PRIVACY POLICY

Effective Date: [12/19/2023]

  1. INTRODUCTION

    Welcome to GETHINS LIMITED.

    We operate https://lovechats.app (the “Service” or “LoveChats” or “Website”) available in the form of either a website or an application.

    Our Privacy Policy governs your visit to LoveChats, and explains how we collect, safeguard and disclose information that results from your use of our Service.

    We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

    Our Terms and Conditions (the “Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (the “Agreement”).

  2. DEFINITIONS

    1. Cookies are small files stored on your device (computer or mobile device).
    2. Data controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this privacy policy, we are a data controller of your data.
    3. GDPR means the European Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, as amended or may be amended from time to time,
    4. Personal Data means any data about a Data Subject.
    5. Data Processors (or Service Providers) mean any natural or legal person who processes the data on behalf of the data controller. we may use the services of various service providers in order to process your data more effectively.
    6. Data Subject means an identified or identifiable natural person who is the subject of personal data.
    7. User is the individual using our Service under the categories described in Section 3 below. The User corresponds to the Data Subject, who is the subject of Personal Data.
    8. Usage Data is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
  3. USERS

    1. The Website will be used by the following categories of users:
      • Category 1: a visitor of the Website who does not create an account on the Website and cannot upload any content;
      • Category 2: a user of the Website who creates an account.
    2. Subject to our Terms and Conditions and as explained in the privacy notice at https://info.lovechats.app/legal/privacynotice, we do not process personal data of the Category 1 users (i.e., the visitors of the Website who have not created an account). Instead, in such instances, we use cookies for the purposes identified in our cookie policy, which is available at https://info.lovechats.app/legal/cookiepolicy. For more information, including on how to manage your preferences on, and disable, cookies, please refer to our cookie policy, which is available at https://info.lovechats.app/legal/cookiepolicy.

    3. For the individuals who fall within the remaining Category 2, personal data is processed in line with this privacy policy.This privacy policy describes how we collect, use, process, and disclose information, including Personal Data, for Users falling under Category 2. It is applicable in conjunction with your access to and use of the Website. We process personal data only in accordance with this privacy policy.
    4. This privacy policy describes how we collect, use, process, and disclose information, including Personal Data, for Users falling under Category 2, Category 3 and Category 4. It is applicable in conjunction with your access to and use of the Website. We process personal data only in accordance with this privacy policy.
  4. ACKNOWLEDGMENT

    1. By accessing the Website, you acknowledge that you have read this privacy policy and understand that your Personal Data, including data that may reflect or concern your sex life, sexual preferences, and sexual orientation, may be processed as explained below.
    2. You also acknowledge that, if you do not grant us with your consent to process your Personal Data in accordance with the terms of this Privacy Policy, we may be unable to comply with our contractual obligations, offer you the entire range of products and services available on the Website, and allow you to create an account on this Website.
    3. By accessing this Website and creating an account, you consent to GETHINS processing your Personal Data, including data that may reflect or concern your sex life, sexual preferences, and sexual orientation. You grant your consent based on the understanding that GETHINS will rely on this basis only when necessary and proportionate to carry out its contractual obligations, comply with its legal obligations and protect its legitimate business aims.
  5. PERSONAL DATA COLLECTION

    We collect different types of Personal Data for various purposes to provide and improve our Service to you.

    1. Types of Personal Data we collect
      1. While using our Service (including but not limited to watching a video, making an inquiry or application for our services, registering to use and/or using any of our services and when you communicating with us through email, the Website or portal, or any other electronic means), we may request you to provide us with certain information and Personal Data, including but not limited to:
        1. your full name including first name and family name, gender, date of birth, email address, billing address, username, password, photograph, nationality and country of residence;
        2. other Personal Data (such sexual orientation);
        3. Cookies and Usage Data.
      2. We do not act as a joint controller of Personal Data belonging to any third parties (other than yourself) that is available or contained in any of the forms submitted, or otherwise provided to us by you (the “Third Party Personal Data”), and we hereby disclaim any and all liability in connection with the Third Party Personal Data.

      3. We collect Personal Data about the services that you use and how you use them, such as when you watch a video on the Website, visit a website that uses our advertising services or view or interact with our ads and content. This includes:
        • Device information. We collect device specific information such as IP address, access dates and times, hardware and software information, device information and cookie data.

        • Geo-location Information. When you use certain features of the Website, we may collect information about your approximate location as determined through data such as your IP address.

        • Usage Information. We collect information about your interactions with the Website such as the content you view, your searches queries and other interactions with the Website.

        • Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers, to track the activity of our Service. For more information on our use of these technologies, see our Cookie Policy, available at https://info.lovechats.app/legal/cookiepolicy. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

      4. We may collect information, including Personal Data, that others provide about you when they use the Website, or obtain information from other sources and combine it with information we collect through the Website. We do not control or supervise, and therefore, we are not responsible for how the third parties providing your information process your Personal Data. Any inquiries regarding the disclosure of your personal information to us should be directed to such third parties.
      5. To the extent permitted by the applicable law, we may receive additional information about you, such as demographic data or fraud detection information and combine it with the information we already have about you.
    2. Please note that this Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. We do not control or supervise these third-party websites and therefore, we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every site you visit.
    3. It is also important that the Personal Data we hold about you is accurate and up-to-date. Please keep us informed if your Personal Data changes during your relationship with us.
  6. HOW WE USE PERSONAL DATA WE COLLECT

    We use, store, and process information, including Personal Data, to provide, understand, improve, and develop the Website and/or the Service, to protect us and our users and to comply with our legal obligations.

    We also use this information to offer you tailored content – like giving you more relevant search results and ads.

    We collect your Personal Data for various purposes based on the below legal grounds:

    1. Provide, Improve, and Develop the Website.
      • Enable you to access and use the Website.
      • Enable you to communicate with other users.
      • Operate, protect, improve, and optimize the Website, such as by performing analytics and conducting research.
      • Provide customer service.
      • Send you service or support messages, updates, security alerts, and account notifications.
      • To operate, protect, improve, and optimize the Website, and personalize and customize your experience (such as making suggestions or ranking search results), we conduct profiling based on your interactions with the Website, your search and viewing history, your profile information and preferences, and other content you submit to the Website.
    2. Lawful bases: we rely on the following three lawful bases to process your Personal Data for the specific purpose of providing, improving and developing the Website as described above:

      • we process this Personal Data in order to adequately perform the contract with you;
      • our legitimate business interests in processing your Personal Data, specifically for the purpose of improving the Website and our users’ experience with it, which we have determined can only be achieved by processing your Personal Data. We consider the processing of your Personal Data to be proportionate with your interests, rights and freedoms;
      • to the extent necessary to perform our contract with you and customize your experience, we seek your consent to process special categories of data.
    3. Protect us and our Users and comply with our legal obligations
      • Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
      • Conduct security investigations and risk assessments, including any reports third parties may file about you or the content you have uploaded pursuant to the Terms of Service.
      • Comply with our legal obligations, including assistance in the prevention of crimes, including child sexual abuse material or non-consensual sexual acts.
      • Resolve any disputes with any of our users and enforce our agreements with third parties.
      • Communicate with you regarding any abuse reports (if you do not submit them anonymously), or any copyright infringement takedown requests or counter notifications (which cannot be submitted anonymously) that you may file pursuant to the Terms of Service.
      • Enforce our Terms and Conditions and other policies.
    4. Lawful bases: we rely on the following three lawful basis to process your Personal Data for this specific purpose:

      • legal obligations to which we are subject, which may include disclosing your Personal Data to a third party or competent national authorities.
      • consent to process certain special categories of personal data is sought to the extent necessary to achieve the purposes set out above. This includes transferring limited categories of your Personal Data to third parties against whom you have filed a copyright infringement takedown request under the Digital Millennium Copyright Act (DMCA) or to whom you are responding with a copyright counter-notification, in accordance with our Terms and Conditions and as further described in this Privacy Policy.
      • legitimate interests in protecting our business, which includes protecting the Website and our reputation as a law-abiding business to the extent appropriate. We consider the processing of your Personal Data to be proportionate with your interests, rights and freedoms.
      1. Personal Data processed when filing a takedown request or a counter-notification pursuant to paragraph 11 of our Terms and Conditions

        Although our Company is based outside the United States, we respect the rights of copyright owners and thus have implemented certain policies in an effort to voluntarily comply with laws, such as the Digital Millennium Copyright Act (the "DMCA").


        What is the Digital Millennium Copyright Act?

        The takedown process provided by the DMCA is a tool for copyright holders to have user-uploaded material that infringes their copyrights taken down from our website. The process entails the copyright owner (or the owner’s agent) sending a copyright infringement takedown request to a service provider requesting that the provider remove material that the copyright owner contends is infringing their copyright(s). Once a website is in receipt of the takedown request, it is required to send the takedown request to the uploader of the material in question. The uploader is subsequently given a chance to respond to the takedown request . The mechanism serves as an initial step for the copyright holder and the uploader to resolve any dispute relating to the copyrighted material at issue. For that purpose, NKL is required to process and transfer limited personal data between the individuals submitting a takedown request (i.e., the alleged copyright holder) and the uploader.


        In compliance with the DMCA, we only accept copyright infringement takedown notices from content owners or someone officially authorized to act on their behalf. To read more about the requirements of a complete notice, we invite you to visit https://www.dmca.com/faq/What-is-a-DMCA-Takedown, and consult with your own counsel. (We do not and cannot provide you with legal advice, and none should be implied from this Privacy Notice or anything else on our site.) Information provided for purposes of copyright takedown requests / counter-notifications will be forwarded to the uploader of the material at issue.


        What lawful basis do we rely upon to process your Personal Data when you file a copyright infringement takedown request / counter-notification pursuant to the DMCA?

        For the specific purpose of our review of your copyright infringement takedown request / counter-notification which you may have filed pursuant to paragraph 11 of our Terms and Conditions, you are required to provide the information needed to make a valid request, including but not limited to:
        (a) takedown website URL and
        (b) statement regarding the ownership of this content.


        We will process your Personal Data in order to further our legitimate interests as an entertainment business that respects intellectual property rights, abide by the law and acts appropriately when reports of copyright infringements are made. For those legitimate purposes, we process your personal data we deem necessary in order to be able to review the takedown request / counter-notification that you may have submitted pursuant to paragraph 6C of the Terms of Service and to allow us to contact you about its content. We consider the processing of your personal data to be proportionate with your interests, rights and freedoms.


        In line with the mechanism provided for under the DMCA, explained above, we will also share with the takedown request claimant or the counter-notification claimant the following personal data to comply with and follow the prescribed steps under the DMCA: your name, your contact information, as well as the contents of your takedown request or your counter-notification. We rely on your consent to transmit your personal data to the addressees of your takedown request or counter-notifications. By submitting a copyright infringement takedown request, you consent to your data being transmitted to the uploader of the material in question in line with and for the reasons explained above and detailed in our Terms of Service. Without your consent, we are unable to process your takedown request or counter-notifications as prescribed under the DMCA.

    5. Provide, Personalize, Measure, and Improve our Advertising and Marketing.
      • Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Website).
      • Personalize, measure, and improve our advertising based on your characteristics and preferences (based on the information you provide to us, your interactions with the Website, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

      Lawful bases: we rely on the following two lawful bases to process your Personal Data for this specific purpose:

      • We process your Personal Data for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. We consider the processing of your Personal Data to be proportionate with your interests, rights and freedoms.
      • To the extent necessary, we will also rely on your consent to process special categories of Data in undertaking marketing activities and personalising the content on the Website.

      You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your account.

    6. your direct contact with us through our Website or by post, phone, email or otherwise
      • Respond to your queries regarding the Service or to your complaints.
      • Provide you with further information on privacy.
      • Any other queries you may have for which you contact us.

      Lawful bases: when you contact us directly through our Website or by post, phone, email or otherwise, including for the purposes of exercising your rights under the GDPR or to file any complaints, we will rely on the following two bases to process your Personal Data:

      • We rely on our legitimate interests as a customer-friendly entertainment business that wants to improve the experience of the customers using our Website, to resolve satisfactorily any complaints made by our customers, or to respond to any requests for further information. We will process your personal data we deem necessary for these legitimate interests. Additionally, in rare cases where we reasonably determine that your direct communications with us or our staff are or become abusive, amount to harassment or otherwise illegal under the applicable laws, we may also process your personal data for these purposes and pass it onto the relevant governmental authorities. We consider the processing of your Personal Data to be proportionate with your interests, rights and freedoms.
      • We may also need to rely on our legal obligations to process your Personal Data in cases where the applicable law compels us to communicate your Personal Data exchanged in direct communications with us to the responsible governmental authorities.
  7. YOUR RIGHTS UNDER GDPR

    In accordance with the GDPR you have specific rights related to your Personal Data.

    You may exercise any of the rights described in this section by adjusting settings in your user account and, if it is not possible, you can contact us at hello@perchapps.com.

    Please note that we will ask you to verify your identity before taking further action on your request, and if we cannot identify you we cannot act according to your request.

    You have the following data protection rights:

    1. Managing Your Information.

      You may access and update the Personal Data we hold about you. You are responsible for keeping your Personal Data up-to-date in a secure place.

    2. Rectification of Inaccurate or Incomplete Information.

      You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your account) by contacting us at the address listed in the Contact Us section below.

    3. Withdrawing Consent and Restriction of Processing.

      Where you have provided your consent to the processing of your Personal Data by us, you may withdraw your consent at any time by changing your account settings. The withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
      Additionally, you have the right to limit the ways in which we use your Personal Data, in particular where (i) you contest the accuracy of your Personal Data; (ii) the processing is unlawful and you oppose the erasure of your Personal Data; (iii) we no longer need your Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of the Website provider override your own.

    4. Objection to Processing.

      You have a right to require us not to process your Personal Data for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
      Where your sensitive Personal Data are processed you may, at any time ask us to cease processing your data by changing your user’s profile settings.

    5. Lodging Complaints.

      We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Data, you may contact our respective Data Protection Officer at hello@perchapps.com. We will investigate your complaint promptly and will reply to you within 30 (thirty) calendar days.
      If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed, you have the right to lodge a complaint at any time to Cyprus supervisory authority, the Office of the Commissioner for Personal Data. https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page1i_gr/page1i_gr?opendocument We would appreciate the chance to deal with your concerns and address your queries before you approach the supervisory authority.

      While we recognize that the rights of Data Subjects under GDPR are fundamental, there are certain circumstances where these rights might be subject to exceptions or limitations. Any exceptions or limitations to these rights are either defined by applicable laws or are necessary, proportionate and respect the essence of fundamental rights and freedoms of the Data Subject.

  8. CHILDREN’S PRIVACY

    1. Some of our Services are not intended for use by children under the age of 18 or the age of majority in their jurisdiction (the “Child” or “Children”).
    2. We do not knowingly solicit or collect Personal Data from Children.
    3. If you are under the age specified above, please refrain from attempting to register on our Website or provide us with any information about yourself.
    4. If you become aware that a Child has provided us with Personal Data or that we have collected Personal Data from Children without verification of parental consent, please inform us immediately to take steps to remove that information from our records.
    5. We will take all necessary steps to remove and permanently delete from our records any Personal Data provided to us about a minor and promptly suspend any account created by a minor.
  9. PERSONAL DATA TRANSFER OUTSIDE THE EEA

    Where we transfer, store, and process your personal data outside of the EEA, we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. We rely on EU model clauses and adequacy decisions issued by competent European authorities. If we are unable to rely on these two bases, we will transfer data outside the EEA to the extent doing so is: (a) necessary for the performance of a contract between you and us; (b) necessary for the conclusion or performance of a contract concluded for your interest between us and another natural or legal person; (c) necessary for the establishment, exercise, or defense of legal claims; or (d) any other bases listed in Article 49 of the GDPR if applicable, such as seeking your consent.

    We share certain data within our corporate group of companies and with the following groups of recipients to the extent we deem it necessary to be able to perform our operations or are compelled to do by law:

  10. COOKIES POLICY AND GOOGLE ANALYTICS

    Our Website uses session cookies and persistent cookies. To learn more about cookies, please visit our cookies policy, available at https://info.lovechats.app/legal/cookiepolicy, which explains how cookies works, what data we collect and how you can manage your preferences.

  11. SECURITY

    Gethins keeps all the data it processes in a secure environment. We protect Personal Data by using appropriate safeguard procedures and measures, in particular:

    While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

    If you know or have reason to believe that your account credentials or your Personal Data have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us immediately by email hello@perchapps.com.

  12. RETENTION OF PERSONAL DATA

    1. We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
    2. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
    3. To determine the appropriate retention period for Personal Data, we consider factors such as the quantity, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes of processing, the feasibility of achieving those purposes through alternative means and compliance with applicable legal requirements.
    4. When the need to process your Personal Data for purposes outlined in this Privacy Policy, ceases, we will permanently delete your Personal Data from our systems. However, if we are unable to delete it due to legal, regulatory or technical reasons, we may retain your Personal Data for an extended period. In such cases, we ensure that your privacy is protected and that your Personal Data is solely processed for the specified purposes.
  13. LINKS TO OTHER SITES

    Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

  14. CHANGES TO THIS PRIVACY POLICY

    We reserve the right to modify this Privacy Policy at any time and without prior notification to you. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website and update the “Last Updated” date at the top of this Privacy Policy. If you disagree with the revised privacy policy, you may cancel your account. If you do not cancel your account before the date the revised privacy policy becomes effective, your continued access to or use of the Website will be subject to the revised privacy policy.

  15. LAW AND HARM

    Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your Personal Data if we believe it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our Users’ rights or property. This Privacy does not intend to limit any legal defenses or objections you may have to a government’s request for disclosure of your Personal Data.

  16. NO ERROR FREE PERFORMANCE

    We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive damages relating to this Privacy Policy.

  17. CONTACT US

    You may contact us at