Privacy Policy
Last Updated: [DATE]
1. Who We Are and What This Policy Covers
1.1 This Privacy Policy explains how [MUSCLE WORSHIP OÜ], registry code [●], registered address [●], Tallinn, Estonia ("Muscle Worship", "we", "us"), processes personal data when you visit or use the muscleworship.io platform (the "Platform"). We are the data controller for the processing described in this Policy.
1.2 Sensitive context — read this. The Platform is an adult content service. The fact that you hold an account, together with your activity on it, can reveal information concerning your sex life or sexual orientation. Under Article 9 GDPR this is special-category data and we process it only with your explicit consent, which we ask for when you register (and which you may withdraw at any time — Section 10). If you do not give or you withdraw that consent, you cannot use the Platform, because operating your account inherently involves this data.
1.3 Data protection contacts. Data Protection Officer: dpo@muscleworship.io / [DPO name or provider], [address]. General privacy requests: privacy@muscleworship.io. UK representative (Article 27 UK GDPR): [●] [DRAFTING NOTE: appoint if UK users are targeted]. As an Estonian controller, no separate EU representative is required.
1.4 This Policy applies to all users (Fans, Creators, and visitors). Sections 5 and 6 contain additional information for Creators and for persons appearing in content.
2. Age Restriction
The Platform is strictly for adults (18+). We do not knowingly process the data of anyone under 18; where legally required we use age-assurance measures before granting access to adult material (Section 6). If we learn that a person under 18 has used the Platform, we delete their account and data, subject to legal preservation duties, and take steps to prevent re-registration.
3. Personal Data We Process
- Account data: email address, username, password (hashed), date of birth, account type, country, language, settings.
- Verification data (Creators, and Fans where verification is required): government ID document data, selfie/liveness imagery, verification result, sanctions/PEP screening results — collected and processed by our verification provider (Section 6).
- Profile data: display name, bio, photos, physique/competition details, and other information you choose to publish.
- Content data: photos, videos, live streams, messages, comments, and metadata (upload time, classification labels, moderation status).
- Transaction data: purchases, subscriptions, wallet top-ups and balance, escrow states, payouts, platform fees, currency, timestamps, billing country, VAT determination data, limited payment-instrument data (card brand, last four digits, expiry) — full card numbers are held by our payment processors, never by us.
- Session data: bookings, attendance, duration, ratings, disputes and their evidence.
- Usage and device data: IP address, device and browser type, pages viewed, referral source, log data, approximate location derived from IP.
- Communications: support tickets, complaint and appeal records, notification preferences.
- Compliance data: moderation decisions, statements of reasons, DMCA notices, consent and takedown records, fraud and risk scores, AML/KYC records, tax reporting data (DAC7).
4. Purposes and Legal Bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Creating and operating your account; providing content, Subscriptions, Sessions, wallet, payouts | Contract (Art. 6(1)(b)); explicit consent for the special-category dimension (Art. 9(2)(a)) |
| Age, identity, and liveness verification; sanctions/PEP screening | Legal obligation (Art. 6(1)(c)) — AML, age-verification and card-network-mandated checks; explicit consent where biometric age/ID checks require it (Art. 9(2)(a)) |
| Payment processing, fraud prevention, chargeback handling | Contract (6(1)(b)); legal obligation (6(1)(c)); legitimate interests (6(1)(f): protecting the Platform and users from fraud) |
| Content moderation, complaint handling, statements of reasons, transparency reporting | Legal obligation (6(1)(c): DSA); legitimate interests (6(1)(f): platform safety); contract (6(1)(b)) |
| Record-keeping for performer age/consent verification | Legal obligation and legitimate interests (compliance with 2257-analog contractual regime and card-network rules) |
| Tax and accounting, DAC7 reporting of Creator income | Legal obligation (6(1)(c)) |
| Service emails (receipts, confirmations, security alerts) | Contract (6(1)(b)) |
| Marketing emails | Consent (6(1)(a)) — opt-in, withdrawable at any time |
| Analytics and product improvement | Consent for non-essential cookies (ePrivacy); legitimate interests for aggregated, privacy-preserving measurement |
| Establishing, exercising, or defending legal claims | Legitimate interests (6(1)(f)); Art. 9(2)(f) for special-category data |
We do not use your data for third-party advertising, and we do not sell personal data.
5. Creators and Persons Appearing in Content
5.1 Creators' verification records, tax data, and payout data are processed to meet KYC/AML, card-network, tax (including DAC7 reporting to the Estonian Tax and Customs Board, which may exchange it with other EU tax authorities), and platform-compliance obligations.
5.2 Where you appear in content uploaded by another Creator, that Creator is required to hold your signed consent and ID verification (Terms of Service, Section 10). When those records are provided to us for audit or complaint handling, we process them to verify age and consent, resolve complaints, and meet card-network obligations. If you wish to withdraw consent to content you appear in, see the DMCA & Content Removal Policy — we act on withdrawal regardless of which Creator uploaded the content.
5.3 Published content and profiles are visible to other users according to your visibility settings; treat everything you publish as potentially public. We provide tools (watermarking, geo-blocking) but cannot guarantee third parties will not misuse published content (Legal Disclaimer, Section 5).
6. Age and Identity Verification; Biometric Data
Verification is performed by specialist providers acting as our processors [(currently [PROVIDER NAME])]. Face imagery and biometric templates used for liveness and age estimation are collected and held by the provider; we receive only the verification outcome and required audit fields, and we do not ourselves store facial-recognition templates. Where a jurisdiction's age-verification law mandates non-retention, verification data is retained only as that law permits. You may ask the provider or us which data the provider holds.
7. Who We Share Data With
- Payment processors and acquirers (transaction data needed to process payments, prevent fraud, and meet card-network rules — including complaint statistics reporting);
- Verification providers (Section 6);
- Hosting, storage, communications, moderation-tooling, and support providers acting under processing agreements;
- Other users, per your settings and activity (profiles, content, messages);
- Professional advisers, auditors, insurers;
- Authorities and third parties where the law requires or permits: courts, law enforcement, tax authorities (DAC7), financial intelligence units, NCMEC (suspected child sexual abuse material), and parties to legal proceedings under valid process;
- A buyer or successor in a merger, acquisition, or asset sale, under confidentiality obligations.
We require all processors to act only on our instructions and to protect your data by contract meeting Article 28 GDPR.
8. International Transfers
We are established in Estonia and store data primarily in the EU/EEA. Where data is transferred to countries without an EU adequacy decision (for example, to a U.S.-based processor), we use the European Commission's Standard Contractual Clauses together with supplementary measures, or another valid mechanism (including the EU–U.S. Data Privacy Framework where the recipient is certified). You may obtain a copy of the relevant safeguards via privacy@muscleworship.io.
9. How Long We Keep Data
| Category | Retention |
|---|---|
| Account and profile data | Life of the account + up to 90 days after closure (dispute wind-down), then deleted or anonymised |
| KYC/AML verification records | 5 years after the end of the business relationship (Estonian Money Laundering and Terrorist Financing Prevention Act; extendable where the FIU requires) |
| Performer age/consent records provided to us | While the related content is available + 7 years |
| Transaction, invoicing, and accounting records | 7 years (Estonian Accounting Act) |
| Moderation decisions, complaints, statements of reasons | Up to 5 years (DSA transparency, defence of claims) |
| Content you delete | Removed from public view immediately; residual copies purged from backups within [30] days, except where preservation is legally required (e.g., evidence of unlawful content) |
| Support communications | 3 years after closure of the matter |
| Marketing consents and preferences | Until withdrawn + proof-of-consent records 5 years |
| Server logs and IP data | [12] months |
Banned-user records (limited identifiers needed to enforce bans and legal exclusions) are retained as long as necessary for platform safety and legal defence.
10. Your Rights
Under the GDPR you may: access your data and obtain a copy; rectify inaccurate data; erase data (subject to the legal retention duties above); restrict processing; object to processing based on legitimate interests; receive your data in a portable format; and withdraw any consent at any time, without affecting prior processing. Self-service tools are at *Settings → Privacy* (export, deletion request); or contact privacy@muscleworship.io. We respond within one month (extendable by two further months for complex requests, with notice). We may need to verify your identity before acting.
You may lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee, Tatari 39, Tallinn) or the supervisory authority of your residence or workplace. UK users: the ICO (ico.org.uk).
11. U.S. State Privacy Disclosures
If you reside in California, Colorado, Connecticut, Texas, Virginia, or another U.S. state with a comprehensive privacy law, you have rights of access, correction, deletion, portability, and to opt out of "sales", "sharing", and targeted advertising. We do not sell or share personal data for cross-context behavioral advertising and do not process personal data for targeted advertising. Sensitive-data processing (account existence on an adult platform; verification data) occurs only with your consent or as strictly necessary to provide the service you request. Submit requests to privacy@muscleworship.io; we do not discriminate against you for exercising rights, and you may appeal a refusal by replying to our decision, after which you may contact your state Attorney General.
12. Cookies and Similar Technologies
We use: essential cookies (authentication, security, load balancing — no consent required); and, only with your consent via the cookie banner, preference and analytics cookies. We do not use third-party advertising cookies. You can change your choices at any time via *Cookie Settings* in the footer. Full details, including names and lifetimes, are in the Cookie Table at [/cookies]. "Do Not Track" and Global Privacy Control signals are honoured where they signal an opt-out we are required to respect.
13. Security
We apply technical and organisational measures appropriate to the high sensitivity of this service: TLS encryption in transit, encryption at rest, access controls and least-privilege administration, segregated storage of verification outcomes, logging and monitoring, and vendor due diligence. No system is perfectly secure; if a breach occurs that risks your rights, we will notify the supervisory authority within 72 hours and affected users without undue delay, as the GDPR requires. Protect your own account with a strong unique password and two-factor authentication (*Settings → Security*).
14. Automated Decision-Making
We use automated tools for: pre-publication content screening, fraud and chargeback risk scoring, and AML screening. Decisions with significant effects (account rejection, content removal, payout blocking) are subject to human review — automated flags trigger review rather than final decisions, and every moderation decision can be appealed to a human reviewer (Terms of Service, Section 12.4; DMCA & Content Removal Policy, Section 6).
15. Changes to This Policy
We will notify you of material changes by email or Platform notification before they take effect and update the date above. The version history is available on request.
16. Contact
[MUSCLE WORSHIP OÜ] · Registry code [●] · [Address], Tallinn, Estonia privacy@muscleworship.io · dpo@muscleworship.io · [SUPPORT PHONE]