プライバシー・Cookieポリシー
この文書は英語版とチェコ語版のみご用意しています。以下は英語版です。
This policy explains what personal data we process when you visit www.seeamateurs.com, join the waitlist, create an account or make a purchase, why we do it, how long we keep the data and what rights you have. We collect only what we need, we never see your full card number, we do not sell your data, and we use no advertising or third-party tracking unless you explicitly agree to marketing cookies on a model's page – our analytics are self-hosted and work without cookies.
1. Controller
The controller of your personal data is:
- Media Logic s.r.o., Štúrova 1701/55, 142 00 Praha 4 – Krč, チェコ
- Company ID: 28971621, VAT ID: CZ28971621
- Registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Insert 156872.
- E-mail for all privacy matters: perseya@seeamateurs.com
We have not appointed a data protection officer because we are not required to do so. Please send all questions about your personal data to the e-mail address above.
2. Personal data we process
- Waitlist and newsletter: your e-mail address, the language of the Site you signed up in, and proof of your consent – the exact wording of the consent you gave, the time of sign-up, confirmation and any unsubscription, your IP address and browser details (user agent and the browser, operating system and device type derived from it, browser language, time zone, screen size and the referring page).
- Account: e-mail address, username, display name, password (stored only as a secure hash, never in readable form), your confirmation that you are 18 or older, language settings, the date of registration and your activity on the Site (for example, likes and unlocked posts).
- Subscriptions and purchases: what you bought, when, the price, currency, taxes, transaction and subscription identifiers, payment status, renewals and cancellations. We do not receive or store your full card number or security code – card details are entered only on the secure page of our payment processor.
- Communication and complaints: your e-mail address, your name (if you give it), the type of request, the web address concerned, the content of your message and our correspondence; for submissions via the complaint form also your IP address, browser user agent and language.
- Age verification: before your first payment we verify that you are 18 or over through our verification partner Didit. You photograph an identity document and take a selfie; Didit reads the document, checks that the selfie shows a live person and that it matches the document, and reports the result to us. We store only the identifier of the verification session, its result, the date and the type of document used – not the document, its images, your name, your date of birth or your biometric data.
- Country: from your IP address we determine only the country (a two-letter code) using a local database, so we can apply the age verification rules of your country; the country code is stored with your account at registration and at each login (not the IP address). IP geolocation by DB-IP.
- Technical and security data: IP address, date and time of access, requested pages, user agent and error records in server logs; records of login attempts used to block password-guessing attacks.
- Analytics data: anonymised information about visits to the Site (see section 12).
Apart from the biometric check described above, which Didit carries out on our behalf and of which only the result reaches us, we do not ask for or process special categories of personal data (such as health or sexual orientation). Please do not send us such data.
3. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Sending launch announcements and the newsletter to people who have joined the waitlist | E-mail, language | Your consent – Art. 6(1)(a); you can withdraw it at any time |
| Proof of consent and protection of the sign-up form against bots and abuse | Consent record, IP address, browser details | Legitimate interest – Art. 6(1)(f) – in demonstrating consent (Art. 7(1)) and in preventing abuse |
| Creating and running your account, providing access to subscriptions and unlocked posts, customer support | Account data, purchase records | Performance of a contract – Art. 6(1)(b) |
| Service e-mails (confirmation of purchase, renewal, cancellation, price change, changes to the Terms) | E-mail, purchase records | Performance of a contract – Art. 6(1)(b); legal obligation – Art. 6(1)(c) |
| Verifying that you are 18 or over before your first payment | Identity document and selfie (processed by Didit), the result of the check | Legal obligation – Art. 6(1)(c) – and legitimate interest – Art. 6(1)(f) – in keeping minors away from adult content; for the biometric comparison your explicit consent – Art. 9(2)(a) – which you give to Didit before the check |
| Accounting and tax records | Purchase and billing records | Legal obligation – Art. 6(1)(c) (Czech accounting and VAT laws) |
| Handling complaints, content reports, removal requests and the exercise of your rights | Communication and complaint data | Legal obligation – Art. 6(1)(c); legitimate interest – Art. 6(1)(f) – in handling reports and protecting the rights of others |
| Security of the Site, fraud and chargeback prevention, bot protection, enforcement of the Terms and defence of legal claims | Technical and security data, account and purchase data | Legitimate interest – Art. 6(1)(f) |
| Anonymised statistics on how the Site is used, to improve it | Analytics data | Legitimate interest – Art. 6(1)(f) |
Where we rely on legitimate interest, we have weighed our interests against your rights and freedoms. You can object to this processing at any time (section 9).
4. Where the data comes from and whether you must provide it
We obtain most data directly from you or from your browser when you use the Site. We receive information about the result of a payment (but not your card details) from our payment processor. Providing your e-mail for the waitlist is voluntary. The account data is necessary for concluding and performing the contract – without it we cannot give you access to paid content. Some data (such as billing records) must be kept by law.
5. Recipients and processors
We share personal data only to the extent necessary, with:
- Hosting provider – servers located in Germany (EU), which store the Site and its database;
- E-mail service – our e-mails are sent through the SMTP service of our hosting provider onlinehosting.cz (Czech Republic);
- Payment processor – our third-party payment processor, whose name is shown at checkout, processes your payment details and checks transactions for fraud. It acts as an independent controller for the payment data it collects, and its own privacy policy applies to that processing;
- Age verification provider – Didit, which checks your identity document and performs the biometric comparison before your first payment. The document and the biometric data are processed by Didit under a data processing agreement with us and under its own privacy policy; only the result of the check reaches us;
- Professional advisers – for example, our accountant, tax adviser or lawyer, who are bound by confidentiality;
- Public authorities, banks and card schemes – where we are required to provide data by law, or where it is necessary to resolve a chargeback or investigate fraud or illegal content.
Our processors process data only on our instructions and under a data processing agreement. Our analytics tool (Matomo) runs on our own server, so analytics data is not passed to any third party. We do not sell personal data and do not share it for advertising.
6. International transfers
We store data within the European Union. Our payment processor may be located outside the EU/EEA, for example in the United States. Such transfers take place only on the basis of an adequacy decision of the European Commission (for example, the EU–U.S. Data Privacy Framework, where the recipient is certified) or under the European Commission's standard contractual clauses with additional safeguards where needed (Art. 45 and 46 GDPR). You can ask us for more information about these safeguards.
7. How long we keep data
| Data | Retention period |
|---|---|
| Waitlist and newsletter | Until you unsubscribe or withdraw your consent. If you do not confirm your e-mail address, we delete the sign-up no later than 12 months after it was made. |
| Proof of consent and unsubscription | As long as needed to demonstrate consent, and no longer than 3 years after you withdraw it. During this time we keep your address on a do-not-contact list so that we do not write to you again. |
| Account data | For as long as your account exists; after it is closed we delete it or anonymise it, except for data we must keep for the reasons below. |
| Billing and purchase records | 10 years from the end of the year in which the transaction took place (accounting and VAT laws). |
| Complaints, content reports and related correspondence | 3 years from their resolution. |
| Age verification record | For as long as your account exists and then 3 years, so that we can demonstrate that we checked your age before accepting a payment. We keep only the session identifier, the result, the date and the type of document. |
| Server and security logs | 90 days, unless needed longer to investigate a specific security incident. |
| Raw analytics data | No more than 13 months; after that only aggregated statistics that do not relate to any individual are kept. |
If data is needed to establish, exercise or defend a legal claim, we may keep it until the matter is finally resolved.
8. Security
We protect your data with appropriate technical and organisational measures: all connections to the Site are encrypted (HTTPS), passwords are stored only as secure hashes, access to data is limited to authorised persons, login attempts are limited, and payments are processed exclusively by a certified (PCI DSS) payment processor.
9. Your rights
Under the GDPR you have the right to:
- access your personal data and receive a copy of it (Art. 15);
- rectification of inaccurate or incomplete data (Art. 16);
- erasure of your data, unless we have to keep it, for example for tax purposes (Art. 17);
- restriction of processing, for example while we check the accuracy of your data (Art. 18);
- data portability – receiving the data you have given us, processed on the basis of consent or contract, in a structured, machine-readable format (Art. 20);
- object to processing based on legitimate interest (Art. 21) – we will stop unless we have compelling legitimate grounds; you can object to direct marketing at any time, without giving a reason;
- withdraw your consent at any time (Art. 7(3)) – for example by clicking the unsubscribe link in any e-mail. Withdrawal does not affect the lawfulness of processing before it.
10. How to exercise your rights
Send your request to perseya@seeamateurs.com, ideally from the e-mail address registered with us. If we have reasonable doubts about your identity, we may ask you for additional information to confirm it. We will respond without undue delay and within one month at the latest; in complex cases we may extend this period by up to two further months, and we will tell you why. Exercising your rights is free of charge, unless requests are manifestly unfounded or excessive.
11. Right to lodge a complaint
If you believe that we process your personal data unlawfully, you can lodge a complaint with the supervisory authority: Úřad pro ochranu osobních údajů (Office for Personal Data Protection), Pplk. Sochora 27, 170 00 Praha 7, Czech Republic, www.uoou.cz. You can also contact the supervisory authority in the EU country where you live or work. We would be grateful if you contacted us first – we will try to resolve the matter.
12. Cookies and analytics
We use only cookies that are strictly necessary for the Site to work or that remember a choice you have made, so we do not need your consent to use them. Advertising pixels (Meta, TikTok, Google) of a model are loaded only on that model's public pages and only if you agree to marketing cookies in the cookie bar; without your consent nothing is loaded and your browser does not contact those services. You can change your choice at any time with the "Cookie settings" button.
| Cookie | Purpose | Duration |
|---|---|---|
Session cookie (PHPSESSID) | Keeps you signed in during your visit, protects forms and remembers the state of the session (e.g. a confirmation after submitting a form). Strictly necessary. | Until you close your browser |
REMEMBERME | Keeps you signed in on this device; set only if you leave "Remember me" ticked when signing in. Functional. | 30 days |
__Host-csrf-token_… | Protects forms against cross-site request forgery. Strictly necessary. | A few seconds – deleted after the form is submitted |
locale | Remembers the language you have chosen. Functional. | 1 year |
age_verified | Remembers that you confirmed you are 18 or older, so that the age notice is not shown again. Strictly necessary. | 1 year |
sa_lt, sa_rf | Remember a random code of the link (a model's campaign link or a friend's invitation link) you arrived through, so the registration can be credited to it. They contain no personal data and are deleted after registration. Functional. | 30 days |
sa_consent | Remembers your choice about marketing cookies (accepted or rejected). Functional. | 6 months |
You can delete or block cookies in your browser settings. If you block strictly necessary cookies, signing in and some other functions will not work. The payment processor's checkout page may use its own cookies; its own policy applies to them.
Analytics: we measure visits with Matomo, which runs on our own server, so the data never leaves our control. Matomo is set up without cookies, and your IP address is anonymised immediately (the last two bytes are removed), so we cannot identify you. We see only aggregated information such as visited pages, the referring website, browser, operating system, device type, screen resolution, language and approximate location (country). To recognise page views within a single visit, Matomo uses a temporary identifier calculated from technical data of the request combined with a value that changes every day, so your visits cannot be linked across days. We do not combine analytics data with your account. If you do not want your visits to be measured, you can block JavaScript or use a tracker-blocking extension in your browser, or object by e-mail.
13. E-mails we send
- Waitlist and newsletter: after you sign up, we send you an e-mail with a confirmation link (double opt-in). If you do not confirm, we send one reminder after 24 hours and nothing more. Announcements and newsletters are sent only to confirmed addresses.
- Service e-mails: to account holders we send e-mails necessary to provide the service – for example, confirmations of purchases and cancellations, and notices of price changes or changes to the Terms.
- Every newsletter and announcement contains a one-click unsubscribe link. You can also unsubscribe by e-mail to perseya@seeamateurs.com.
14. Automated decision-making
We do not make decisions based solely on automated processing, including profiling, that would have legal or similarly significant effects on you. Our payment processor may use automated fraud checks when processing a payment, which may result in a payment being declined; its own privacy policy applies to that processing, and you can contact the processor or us for a review.
15. Minors
The Site is intended exclusively for adults aged 18 or over. We do not knowingly collect personal data from minors. If we find out that a minor has provided us with personal data, we close the account and delete the data. If you believe a minor has given us their data, please tell us at perseya@seeamateurs.com.
16. Changes to this policy
We may update this policy, for example when we introduce new features or when the law changes. We will publish the current version on this page and inform registered users of significant changes by e-mail in advance. This policy is effective from October 1, 2026.