Privacy Policy

1. Introduction

VelvetElite ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our Platform, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

VelvetElite is the data controller responsible for your personal data. Our contact details are:

3. Personal Data We Collect

We collect and process the following categories of personal data:

3.1 Account Information

• Email address
• Password (encrypted)
• Account type (Member or Creator)
• Account creation and login timestamps

3.2 Creator Profile Information

• Display name and profile description
• Location (general area, not precise address)
• Profile photographs
• Service categories and preferences
• Contact preferences (platforms for communication)

3.3 Identity Verification Data (Creators Only)

• Government-issued identification document
• Photograph for liveliness verification
• Verification status and timestamps

3.4 Payment Information

• Transaction history
• Subscription status
• Payment method details are processed by our payment provider and not stored by us

3.5 Usage Data

• IP address
• Browser type and version
• Device information
• Pages visited and features used
• Date and time of access

4. Lawful Basis for Processing

We process your personal data on the following legal bases:

• Contract Performance: Processing necessary to provide our services to you, including account management, subscription processing, and platform functionality.
• Legal Obligation: Processing required to comply with UK laws, including age verification requirements under the Online Safety Act 2023 and financial record-keeping obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided these do not override your rights.
• Consent: Where you have provided explicit consent, such as for marketing communications.

5. How We Use Your Data

We use your personal data for the following purposes:

• Providing and maintaining the Platform
• Processing account registration and authentication
• Verifying age and identity
• Processing payments and subscriptions
• Communicating with you about your account and services
• Enforcing our Terms and Conditions and Content Policy
• Detecting and preventing fraud and abuse
• Complying with legal obligations
• Improving our services and user experience

6. Data Sharing

We may share your personal data with:

• Service Providers: Third-party providers who assist with payment processing, identity verification (AgeVerif), email services, and cloud hosting. These providers are contractually bound to protect your data.
• Law Enforcement: We may disclose data to law enforcement agencies, regulators, or other authorities when required by law or to protect the safety of our users.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction.

We do not sell your personal data to third parties.

7. International Data Transfers

Some of our service providers may be located outside the UK. Where we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO).

8. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy:

• Account data: Retained while your account is active and for 2 years after deletion
• Identity verification data: Retained for 5 years after account closure as required by anti-money laundering regulations
• Transaction records: Retained for 7 years as required by UK tax regulations
• Usage data: Retained for 12 months for analytics purposes

9. Your Rights

Under UK GDPR, you have the following rights:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your data in certain circumstances.
• Right to Restriction: Request restriction of processing in certain circumstances.
• Right to Data Portability: Receive your data in a structured, commonly used format.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.

To exercise these rights, contact us at privacy@velvetelite.com. We will respond within one month.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• SSL/TLS encryption for data in transit
• Encrypted storage for sensitive data
• Access controls and authentication
• Regular security assessments
• Staff training on data protection

11. Cookies

We use cookies and similar technologies to enhance your experience. For detailed information about our use of cookies, please see our Cookie Policy.

12. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will take steps to delete it immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or prominent notice on the Platform. We encourage you to review this policy periodically.

14. Complaints

If you have concerns about how we handle your data, please contact us first at privacy@velvetelite.com. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

15. Contact Us

For any questions about this Privacy Policy or our data practices: