Privacy Policy

1. Introduction and Data Controller

This privacy policy explains what personal data is collected when using the escort listings platform (hereinafter referred to as the "Platform" or "Website") operated by [Company Name], [Address] (hereinafter referred to as the "Operator" or "we"), and how this data is processed. The Operator is the data controller under Swiss data protection law (Federal Act on Data Protection, FADP) and, where applicable, the EU General Data Protection Regulation (GDPR). If you have any questions about data protection or wish to exercise your rights as a data subject (see Section 9), you can contact us at any time: [Company Name, Address, Email Address].

The protection of your personal data and the preservation of your privacy are important to us. We treat personal data confidentially and in accordance with the legal data protection provisions of Switzerland (in particular the revised Data Protection Act, revFADP 2023) and this privacy policy. Below, we inform you about what data we process for which purposes, to whom we may disclose it, and what rights you have regarding your data. This privacy policy applies to all processing of personal data in connection with the use of our Platform, both for unregistered visitors and registered users and advertisers.

2. Types of Personal Data and Processing Purposes

We collect and process personal data only to the extent necessary to provide a functional platform, to manage our services, or to safeguard our legitimate interests. Depending on your interaction with our Platform (visiting the website, registration, posting an ad, using certain features), we may collect the following categories of personal data:

• Basic registration data: When you create a user account, we record the data you provide. This typically includes your name or pseudonym, email address, password, and optionally other contact details (such as a phone number) if provided. This data is required to enable your access to protected areas of the Platform, manage your account, and communicate with you regarding inquiries or important information (e.g., changes to the Terms & Conditions/Privacy Policy).
• Profile and ad data: Advertisers who post an escort listing voluntarily provide additional information. This may include personal details in the ad (such as a display or profile name, age, gender, descriptions of the person and services offered, prices, availability), location details (e.g., city/region of service), contact information (e.g., phone number, messenger contact, or email for inquiries), and uploaded photos/videos. This data is processed to publish the ad on the Platform so that other users can view and contact the advertiser if interested. Please note that all information provided in the ad—including any personal data such as your (stage) name, photo, phone number, etc.—is publicly visible on the website. Therefore, only include information in the ad that you explicitly wish to disclose publicly and that does not violate third-party rights. The publication of this data is based on your consent, which you grant by voluntarily providing the data and posting the ad, as well as for contract fulfillment, as this information is necessary for the provision of our service (ad publication).
• Usage and technical data: When visiting our website (even without logging in), our servers automatically collect certain technical information, which qualifies as usage data. This includes, for example, your device’s IP address, date and time of access, pages/URLs visited, browser type and version, operating system, referring website (referrer), and similar technical identifiers. This data is automatically generated when using internet services. We use this information to ensure the operation and security of the website (e.g., preventing attacks, diagnosing errors) and to analyze Platform usage in anonymized or pseudonymized form (see Section 5 on analytics services). IP addresses are stored only in truncated form or for a limited period unless required for security-related analysis or evidence in case of misuse. The collection of this usage data is based on our legitimate interests in the security, stability, and optimization of our services.
• Communication data: If you contact us (e.g., via email or a contact form, if available), we process the contact details you provide (e.g., name, email, phone) and the content of your message. This data is used solely to process your inquiry and any follow-up questions. The legal basis for this is usually your consent (implied by your initiation of contact) or our contractual obligations if the inquiry relates to your user account or ad.
• Payment data: If an advertiser or user uses paid services (e.g., booking a premium ad or promotional option), we process certain payment information. Payment processing is handled by third-party payment providers (see Section 4), so we do not store financial information such as credit card numbers. However, we receive transaction data such as payment amount, date, chosen payment method, and confirmation of successful payment. This data is used for billing and accounting. The legal basis for this is contract fulfillment (providing the paid service) and compliance with legal obligations in accounting (retention of payment records).

The above data is collected either directly from you (e.g., during registration, profile/ad input, or Platform usage) or automatically through your interaction with the website (usage data via server logs, cookies, etc.). We generally do not obtain data about you from third-party sources. If this is exceptionally necessary (e.g., for identity verification or payment fraud checks via external services), we will inform you separately.

Special categories of personal data: We do not collect special categories of sensitive data (such as health data, religious affiliation, political opinions, etc.) unless you voluntarily provide such information in your ad or profile. Note that details in an escort ad (e.g., sexual orientation, preferences) may allow inferences about particularly sensitive data (e.g., sexual life). The disclosure of such information is entirely voluntary and at the advertiser’s discretion. We treat such voluntarily shared sensitive details with extra confidentiality but advise advertisers to carefully consider which personal details they wish to disclose in a public ad.

In summary, we use the collected data for the following purposes:

• To provide the Platform services: including registration/login, ad publication and display, enabling contact between users (providing contact details or external contact buttons), managing user accounts and content, and fulfilling contractual relationships with you.
• To ensure security and prevent misuse: e.g., detecting unauthorized access, tracking user behavior in case of violations, suspending accounts for rule breaches, and protecting our systems from cyberattacks. For this, we may analyze technical usage data and log files.
• To improve and develop our services: We analyze aggregated and anonymized information about Platform usage (e.g., frequently visited pages, popular ads) to continuously optimize usability and functionality. Web analytics tools (see Section 5) may also be used.
• To communicate with users: Including responding to inquiries, sending important account notifications, delivering technical notices (e.g., verification emails, password resets), and—if you explicitly consent—sending optional informational or marketing emails (e.g., newsletters).
• To bill and administer paid services: If you use a paid option, we process your data to handle payments, accounting, and, if necessary, debt collection.
• To comply with legal obligations: We may store or disclose personal data if legally required (e.g., retaining certain data for tax purposes or providing information to authorities under legal disclosure obligations) or to assert or defend legal claims.

 

3. Cookies and Tracking Technologies

Our Platform uses cookies and similar technologies to ensure functionality and improve user experience. Cookies are small text files automatically stored by your browser on your device when you visit our website. Some cookies we use are technically necessary (e.g., session cookies that maintain settings or logins during your visit). These cookies are usually deleted automatically after the browser session ends.

Other cookies are used for statistics and analysis (see Google Analytics below) or to enhance usability (e.g., remembering language settings). Such cookies may have a longer lifespan but typically remain on your device for a few days to months unless you delete them earlier. We use these technologies based on our legitimate interests in ensuring the functionality and security of our website and understanding how our services are used. Where we use third-party cookies (e.g., for analytics), we obtain consent via a cookie banner if legally required.

Cookie settings: You can control cookie usage. In your browser settings, you can specify whether to accept, block, or delete cookies when closing the browser. You can also delete existing cookies at any time. Note that disabling technically necessary cookies may limit some Platform features.

In addition to cookies, we may use similar technologies like pixel tags or local storage to store certain information. These serve purposes comparable to cookies (e.g., faster page loading, preference storage).

4. Data Disclosure to Third Parties and Processors

We generally treat your personal data confidentially and disclose it to third parties only if necessary to provide our services, you have consented, or we are legally obligated or permitted to do so. In connection with this Platform, data may be disclosed to the following categories of recipients:

• External payment providers: If you use a paid service, payments are processed by independent providers (e.g., credit card companies, banks, online payment platforms like PayPal). For this purpose, necessary payment data is transmitted to the respective provider. Typically, payment details (e.g., credit card number, PayPal login) are entered directly on the provider’s pages, so we do not collect this information ourselves. Depending on the provider, your name, email, and transaction details (amount, date, time, order/service description) are shared for payment processing. These providers process your data as independent controllers (under their own privacy policies). Please review the provider’s privacy policy for details.
• Hosting and technical service providers: Our website is hosted by an external provider. This processor handles technical usage data and all data generated through Platform usage (e.g., database content, images, communication) for storage and website provision. A hosting provider may access personal data if necessary to fulfill its services (e.g., server maintenance, backups). We have data processing agreements with such providers to ensure your data is processed per this privacy policy. The same applies to other technical providers we use, e.g., for email delivery (SMTP servers), data analysis, or maintenance. These providers are usually located in Switzerland or the EU.
• Analytics/tracking providers: As explained in Section 5, we use external analytics services (currently Google Analytics). These providers receive usage data (and possibly truncated IP addresses, cookie IDs, etc.) to provide us with reports. These providers act as our processors, though Google may also process data for its own purposes (see Section 5 for details and opt-out options).
• External communication services: If you use features that integrate external services (e.g., a WhatsApp button to contact an advertiser), certain data is transmitted to these services. For example, clicking the WhatsApp button opens WhatsApp (a Meta Platforms service, USA/Ireland). Meta/WhatsApp may receive information about your visit (including date/time, device, and technical data). Further communication occurs solely on WhatsApp. The Platform operator does not receive or access this communication. Please review WhatsApp’s privacy policy, as external contacts are governed solely by the third party’s rules. The same applies to other external links in ads (e.g., links to personal websites or social media profiles). We are not responsible for data processing on external sites accessible via our Platform.
• Law enforcement and supervisory authorities: In certain cases, we are legally required to disclose personal data to authorities, e.g., for criminal investigations, official requests, court orders, or other legal obligations. We only disclose data to authorities per legal requirements and with a valid request.
• Legal advisors and courts: If necessary, we may disclose data to our lawyers, experts, or courts to assert or defend legal claims.

We do not sell or unlawfully share your data with third parties for marketing purposes. Disclosure occurs only as described above and to the necessary extent. If we use processors abroad or transfer data internationally (see next section), we ensure adequate data protection safeguards.

5. Web Analytics and Tracking (Google Analytics)

Our Platform uses Google Analytics, a web analytics service by Google LLC (USA) or Google Ireland Ltd. (for Europe). Google Analytics uses cookies (see Section 3) to analyze your website usage. The cookie-generated information (including your IP address) is typically transmitted to and stored on Google’s servers. However, we have configured Google Analytics to anonymize your IP address using the "anonymizeIp" function, which truncates your IP within Switzerland/EU/EEA before transmission, eliminating direct personal identification. Google uses this information to evaluate website usage, compile reports, and provide other services related to website and internet usage. Google Analytics sets various cookies with different lifespans (some session-only, others lasting months). These cookies store a random user ID (to recognize returning visitors), technical device/browser details, and your usage behavior. Google uses this to create pseudonymized usage profiles. We receive aggregated statistics but no personally identifiable data. However, Google may combine usage data with other data about you (e.g., your Google account). We have no control over such data merging; Google processes this data under its own responsibility per its privacy policy.

Data transfer to the USA: Google LLC is based in the US. Data we transmit to Google (usage data, truncated IPs, etc.) may be processed on US servers. Note: The US is considered a country with insufficient data protection under Swiss and EU law, as authorities may access personal data without adequate redress. While Google contractually commits to European data protection standards (e.g., via EU Standard Contractual Clauses), and we take additional measures (like IP anonymization), residual risks cannot be entirely ruled out. By using our website and—where required—consenting to analytics cookies, you accept this potential privacy risk.

Opt-out: You can prevent Google Analytics from collecting your data by either rejecting analytics cookies in our cookie banner or disabling "Analytics" in cookie settings. Alternatively, install Google’s browser add-on to disable Google Analytics: https://tools.google.com/dlpage/gaoptout. For more details, see Google’s privacy policy: https://policies.google.com/privacy and Google Analytics: https://support.google.com/analytics/answer/6004245.

We use Google Analytics solely to analyze website usage anonymously and improve our services. Your data is not used for profiling or advertising. If we introduce additional tracking/analytics tools, we will update this privacy policy and obtain your consent if required.

6. International Data Transfers

We generally process personal data in Switzerland and the European Economic Area (EEA). However, data may occasionally be transferred to or stored in third countries outside Switzerland/EU, e.g., when using service providers in such countries (e.g., Google in the US). For transfers to countries without adequate data protection laws, we implement contractual safeguards (e.g., EU Standard Contractual Clauses) or other measures to protect your data. Where such measures are impossible, we rely on exceptions under Art. 49 GDPR or Art. 16 revFADP—such as your explicit consent, contractual necessity (e.g., international payment processing requiring data transfer), or legal claim enforcement. If you initiate a transfer yourself (e.g., clicking a WhatsApp button sending data to Meta/USA), we consider this as your consent to the transfer.

For details on safeguards for international transfers (e.g., copies of Standard Contractual Clauses), please contact us using the details provided.

7. Data Retention and Deletion

We retain personal data only as long as necessary to fulfill the purposes for which it was collected or as required by law. Specific retention periods vary by data category and purpose:

• Account data: User account data (registration/profile details) is stored for the duration of active registration. If you delete your account or request deletion, we typically remove your personal account data from active systems within 30 days. Legal retention obligations or our legitimate interests (e.g., evidence in disputes or IP logs for misuse investigations) may require longer storage.
• Ad data: Public ads and their contents remain visible for the booked duration. After expiration or deactivation/deletion by the advertiser, the ad is removed from the Platform. We may retain archive copies or backups for a limited time (e.g., for legal disputes, complaints, or accidental deletion recovery). Such archives are not publicly accessible and are deleted or anonymized after legal limitation periods or legitimate retention interests expire.
• Communication data: Inquiry/email/support ticket content is retained as long as necessary to address your request. Beyond this, we may retain correspondence under legal retention periods (up to 10 years for business correspondence under Swiss law) or for legal claim enforcement/defense.
• Payment and accounting data: All accounting-relevant documents (invoices, payment confirmations, transaction records) are retained for 10 years per legal requirements (Art. 958f Swiss Code of Obligations). Even if you delete your account, such data must be retained but is blocked for other purposes.
• Log files and technical data: Server logs with IP addresses and usage data are stored temporarily for security and troubleshooting. IPs in logs are deleted or anonymized when no longer needed, typically within 7–90 days. Aggregated analyses (without personal identifiers) may be retained longer.

Once personal data is no longer necessary and no legal retention obligations apply, we delete or anonymize it. Anonymized data (without personal identifiers) may be retained for statistical purposes.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from loss, misuse, unauthorized access, alteration, or destruction. These include firewalls, encryption (e.g., SSL/TLS for data transmission), access restrictions, database controls, and physical server protections. Internally, only authorized personnel needing access for their duties can view personal data, and they are bound by confidentiality.

However, no internet transmission is completely secure. While we strive to protect your data, we cannot guarantee absolute security. You use the Platform and communicate with us at your own risk. Please safeguard your login credentials and never share your password with others (see also Section 4 of the Terms & Conditions). In the event of a data breach posing a high risk to your rights, we will notify you and the relevant supervisory authority promptly, as required by law.

9. Rights of Data Subjects

Under applicable data protection laws (particularly Art. 25 ff. revFADP and, where applicable, Chapter 3 GDPR), you have the following rights:

• Right to information: You may request confirmation whether we process your personal data and, if so, access to that data. Your request can include details about data categories, processing purposes, recipients, storage duration, and data sources (if not collected directly from you). Note that this right may be legally restricted (e.g., if third-party interests override or if disclosure is prohibited). We generally provide information free of charge within 30 days. For manifestly unfounded or excessive requests, we may charge a reasonable fee or refuse the request per law.
• Right to rectification: You may request correction of inaccurate or incomplete personal data. You can update much of this information in your account. Otherwise, we will correct errors upon notification unless legal grounds prevent this.
• Right to erasure: You may request deletion of your personal data if processing is no longer necessary (e.g., after account deletion, withdrawal of consent without alternative legal basis, or unlawful processing). Note that we may not always fully comply if legal retention obligations or overriding interests (e.g., legal claim enforcement) apply. In such cases, we will restrict processing (block data) and inform you accordingly.
• Right to restriction of processing: Under certain conditions, you may request that we restrict processing (instead of deletion), e.g., if data accuracy is contested (during verification) or if you object to processing (pending assessment of overriding interests). In such cases, we will mark the affected data to limit processing.
• Right to data portability: Where applicable, you may request a copy of certain personal data you provided in a structured, machine-readable format. Upon request, we will—where technically feasible—transmit this data directly to a third party you designate. This right applies only to data processed based on consent or contract performance and does not adversely affect others’ rights.
• Right to object: You may object to data processing based on legitimate interests (Art. 31 revFADP or Art. 6(1)(f) GDPR), particularly for direct marketing. Upon objection, we will cease processing for these purposes unless we demonstrate compelling legitimate grounds overriding your interests or for legal claim enforcement. You may opt out of marketing emails anytime (e.g., via unsubscribe links or by contacting us).
• Right to withdraw consent: If processing is based on your consent, you may withdraw it anytime with future effect. Withdrawal can be informal (e.g., via email). Upon receipt, we will stop the affected processing unless another legal basis applies. Lawfulness of pre-withdrawal processing remains unaffected.
• Right to lodge a complaint: If you believe we process your data unlawfully, you may complain to the relevant data protection authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC; see https://www.edoeb.admin.ch for complaint procedures). Under the GDPR, you may also contact your EU member state’s supervisory authority.

Exercising your rights: To exercise any rights, contact us at [Email Address] or the address in Section 1. To prevent misuse, we may require identity verification before disclosing or deleting personal data. Depending on request sensitivity, we may ask for proof of identity (e.g., a redacted ID copy). We aim to respond promptly, within legal deadlines, and will inform you of actions taken or reasons for any denials.

10. Minors’ Use of the Platform

Our Platform is strictly for adults (18+). We do not knowingly collect personal data from minors under 18. Persons under 18 may not use the Platform or submit personal data to us. Parents/guardians who become aware of such submissions should contact us immediately for deletion. If we inadvertently discover minor data, we will remove it promptly unless legal retention obligations apply.

11. Changes to This Privacy Policy

The Operator may update this privacy policy as needed, e.g., due to changes in data processing, new legal requirements, or new Platform features/services. Material changes will be published on the website and, where feasible, notified to registered users. The current version is marked with a date at the top. Please review this policy periodically. If we intend to use your data for new purposes, we will inform you beforehand and obtain consent if required.

Last updated: [Insert Date].