Privacy Policy
Last update: 16.01.2025
AskForNudes ("Us", "We", "Our") respects Your privacy and fully understands how it is important to You. We are committed to being transparent and to comply with all applicable laws to protect the privacy and security of Personal Data. NINETAILS MEDIA LTD, a company duly registered under the laws of Cyprus, with principal office at Agias Faneromenis, 143-145, Patsias Court, Flat/Office 201, 6031, Larnaca, Cyprus, acts as the data controller and processor of the Personal Data collected and processed through AskForNudes.
AskForNudes Privacy Policy ("Privacy Policy") applies to all information that AskForNudes, located on askfornudes.com or app.askfornudes.com ("Website"), can receive about the User ("You", "Your") while using the Website, and also describes Our procedures for collecting, using and protection of the User's Personal Data and an indication of the cases in which the information We collect may be disclosed or transferred to third-party services providers.
This Privacy Policy is concluded in accordance with the laws of Cyprus.
- 1. DEFINITIONS
- 1.1. The following terms shall have the following meaning:
- 1.1.1. Cookies — are small files, usually consisting of letters and numbers, that are downloaded to the device (computer or mobile device) when a user visits a particular website stored on Your device (computer or mobile device) which enables Us to collect information about Your device identifiers, IP address, web browsers used to visit the website, pages, or features viewed, time spent on the website, and links clicked.
- 1.1.2. Usage Data — is data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- 1.1.3. In this Privacy Policy, defined terms have the same meanings given to them in the Terms of Services.
- 2. SUBJECT MATTER
- 2.1. By using the Website, the User agrees to this Policy, any other annexes to the Policy, and any other documents referred to in this Policy. If the Users do not agree to the terms of this Policy, they shall not use the Website and must immediately exit the Website.
- 2.2. By accepting this Privacy Policy, You approve to have reached the age of majority or the legal age in Your jurisdiction (generally 18 or older), are solely responsible for all Your actions, and fully understand the statements outlined in this Privacy Policy. If You are under 18 years old, You shall not use the Website and must immediately leave the Website, except when the appropriate age of majority provided by the laws of Your country is reduced.
- 2.3. Please be attentive when visiting the Website. The Website may contain links to other websites. Once You link to another website, this Policy no longer applies. We are not responsible for the content or privacy policies of other websites.
- 2.4. This Privacy Policy should be read in conjunction with AskForNudes Terms of Service, and if You are the Model - Models' Terms of Use incorporated herein by reference. Capitalized terms used and not otherwise defined in this Privacy Policy shall have the meaning given to them in the Terms of Service.
- 3. DATA PROCESSING PRINCIPLES
- 3.1. We adhere to the following principles to protect Your privacy:
- 3.1.1. principle of purposeful limitation — We process Personal Data solely for the achievement of specific, clear, and legitimate purposes;
- 3.1.2. principle of lawfulness, fairness, and transparency — We process Personal Data lawfully, fairly, and transparently concerning the data subject;
- 3.1.3. principle of data minimization and storage limitation — We collect Personal Data only to the extent necessary to achieve the defined purposes. We do not store Personal Data if it is no longer needed or if the purposes for which the Personal Data was collected have been achieved;
- 3.1.4. principle of data accuracy — We always keep Personal Data up-to-date and complete to more effectively achieve the ultimate purpose of data processing. We take every reasonable step to ensure that inaccurate Personal Data, having regard to the purposes for which they are processed, are erased or rectified without delay;
- 3.1.5. principle of security and integrity — We process Personal Data in a way that ensures appropriate security of Personal Data, in particular their protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical and organizational measures;
- 3.1.6. principle of individual participation — We inform Users about data collection. Users have the right to access their Personal Data and request the correction of inaccurate or misleading data.
- 3.2. AskForNudes does not sell Your Personal Data to third parties. A “sale” of Personal Data includes the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means the Personal Data of a User to another business or third party for monetary or other valuable consideration.
- 4. THE POLICY'S OBJECTIVE
- 4.1. The User gives the Consent to and authorizes AskForNudes the right to receive, store, process, use, and disclose the User's Personal Data in accordance with the terms of this Privacy Policy by using any aspect of the Website to allow Users to use the Website, as well as to defend the rights and legitimate interests of the User of Personal Data as set forth by law.
- 4.2. To fulfill Our obligations on provision of the Services on AskForNudes for You and applicable Terms of Service, We are entitled to ask You to provide Us with Your Personal Data, including (but not limited): 1) first and last name; 2) email address; 3) country of residence; 4) payment information; 5) username; 6) password; 7) IP address; 8) geolocation; 9) profile photo; 10) interests; 11) identification documents: passport, driver's license or ID card (only for the Model).
- 4.3. We may collect Personal Data from You in a variety of ways and circumstances, including, but not limited to, access to AskForNudes, filling out a form, and providing Us with feedback. We shall be entitled to combine Personal Data collected in the course of Your interaction with different sections of the Service with any other relevant available information.
- 5. PURPOSES OF PERSONAL DATA COLLECTION
- 5.1. The purposes of processing and collecting Your Personal Data via the Website are (but not limited):
- 5.1.1. to provide the User an option to create an account and manage it;
- 5.1.2. to ensure that You are able to make use of the Services We provide via the Website;
- 5.1.3 to evaluate the popularity of web pages on the Website and the effectiveness of Content delivered to the User;
- 5.1.4. to provide You with customer support and respond to Your requests;
- 5.1.5. to allow the User to make payments for photos uploaded by the Models;
- 5.1.6. to provide an appropriate level of User's password security by preventing unauthorized access to the User's Personal Data and hackers' attacks;
- 5.1.7. to gather analysis or valuable information so that can help Us to optimize the platform's interface and functionality for better compatibility with User's devices/browsers and understand its popularity;
- 5.1.8. to provide Our developers to detect, prevent, and address core technical issues by using special programs;
- 5.1.9. to monitor the User's usage of the Website for web product improvement and optimization of User experience;
- 5.1.10. to fulfill any other purpose for which You provide it;
- 5.1.11. to carry out Our obligations and enforce Our rights arising from any contracts entered into between You and us, including for billing and collection;
- 5.1.12. for any other purpose as We determine, in Our sole discretion, to be necessary or required to ensure the safety and/or integrity of Our users, employees, third parties, public, and/or Our Website, or to comply with requirements of any applicable law.
- 5.2. We may use Your Personal Data internally to help Us improve Our Website and resolve any problems.
- 5.3. We may also utilize Your Personal Data for other purposes due to the provision of the Services.
- 6. PERSONAL DATA, COLLECTED IN AN AUTOMATIC WAY (USAGE DATA)
- 6.1. We may also automatically collect data about the devices You use to interact with Our Website. Personal Data automatically collected by or transmitted to Us in the course of accessing, interacting, and operating the Website may include, but is not limited to, the following Personal Data:
- 6.1.1. Usage Information. Using the Services generates data about Our activity on Our Services, for instance how You use them (e.g., when You logged in, features you've been using, actions taken, the information shown to You, referring web page addresses and ads that You interacted with);
- 6.1.2. Device information. We collect information from and about the device(s) You use to access Our Services, including hardware and software information such as IP address, device ID and type, app settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that You can reset by going into Your device's settings), identifiers associated with cookies or other technologies that may uniquely identify a device or browser;
- 6.1.3. Other information with Your Consent. If You give Us permission, We can collect Your precise geolocation (latitude and longitude). The collection of Your geolocation may occur in the background even when You aren't using the Services if the permission You gave Us expressly permits such collection. If You decline permission for Us to collect Your precise geolocation, We will not collect it.
- 7. TERMS OF PROCESSING PERSONAL DATA
- 7.1. The basis for the processing of the Personal Data of Our Users is their Consent to the processing of their Personal Data. We use such Personal Data in ways You would reasonably expect and that have minimal impact on Your privacy.
- 7.2 The processing of the User's Personal Data is carried out within the Storage Period, in any legal way, including in Personal Data information systems using automation tools or without using such tools.
- 7.3 The User's Personal Data may be transferred to authorized state authorities only based on and as it is prescribed by applicable law.
- 7.4. In case of loss or disclosure of Personal Data, We inform the User about the loss or disclosure of such Personal Data.
- 7.5. We take the necessary organizational and technical actions to protect the User's Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, and distribution, as well as from other illegal actions of third parties.
- 8. LAWFUL BASIS OF DATA PROCESSING
- 8.1. Your Personal Data is processed in accordance with the generally recognized norms of international law and the legislation of the particular User, as well as the norms applicable to You, including but not limited to:
- 8.2. If You are located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed by regulations and rules following Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation ("GDPR").
- 8.2.1. Under Art. 6 of the GDPR, We only process Personal Data, where We have a lawful basis for doing so.
- 8.2.2. The processing of Personal Data, described in this Policy is based on the User's Consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Policy.
- 8.3. If You are located in the United Kingdom, all processing of Personal Data is performed in accordance with regulations and rules following the Data Protection Act 2018 and the UK General Data Protection Regulation.
- 8.4. If You are located in Australia, all processing of Personal Data is performed in accordance with regulations and rules following the Privacy Act 1988.
- 8.5. If You are located in Japan, all processing of Personal Data is performed in accordance with regulations and rules following the Act on the Protection of Personal Information Act No. 57 of 2003 (“APPI”).
- 8.6. If You are located in other countries, that are not mentioned above, all processing of Personal data is performed in accordance with regulations and rules of the following countries.
- 9. CONSENT TO PERSONAL DATA PROCESSING
- 9.1. EU Persons Consent to Personal Data Processing
- 9.1.1. If You are an EU Person and to process Your Personal Data We need to receive Your Consent, as it is prescribed by GDPR, We will process Your Personal Data only in the case We have received from You a freely given, specific, informed, and unambiguous indication of Your wishes by which You signify agreement to the processing of Your Personal Data ("Consent").
- 9.1.2. We only collect the location information where Users have granted Us permission to do so through the obtaining permission system used by their mobile device platforms.
- 9.1.3. Your Consent covers all processing activities with Your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, Your Consent should be deemed given for all of them.
- 10. THE RIGHTS OF USERS
- 10.1. Users may review, correct, update, delete, and transmit their Personal Data.
- 10.2. Subject to possible restrictions under applicable national law of the data subject You may have certain rights regarding the Personal Data that We collect on You, particularly:
- 10.2.1. Right to object to the processing of Your Personal Data. In case Our processing is based on a legitimate interest to run, maintain, and develop Our business, You have the right to object at any time to Our processing. We shall then no longer process Your Personal Data unless for the provision of Our Services or if We demonstrate other compelling legitimate grounds for Our processing that override Your interests, rights, and freedoms or for legal claims. Notwithstanding any Consent granted beforehand for direct marketing purposes, You have the right to prohibit Us from using Personal Data for direct marketing purposes, by contacting Us or by using the functionalities of the Website, or unsubscribing possibilities in connection with Our direct marketing messages.
- 10.2.2. Right to access Your Personal Data. Users have the right to find out whether or not We are processing Your Personal Data. When We process Your Personal Data, We will inform You of what categories of Personal Data We process regarding You, the processing purposes, the categories of recipients to whom Personal Data have been or will be disclosed, and the envisaged Storage period or criteria to determine that period.
- 10.2.3. Right to restriction, verification, and correction. Users have the right to verify their Personal Data's accuracy and request its update, correction, or to prevent Us from erasing Personal Data when Personal Data is no longer necessary for the purposes but still required for Your legal claims or when Our processing is unlawful.
- 10.2.4. Right to restrict the processing of Your Personal Data. Users have the right, under specific circumstances, to request that We restrict the processing of their Personal Data as required by applicable data protection laws, such as when Our processing is unlawful. In this case, We will not process Your Personal Data for any purpose other than to store it. Restriction of processing may lead to fewer possibilities to use the Website.
- 10.2.5. Right to receive Your Personal Data and to transmit it to another Controller. Where Our processing is based on Your Consent and is carried out by automated means, You have the right to receive Your Personal Data in a structured, commonly used, and machine-readable format and, where technically feasible, to independently transmit it to another Controller without any hindrance.
- 10.2.6. Right to withdraw Consent. Where Our processing is based on Your Consent, You may withdraw Your Consent at any time by contacting Us through support@askfornudes.com and Your Personal Data will be deleted immediately. Withdrawing Consent may lead to fewer possibilities to use the Service.
- 10.2.7. Right to complain. The User also has the right to file a complaint with a supervisory authority if You believe We are violating Your rights. But We ask You to contact Us first so that We can help You.
- 10.2.8. How to use these rights. To exercise any of the above-mentioned rights, You should primarily use the functions offered by the Website.
- 10.3. When We receive any request to access, edit, or delete personally identifiable information, We reserve the right to initially take reasonable steps to verify Your identity before granting You access or otherwise taking action. This is essential to protect Your Personal Data. We also may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.
- 11. INFORMATION STORING AND DELETION
- 11.1. Personal Data shall be processed and stored only for as long as is necessary for the purpose for which it was collected ("Storage period").
- 11.2. We will store, collect, and proceed with Your Personal Data for as long as You are Our User and We have Your Consent. Personal Data that is collected and processed with Your Consent will be stored for as long as We have Your Consent.
- 11.3. The User can delete Personal Data at any time. To delete Personal Data You need to send Us an email to support@askfornudes.com with Your request for Personal Data to be deleted, and We will delete all Your Personal Data immediately in the case of receiving Your request for a Personal Data deletion.
- 11.4. After the expiry of the Storage Period, We shall delete Personal Data. Therefore, the right to object to the processing, the right to access, the right to delete, the right to correction, the right to restrict the processing, and the right to receive and transmit Personal Data cannot be exercised after the expiry of the Storage Period.
- 11.5. We do not provide lists of Users to third parties in any way, except as outlined in this Privacy Policy.
- 12. INFORMATION SECURITY
- 12.1. We care about the security of Your Personal Data. We adhere to generally accepted industry standards to protect the data transmitted to us, both during transmission, and after it is received. We take technical, physical, and administrative security measures to ensure that Your Personal Data is adequately protected. When We process Your data, We also ensure that Your data is protected against unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is achieved through appropriate administrative, technical, and physical measures.
- 12.2. Unfortunately, the transmission of information via the Internet is not completely secure. Although We do Our best to protect Your information, We cannot guarantee the security of Your Personal Data transmitted to Our Website. Any transmission of Personal Data is at Your own risk. We are not responsible for circumventing any privacy settings or security measures contained in the Website.
- 13. TRANSFER OF DATA
- 13.1. Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.
- 13.2. Your Consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
- 13.3. AskForNudes will take all the steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data.
- 14. SERVICE PROVIDERS AND CONTRACTORS
- 14.1. We cooperate with third-party service providers who provide Us with services such as website development, hosting of the Website, maintenance, emailing, marketing, technical support and collateral, information technology and cybersecurity services, customer support, and other services. These contractors may access the Personal Data or process it on Our behalf as part of their services to Us. We limit the information provided to Our service providers to only that which is reasonably necessary to perform their functions.
- 14.2. We may need to transfer Your Personal Data to third parties who provide these services. If Your Personal Data is transferred outside Your state, province, country, or other governmental jurisdiction, We require such third parties to maintain appropriate security measures.
- 14.3. We ensure that We hold data processing agreements with Our service providers that ensure compliance with the applicable law and Our contracts with them which require the privacy of Personal Data.
- 15. CHILDREN
- 15.1. We understand the importance of protecting children's privacy, especially in the online environment. These Services are not designed for or directed at children under the age of 18 years old. We do not knowingly collect Personal Data from such people. If a parent or guardian becomes aware that their child has provided Us with Personal Data, they should contact Us using the details provided above to delete it. We also recommend that parents monitor their children's Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian's preferences.
- 15.2. We do not intentionally collect or maintain information from persons under the age of 18, however, according to each country and its laws, the processing of the Personal Data of a child will be lawful where the child is at another age.
- 15.3. If You believe that We might have any information from or about a child under 18 years of age please contact Us at support@askfornudes.com.
- 15.4. If We determine upon collection that the User is under this age, We will not use or maintain their Personal Data without the parent/guardian's Consent. If We become aware that We have unknowingly collected personally identifiable information from a child under the age of 18, We will make reasonable efforts to delete such information from Our records.
- 16. APPLICABLE LAWS AND DISPUTE RESOLUTION
- 16.1. Any dispute must be settled by contacting Us to support@askfornudes.com; the dispute shall be resolved within 60 (sixty) calendar days by contacting Us via email.
- 16.2. In the event that a dispute cannot be settled within 60 days, any dispute arising out of the use of the Services as well as the receiving, storing, processing, using and disclosing of the User's Personal Data should be governed by the laws of Cyprus.
- 16.3. By accepting the Agreement, the Privacy Policy and the Cookie Policy, You consent to have any legal disputes arising from Your or any third party's use of the Services, from the receiving, storing, processing, using and disclosing of the User's Personal Data by Us as well as the information collected with Cookies mentioned in our Cookie Policy shall be resolved by the courts of Cyprus, as stated in the Section 11 of Terms of Service.
- 17. PRIVACY POLICY CHANGES
- 17.1. AskForNudes is entitled to make changes to this Policy without the Consent of the User.
- 17.2. We may occasionally change and update Our Privacy Policy, so please review it frequently. All changes and updates to this Privacy Policy are effective when posted on the Website. We reserve the right to change and update this Privacy Policy at any time without prior notice.
- 17.3. If there are any changes to this Privacy Policy that We believe are material, We will make every effort to notify You in advance through Your contact information provided to Us or by posting a notice on the Website.
- 17.4. It is the responsibility of the User to review this Privacy Policy constantly to know the changes made, if applicable.
- 17.5. All suggestions or questions regarding this Policy should be directed to support@askfornudes.com.
- 18. CONTACT US