Privacy Notice

Last Modified: February 26th, 2024

Introduction

Aylo Premium Ltd (hereinafter “we”, “us” or “our”) operates the website www.spicevids.com (“Website”) and is the controller of the information collected or provided on the Website.

Please read this Privacy Notice carefully, as your access to and use of our Website signifies that you have read and understand all terms within this Privacy Notice. We respect your privacy and are committed to protecting your Personal Information.

For greater certainty, the term “Personal Information” or “Personal Data” means any information or data regarding a person or a user which can lead to identify such person or user, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person or user.

If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.

1. Scope

For the purposes of this Privacy Notice, “process”, “processed” or “processing” means any operation or set of operations performed on Personal Information, personal data or on sets of personal data or information (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure, or destruction. Information on disclosure of Personal Information or of sets of Personal Information is found in the “Disclosure of Your Personal Information” section below.

This Privacy Notice applies to information we process:

2. The Data We Process About You

We may process different kinds of Personal Information about you, depending on whether you chose to create an account and subscribe with us or not.

Persons who visit the Website without logging in or registering (“Unregistered Users”):

For persons who choose to create an account and subscribe to the Website, (including persons who sign up in content partner or viewshare programs) (collectively, the “Registered Users”), we process the same categories of information just described herein above for Unregistered Users, and additionally the following information:

Please use caution in providing User Contributions. By providing User Contributions you are making that content and information publicly available. User Contributions can be read, collected, used, and disclosed by others, and we cannot control who accesses your User Contributions or what other users may do with the information you voluntarily post or submit. User Contributions are governed by the respective Terms and Conditions of the Website.

We may use your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.

We prohibit minors from using the Website. Our Website are not forbidden of access to persons under the age of eighteen (18) years old or the applicable age of majority in the jurisdiction from which the Website is accessed. As indicated throughout this Privacy Notice, some users may be asked to provide some information to us and our service providers for us to verify that you are over the age of majority required to have access to the Website. We do not knowingly process personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, please contact us immediately at privacy@aylopremiumltd.com to have that minor’s personal information deleted.

3. The Sources from Which We Process Personal Information

We process Personal Information in the following ways:

4. Purposes for Which We Process Your Personal Information

We process Personal Information for the purposes described below.

5. Our Legal Bases under Canadian and European Union (EU) Privacy Law

To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your Personal Information only where:

Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.

6. Disclosure of Your Personal Information

We disclose personal information:

For more information on recipients of personal information, please see the section “Contact Information” below on how to contact us.

7. Cookies and Automatic Data Collection Technogies

As you navigate through and interact with our Website, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.

We currently use the following types of cookies, which are set by the Website’ domains:

Do Not Track: Our systems do not recognize browser “Do Not Track” signals.

Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the Website, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only to provide Google Analytics services to us and will not use this information for other purposes. In addition, we use Google Signals, which are also services provided by Google that help us to run remarketing campaigns, collect more accurate data, and understand in a better way how users engage with the Website on different devices (cross-device activity). Google Signals apply to Google users who accept personalized advertising on their Google accounts. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.

8. Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect Personal Information about you when you click to view, access, or use any of the Website, third-party feature on the Website or directed to such third-party website. Unless expressly stated otherwise, the Website does not provide any Personal Information directly to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access the Website. They may use such information to provide you with interest-based advertising or other targeted content.

You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.

9. Your Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us.

10. California Rights and Choices

As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, Consumers have the right to:

• Opt-out of the sale of their personal information, should we sell their personal information;

• Be informed of certain information concerning our collection and use of their personal information;

• Request that we delete certain personal information we collected from them;

• Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;

• Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

The Website does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable consideration. We may however disclose certain personal information with third parties, service providers and entities within our corporate group to enable them to perform certain services on our behalf, and namely to make the Website function properly, as further described in the section above titled Disclosure of Your Personal Information.

We respect California residents’ right to exclude personal information from such sharing arrangements and grant them the option to opt-out of any future sale of their personal information. If you are a Registered User and the CCPA is applicable to you and you would like to exercise your rights, please use the buttons at the bottom of this page or email us at privacy@aylopremiumltd.com  with the email subject line “CCPA Request”.

In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.

You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.

11. Resident’s Rights – Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange the Registered Users’ personal information with anyone for money.

12. Biometric Information

We employ third-party service providers to verify your identity, age, and the authenticity of the identification documents you provide using facial recognition technology. Facial recognition technology creates a mathematical representation of your facial features from the live scan of your face, your selfie, and the government-issued ID you submit or previously submitted to us. Information derived from this mathematical representation, which may be considered biometric information under the laws of certain states and countries, is shared by our service providers with us as further described below.

Your biometric information will be processed to:

Please note that this section entitled “Biometric Information” applies to relevant content partners who wish to upload content onto the Website but does not apply to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to the Website to view the contents found thereon.

13. Notice to Law Enforcement

The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:

We reserve the right to refuse online service through our Legal Service Process Platform, namely in cases where the above requirements are not met and require formal legal service at the above address. In such an event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.

14. Transfers of Your Personal Information to Other Countries

Where the laws of your country allow you to do so, by using the Website you consent to the transfer of information that we process about you, including, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer Personal Information to countries outside of the EEA or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws.

Where available, we rely on decisions of the European Commission, known as “adequacy decisions”, recognizing that certain countries offer a level of protection of Personal Information that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.

15. Retention of Personal Information

We will only retain your Personal Information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider several factors, including what Personal Information we are processing, the risk of harm from any unauthorized disclosure, why we are processing your Personal Information and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, we will delete your Personal Information from our systems.

For more information on data retention periods, please see the section “Contact Information” below on how to contact us.

Where permissible, we will also delete your Personal Information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.

16. Third-Party Links and Sites

If you click on a link to a third-party website, you will be taken to Website we do not control. This Privacy Notice does not apply to the privacy practices of these Website. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.

17. Changes to Our Privacy Notice

We may modify or revise our Privacy Notice from time to time, We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our Privacy Notice, which will be posted at this location, so you are aware of any changes, the date of change will be reflected in the “last modified date” mentioned in the header of this Privacy Notice.

18. Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us at privacy@aylopremiumltd.com.

You may also contact us at 195-197 old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.

Our Data Protection Officer can be contacted at the following email address: dpo@aylopremiumltd.com.

19. Your Rights Related to Your Personal Information

Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your Personal Information:

If we ask for your consent to process your Personal Information, you have the right to withdraw your consent at any time with effect for the future. Note that, in that case, you may no longer able to use several functionalities on the Website or access the Website in some cases.

You can exercise your rights of access or deletion of your data by following the dedicated links in the section “Manage Your Personal Data” below. If you need assistance regarding the exercise of your rights, you can also send an e-mail at privacy@aylopremiumltd.com to help you with the process. Please note that we have one month to respond to your request.

Prior to processing an access or deletion request of your data, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.

Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be able to respond to your request. Additionally, in some cases, to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.

Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address). If you delete your account, your Personal Information and all account related information including, but not limited to, user profile data, sharing data and any data or content specifically associated with your account will no longer be accessible by you. If, after deleting your account, you wish to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.

20. Manage Your Personal Information

Registered Users may request a copy of or request the deletion of their Personal Information via the links below. Please note that the below website is governed by the present Privacy Notice.

REQUEST A COPY OF MY PERSONAL DATA

DELETE MY PERSONAL DATA

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