Rights concerning automated decisions

Where applicable, you may request human intervention, express your point of view and contest a decision based solely on automated processing that produces legal or similarly significant effects.

20.9 Right to complain

You may lodge a complaint with the data-protection authority in your habitual place of residence, place of work or place of the alleged infringement.

In Romania, the relevant supervisory authority is the National Supervisory Authority for Personal Data Processing — ANSPDCP.

20.10 Additional local rights

Certain jurisdictions may provide additional rights, including:

• the right to know categories and recipients of Personal Data;
• the right to opt out of sale, sharing or targeted advertising;
• the right to limit certain uses of Sensitive Data;
• the right to appeal a refused privacy request;
• the right not to receive discriminatory treatment for exercising a privacy right.

We will honour such rights where the relevant law applies.

21. HOW TO EXERCISE YOUR RIGHTS

Send requests to:

contact@alexsisfaye.com

Include:

• the email address associated with the account;
• the right you want to exercise;
• enough information to identify the relevant account or transaction;
• a clear description of the request.

Do not send a complete payment-card number or unnecessary identity document.

We may request proportionate information to verify that the request concerns you. Verification is intended to protect Personal Data from being disclosed or deleted at the request of an unauthorised person.

Where permitted, an authorised representative may submit a request, but proof of authority and identity may be required.

We normally respond within one month where the GDPR applies. A complex or multiple request may require an extension allowed by law, in which case you will be informed.

Requests are normally free. A reasonable fee may be charged, or a request may be refused, where permitted by law and the request is manifestly unfounded, excessive or repetitive.

If we cannot fully fulfil a request, we will explain the reason where legally permitted and inform you of available complaint or appeal options.

22. AUTOMATED PROCESSING, FRAUD CHECKS AND PROFILING

The Website and its providers may use automated tools to:

• detect fraud;
• assess payment risk;
• identify bot activity;
• prevent account takeover;
• identify suspicious account sharing;
• enforce geographic or age restrictions;
• validate age-assurance tokens;
• prevent affiliate abuse;
• detect scraping or malicious traffic;
• prioritise security alerts.

CCBill and other independent providers may apply their own automated risk systems under their privacy policies.

We do not intentionally make a decision producing legal or similarly significant effects based solely on an inferred sexual preference.

Where a solely automated decision significantly affects you and applicable law provides protection, you may request human review by contacting contact@alexsisfaye.com.

23. ACCOUNT CLOSURE AND DELETION

You may request closure of your Website account by contacting contact@alexsisfaye.com.

Account closure may result in loss of access to:

• Premium Content;
• purchased galleries;
• custom-content deliveries;
• remaining Credits;
• comments and account settings;
• transaction and access history displayed in the account.

Account closure does not automatically cancel an active recurring CCBill subscription. Cancellation must also be completed through the process described in the Terms and Conditions.

Closing an account does not require immediate deletion of every associated record. Information may be retained where necessary for:

• completed transactions;
• legal or accounting obligations;
• refunds and chargebacks;
• fraud prevention;
• minor-protection measures;
• security investigations;
• copyright enforcement;
• legal claims;
• lawful backups.

Where information can lawfully be deleted, it will be removed or anonymised within a reasonable period.

24. THIRD-PARTY WEBSITES AND SERVICES

The Website may link to CCBill, live webcam services, social networks, affiliate portals or other independent websites.

When you leave alexsisfaye.com or use an independent third-party service:

• the third party may collect information directly;
• its own privacy policy and terms apply;
• its cookies and tracking are not controlled by this Policy;
• purchases or communications made there may be between you and that provider.

Review the third party’s privacy information before providing Personal Data.

A link does not mean that we control or accept responsibility for all processing performed by the third party.

25. DOWNLOADED CONTENT AND YOUR DEVICE

Where the Website allows an authorised download, the file may be stored on your device or cloud account.

After a file is downloaded, its security may depend on:

• your device security;
• password protection;
• cloud settings;
• backup settings;
• shared-device access;
• messaging or file-sharing applications;
• malware or unauthorised access.

You are responsible for storing downloaded adult Content in a secure location where minors and unauthorised persons cannot access it.

Deleting an account does not delete files already stored on your personal device.

The intellectual-property rules applying to downloaded Content are set out in the Terms and Conditions.

26. PERSONAL DATA BREACHES

We maintain procedures for evaluating and responding to suspected Personal Data breaches.

Where a breach creates a legally reportable risk, we will notify the competent supervisory authority within the period required by applicable law.

Where a breach is likely to create a high risk to affected individuals, we will provide notice to those individuals where required, unless an applicable exception applies.

Notices may describe:

• the nature of the incident;
• categories of information affected;
• likely consequences;
• measures taken;
• recommended protective steps;
• contact information.

Users should promptly report suspected account or data compromise to contact@alexsisfaye.com.

27. CHANGES TO THIS POLICY

We may update this Policy to reflect:

• changes in the Website or Services;
• new legal requirements;
• changes in providers;
• new age-assurance or security measures;
• changes in cookies or analytics;
• improvements to privacy practices.

The updated version and effective date will be displayed on the Website.

Where a change materially affects how existing Personal Data is used, we will provide additional notice where required.

Where new consent is legally required, continued use of the Website will not replace that consent. A new positive consent action will be requested.

Changes do not retroactively remove rights or protections that cannot lawfully be removed.

28. RELATIONSHIP WITH THE TERMS AND CONDITIONS

This Policy forms part of the privacy information applicable to the Services and should be read together with the Terms and Conditions.

The Terms and Conditions govern matters including:

• adult eligibility;
• accounts;
• Memberships and recurring billing;
• Credits;
• custom content;
• refunds;
• intellectual property;
• prohibited conduct;
• suspension and termination.

This Policy governs the collection and processing of Personal Data.

If there is a conflict concerning Personal Data, mandatory data-protection law and this Privacy Policy prevail to the extent required by law.

29. CONTACT AND COMPLAINTS

For questions, privacy requests, account requests, complaints, security concerns, age-related reports or information-handling concerns, contact:

contact@alexsisfaye.com

Please include enough information for us to understand and respond to the matter, but do not send passwords, complete payment-card details, unnecessary identity documents or unlawful material through ordinary email.

We will investigate legitimate complaints and cooperate with competent data-protection, consumer-protection, law-enforcement and other authorities where required by law.