Privacy Policy

This Privacy Policy describes how Velvet Lobby ("we," "us," or "our") collects, uses, and shares information about you when you use our Platform. By using the Platform, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly to us, including:

• Account information: name, email address, username, and password when you register.
• Profile information: display name, biography, location, photographs, service descriptions, rates, and other content you choose to include in your profile (Providers only).
• Verification materials: government-issued photo identification and verification selfie photographs submitted for age and identity verification (Providers only). These are stored securely and never displayed publicly.
• Payment information: cryptocurrency wallet addresses and transaction identifiers associated with subscription or membership purchases. We do not store credit card numbers or bank account details.
• Communications: messages you send through the Platform's messaging system, and any correspondence you send to us directly.

1.2 Information Collected Automatically

When you use the Platform, we automatically collect certain information, including:

• Log data: IP address, browser type and version, operating system, referring URLs, pages visited, and timestamps of your visits.
• Device information: hardware model, operating system version, unique device identifiers, and mobile network information.
• Usage data: features you use, searches you conduct, profiles you view, and other interactions with the Platform.
• Cookies and similar technologies: see our Cookie Policyfor details.

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Platform and its features.
• Process transactions and send related information, including confirmations and receipts.
• Verify the age and identity of Providers as required by law and our Terms of Service.
• Send administrative messages, technical notices, updates, and security alerts.
• Respond to your comments, questions, and requests.
• Monitor and analyze usage patterns and trends to improve user experience.
• Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities.
• Comply with legal obligations, including responding to lawful requests from law enforcement.
• Enforce our Terms of Service and other policies.

3. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

• With other users: Provider profile information (display name, photographs, biography, location, rates, and contact details you choose to include) is publicly visible to all Platform visitors. Verification materials are never shared publicly.
• Service providers: We share information with third-party vendors and service providers that perform services on our behalf, such as cloud hosting, data analytics, and customer support. These parties are contractually obligated to use your information only as directed by us.
• Legal compliance: We may disclose your information if we believe disclosure is required by law, regulation, legal process, or governmental request, including to comply with subpoenas or court orders. We will report any content depicting minors in a sexual manner to the National Center for Missing and Exploited Children (NCMEC) and relevant law enforcement.
• Safety: We may share information to protect the rights, property, or safety of Velvet Lobby, our users, or the public.
• Business transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred as a business asset.
• With your consent: We may share your information for any other purpose with your explicit consent.

4. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with services. We retain verification materials for a minimum of seven (7) years as required by 18 U.S.C. § 2257 and applicable regulations. We may retain certain information for longer periods as required by law or for legitimate business purposes such as fraud prevention and legal defense.

5. Security

We implement reasonable technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Verification photographs are stored in encrypted cloud storage with access restricted to authorized personnel only. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Your Rights and Choices

6.1 Account Information

You may update or correct your account information at any time by logging into your account settings. You may request deletion of your account by contacting us at [email protected]. Note that we may retain certain information as required by law or for legitimate business purposes.

6.2 California Residents

California residents have certain rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion of personal information, and the right to opt out of the sale of personal information (we do not sell personal information). To exercise these rights, contact us at [email protected].

6.3 European Residents

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR) or equivalent laws, including the right to access, correct, delete, or restrict processing of your personal data, and the right to data portability. Our legal basis for processing your data is typically your consent or the performance of a contract. To exercise these rights, contact us at [email protected].

7. Children's Privacy

The Platform is strictly intended for users who are 18 years of age or older. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected personal information from a minor, we will take immediate steps to delete that information and terminate the associated account. If you believe we may have collected information from a minor, please contact us immediately at [email protected].

8. Third-Party Links

The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies before providing any personal information.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last updated" date at the top of this page and, where appropriate, by sending a notification to your registered email address. Your continued use of the Platform after any changes constitutes your acceptance of the updated policy.

10. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact our Privacy Team at [email protected].