Personal data we collect and other measures relating to it:

• We collect and process your personal data when you interact with us (for example, the information you provide to us by filling in forms on our website, or by corresponding with us by email or otherwise). This includes information you provide when you contact us via email and in other social communication activities. The information you provide to us may include your name, address, email address, and telephone number.
• Sensitive personal data relating to you (for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life, or sexual orientation) are exempted from collection and processing.

The types of personal information we collect:

• IP Addresses: When visitors access our website, we automatically capture the IP address of the source computer, the referring site, and the destination site. We use this information to control access to our website and to optimize the presentation of the website. IP addresses may also be used to help identify users, as well as to gather broad demographic information. It also captures data on which pages visitors have accessed and how often they are accessed. This information is used to understand visitor preferences and to balance the load on our servers.


• Cookies: Cookies are small data files that reside on visitors' computers. Cookies allow us to recognize visitors, personalize their experience, and provide efficiency in terms of their access to our site. We have set a session cookie on visitors' login details to allow them to access multiple areas without having to re-enter login information. Once a user closes their browser, session cookies become inactive. We can also set longer-lasting cookies to make login procedures more efficient for returning members. They may contain email addresses or usernames that are encrypted so that they can only be interpreted by our site. From time to time, we may share cookie information with third-party partners with whom we have a formal relationship. This is done to make the creation of new accounts more efficient and to facilitate special offers. Most browsers have settings that allow users to disable cookies on their devices. If cookies are disabled, certain services or website functionality may not function properly.


• Data about your visit, for example, this may include complete uniform resource locators (URLs), sequence of clicks to, through, and from our site (including date and time), information or products you viewed or searched for (including top articles read, top categories accessed, page response times, download errors, duration of visits to particular pages (including average time spent on particular pages, viewing particular content or videos), average time spent in an application and the number of views from such applications, average number of posts viewed on the site, information about interaction with pages (such as scrolling, clicks, and mouse-overs), methods used to navigate the page, data about Visitor behavior, and any phone numbers used to call or email addresses used to contact our customer service representatives.


• If you use your Facebook or Google account to create your user account on our website, we will process the following public profile data displayed by those applications: username, email address.

We may process your personal data for the following reasons:

• If we need to perform a contract we have entered into with you
• If we need to comply with a legal obligation
• When it is necessary for our legitimate interests and your interests (for example, to detect and prevent fraud or to ensure IT and network security), unless your fundamental rights override these interests
• If it is necessary to protect your vital interests (or the vital interests of others)
• If it is necessary for public interest or official purposes

We process your personal information for various technical, administrative, and operational reasons, such as:

• To ensure that we present content in the most effective way for you and your computer
• To improve our website, including its functionality
• For site administration, internal operations, including for debugging, data analysis, testing, research, and statistical purposes
• For advertising and marketing, including for targeted marketing purposes, so that we can provide content, including personalized content, that may be of greater interest to you
• As part of our efforts to keep our site secure

In some cases, we will only process your personal data with your consent. In these cases, we will ask for your consent separately and transparently when you provide your personal data. Subsequently, you will be able to withdraw your consent at any time via email. However, withdrawal of consent will not affect the lawfulness of any processing that has taken place prior to the withdrawal of consent.

Where we require personal data to comply with legal or contractual obligations, your provision of such personal data is mandatory. This means that if such personal data is not provided, we will not be able to manage contractual relationships or comply with obligations imposed on us. In all other cases, the provision of personal data is optional, and you are under no obligation to provide it.

We may also process your personal data, such as identification data, contact data, and residence address, for the purpose of possibly exercising our rights or claims against you in the future. This processing is based on our legitimate interest, as it is necessary to exercise our rights in the event of possible litigation.

If you are a USER of our website, we will process your personal data as follows:

• To carry out the contractual relationship between you and our Curtezan Platform:To take over, validate, and inform you about the status of the order concerning the number of credits. The processing of your data for this purpose is based on the contract concluded between you and the Curtezan Platform. The provision of your personal data is necessary for the performance of this contract. Refusal to provide your data may result in the impossibility of the contractual relationship between you and the Curtezan Platform.



• For the fulfilment of the legal obligations incumbent on the Curtezan Platform:In the context of the services provided through our website. The processing of your data for this purpose is necessary on the basis of legal obligations. Providing your data for this purpose is necessary. Refusal to provide data may result in the Curtezan Platform being unable to comply with its legal obligations and therefore unable to provide you with services through our website.



• For marketing activities:For the transmission, via remote communication means (e-mail, sms) of commercial communications concerning the products and services offered by the Curtezan Platform through the Site. The processing of your data for this purpose is based on your consent, if you choose to provide it. You can express your consent to the processing of your data for this purpose by ticking the appropriate box at the time of account creation, or after account creation, in the My Account Information section.



• To unsubscribe from receiving such commercial communications:You can use the option at the end of each email/sms containing commercial communications. In addition, you can unsubscribe by going to the My Account Information section. Providing your data for this purpose is voluntary. Refusing to provide consent to the processing of your data for this purpose will not have negative consequences for you.



• For the purpose of performing various analyses, reporting on the functioning of the Site, creating consumer preference profiles:Mainly in order to improve the experience offered on the Site. The processing of your data for this purpose is based on the legitimate interest of the Curtezan Platform to continuously improve the customer experience on the Site. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have negative consequences for you.

If you are a VISITOR of the website, the Curtezan Platform processes your personal data as follows:

• For marketing activities:
  For the transmission, by means of remote communication (e-mail, sms), of commercial communications concerning the products and services offered by the Curtezan Platform through the Site. The processing of your data for this purpose is based on your consent, if you choose to provide it. You can express your consent to the processing of your data for this purpose by completing and ticking the appropriate box in the newsletter subscription form available on the Site.



• To unsubscribe from receiving such commercial communications:
  You can use the option at the end of each email/sms containing commercial communications. Providing your data for this purpose is voluntary. Refusing to provide consent to the processing of your data for this purpose will have no negative consequences for you.



• To resolve complaints, grievances and to monitor traffic and improve your experience on the Site:
  The processing of your data for this purpose is based on the legitimate interest of the Curtezan Platform to ensure the proper functioning of the Site, as well as to continuously improve the experience of visitors to the Site, including by addressing various comments, questions or complaints. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will have no negative consequences for you.

Third Party Sites:
Our website often contains links to websites operated by other companies that are not controlled by us. Therefore, our website has no responsibility or liability for the policies, activities or content of these sites. However, we try to provide a positive experience for our visitors, so we welcome any feedback on these sites.

Customer Information:
Customer information, such as a username, password or email address, may be captured when a customer registers on the site, places an order, subscribes to a newsletter, responds to a survey or enters information on one of our sites. Customer information is used primarily to manage access to our sites and to communicate with customers when necessary regarding membership, product, billing or other support issues. We may retain correspondence, such as emails or messages, for purposes of reference and improving customer support. Customer information may also be used to deliver Curtezan Platform news, administer a contest, conduct a survey, communicate a special offer to a preferred partner, or promote internal programs. All promotional emails contain an easy and automatic way to unsubscribe from receiving future emails. Alternatively, recipients can unsubscribe from receiving future emails by sending a request to the "Contact" section of our website.

Consent:
By accepting the Terms and Conditions during registration, visitors to the website expressly consent to the use and disclosure of personal information in the manner described in this Privacy Policy.

How and to whom do we disclose your personal data?

We do not sell your personal data to third parties.

Personal data may be disclosed to government authorities and/or law enforcement agencies if required to do so by applicable law or if necessary to exercise our rights, including the Terms of Use, or to protect our legitimate interests (including the legitimate interests of third parties) in accordance with applicable law.

Curtezan Platform may also disclose personal data to external consultants (e.g. lawyers, accountants, auditors) if necessary and strictly for the performance of services they perform on behalf of the Curtezan Platform.

Storage of your personal data and transfers abroad

Your personal data that we collect is stored in the European Union ("EU") and the European Economic Area ("EEA"). However, information collected by third parties via cookie files (e.g. Google Double Click for Publishers) will generally serve traffic from a data centre that is closest to where the traffic originates. This means that such information, including advertising traffic, may be handled by servers located in the EEA and may be transferred outside the EEA.

In addition, your personal data may be transferred to and stored in a location outside the EU and EEA. When your personal data is transferred from your own country to another country, the laws and rules protecting your personal data in the country to which your information is transferred may be different (or provide less protection) than those in the country where you work and will apply.

We intend not to transfer your personal data outside the EEA unless adequate safeguards are in place, including: An adequacy decision issued by the European Commission in respect of the country or countries of destination; a "privacy shield" certification; appropriate binding corporate rules; an approved code of conduct, together with binding and enforceable commitments by the data controller or processor in a country outside the EU and EEA; an approved certification mechanism, together with binding and enforceable commitments by the data controller or processor in a country outside the EU and EEA to apply appropriate safeguards; or EU standard contractual clauses approved by the European Commission.

If we obtain your personal data from a third party, we will provide you with all relevant information about the processing as soon as possible, but in any case no later than one month after obtaining your personal data, including on the categories of personal data being processed, the purpose of the processing and the legal basis for the processing.

Your rights:

Customers have the following rights regarding the processing of personal data:

1. to request access to their personal data;
2. to request the completion, correction or replacement of data;
3. to request the deletion of data and the termination of further processing;
4. to request restriction of data processing;
5. to withdraw consent;
6. to exercise their right to data portability in accordance with Article 20 of Regulation 2016/679 of the European Parliament and of the Council.

You can ask us to confirm whether or not your personal data is processed by us, to provide you with a copy of your personal data and/or to correct it. In certain circumstances, you have the right to ask us to delete your personal data or, based on your right to portability, to ask us to transfer part of your personal data to you or to other entities.

You also have the right to object to certain processing of your personal data (e.g. the use of processing for direct marketing purposes or certain decisions taken only by automated processing (including profiling). Where we have asked for your consent to the processing of personal data, you have the right to withdraw this consent without adverse effect on you.

Where we process your personal data because we have a legitimate interest in doing so (as explained above), you also have the right to object to such processing. You also have the right to restrict the processing of your personal data in certain circumstances.

Please note that your rights as described above may be limited in certain situations and are subject to applicable laws and regulations on the protection of personal data; for example, your right to object to the processing of your personal data may be limited if we can demonstrate compelling legitimate grounds for processing your personal data that override your interests.

You will need to prove your identity and provide other details to help us respond to your request. We will not charge a fee for responding to your request unless permitted by law and, if such a fee is charged, it will be reasonable and proportionate to your request. If you wish to exercise these rights, please contact us on .

We hope that we can answer all your questions about how we process your personal data.

However, you also have the right to lodge a complaint with the data protection supervisory authorities. You can lodge your complaint in the Member State where you live, work or where the alleged breach of data protection law took place.