Privacy Policy
Latest modified: Tuesday, 25th of June, 2024
INTRODUCTION
Welcome to MCEscorts and our model directory website at www.mcescorts.com (our “website”). At MCEscorts, we respect your privacy and are committed to being transparent about what data we collect when you visit and use our website and/or our services and how it is used.
1. GENERAL INFORMATION
a. What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, age, e-mail address, address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.
b. What is Processing?
'Processing' means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
c. What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Estonia's Personal Data Protection Act (PDPA) and the EU's General Data Protection Regulation (GDPR).
d. Who is responsible for data processing?
The responsible party for data processing is AHND ENT OÜ of Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115 ('MCEscorts', 'we', 'us', 'our'). If you have any questions about this policy or our data protection practices, you can reach us via email using contact@mcescorts.com or write to us at the above address.
e. What are the legal bases of processing?
We only process your Personal Data if we at least one of the following applies:
- you have given your consent
- the data is necessary for the fulfillment of a contract / pre-contractual measures
- the data is necessary for the fulfillment of a legal obligation or
- the data is necessary to protect our legitimate interests, provided that your interests are not overridden
2. DATA WE COLLECT AUTOMATICALLY
a. Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our platform, and ix) which of our platform pages you are accessing. The legal basis for processing is our legitimate interest.
b. Economic analyses and market research
For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymised values. For this purpose we use Google Analytics from Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, US, and Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland). The legal basis is our legitimate interest and your consent. For further information on our use of analytics, please refer to our Cookie Policy.
c. Cookies
For the processing of personal data using cookies and similar technologies on our website, please refer to our Cookie Policy. The legal basis for the use of cookies is our legitimate interest or your consent when you agree to the use of technically non-essential cookies as further explained in our cookie policy
d. Cookie consent
As set out in Estonia`s Electronic Communications Act (“ECA”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of technically non-essential cookies. For this purpose we use a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via our cookie consent tool: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent
3. DATA WE COLLECT DIRECTLY
a. General
We may ask you for Personal Data when you:
- use our website and model directory services,
- request services, support, or information,
- participate online or otherwise in marketing and advertising activities,
- subscribe to our marketing and promotional emails or other materials,
- interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
- contact us
b. Registration of a user account
On our website, we offer users (Independent Escorts, Agencies, and Members/Visitors) the opportunity to register an account. The data is entered into our registration form and transmitted to us and stored. The data is not passed on to third parties. The following data is collected as part of the registration process: i) Model Name/Agency Name/Username, ii) Email address, iii) Password, iv) Phone Number v) the IP address of the user and vi) date and time of registration. The legal basis for processing is consent and the fulfillment of a contract. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. As a user, you have the option at any time to delete your registration with us. You can change your data stored with us at any time independently and / or delete or have deleted. If the data is necessary for the fulfillment of a contract or for the execution of pre-contractual measures, an early deletion of the data is only possible, as far as contractual or legal obligations do not oppose a deletion.
c. Use of our listing services
If you wish to use our listing services and its features, we process the Personal Data you voluntarily provide for the purpose of providing our listing services. Depending on how you use our listing services, you may provide images, contact information, company information, location data etc. and upload content such as text, photographs etc. This content will be made public and may be viewed and otherwise accessed by others. Some of the Personal Data you provide may be considered 'special' or 'sensitive'. This includes Personal Data concerning for example your racial or ethnic origins and sexual orientation. By choosing to provide this data, you consent to our processing of that data. You have choices about the data you provide and how you share it. You don't have to provide Personal Data or Special Category Data; however, information about you helps you to get more from our Services. It's your choice whether to include Personal Data or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available The legal basis for processing of your Personal Data and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent.
d. When using our services
We process the data of our users in order to be able to provide our services as well as to ensure the security of our website and to be able to develop it further. This includes in particular our support, correspondence with you. Your data will not be used by us for automated decision making or profiling. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.
e. Information that we share with others
You share information with other users when you voluntarily disclose information on the service (including your profile). Please be careful with your information and make sure that the content you share is stuff that you're comfortable being visible. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.
f. Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
g. Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our website and services. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.
4. PRINCIPLES OF PROCESSING PERSONAL DATA
a. Storage and Retention
We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with Estonia`s retention periods for up to 8 years.
b. Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures ('technical and organizational measures') for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website. Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
c. Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
d. Internation Transfer
In the course of my website operation, we process data. We usually do not transfer Personal Data to countries outside Estonia and the EEA. However, if we do, we will make sure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses for a high level of data protection.
e. What we do not do
- We do not request Personal Data from minors and children;
- We do not use Automated decision-making including profiling; and
- We do not sell your Personal Data.
5. YOUR RIGHTS AND PRIVILEGES
a. Your rights
You can exercise the following rights:
- Right to information
- Right to rectification
- Right to object to processing
- Right to deletion
- Right to data portability
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
b. Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object (including withdrawing of consents you have given us) to its processing, please do so in your account or by contacting us.
c. Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).
d. Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Estonia is: Data Protection Inspectorate,Tatari 39, Tallinn 10134, Estonia, www.aki.ee. However, we would appreciate the opportunity to address your concerns before you contact the Data Protection Inspectorate or any other supervisory authority.
6. HOW DO WE MAKE CHANGES TO THIS POLICY?
We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our website. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes