Last Modified: August 17, 2023
Introduction
Aylo Freesites Ltd (hereinafter “we”, “us” or “our”) operates the websites https://cn.P88AV.com/ (hereinafter “P88AV”) and https://cn.P88AVpremium.com/ (hereinafter “P88AV Premium”) (collectively, hereinafter the “Websites”) and is the controller of the information collected or provided via the Websites and its affiliates.
Please read this privacy policy carefully, as your access to and use of our Websites signifies that you have read and understand all terms within this privacy policy. We respect your privacy and are committed to protecting your personal data.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
Scope
For the purposes of this privacy policy, “process”, “processed” or “processing” means any operation or set of operations performed on personal data or on sets of personal data (excluding disclosure thereof), whether or not by automated means, including one or several of the following operations: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction. Information on disclosure of personal data or of sets of personal data may be found in the “Disclosure of Your Personal Information” section below.
This privacy policy applies to information we collect:
The Data We Process About You
We may process different kinds of personal data about you, depending on whether you chose to create an account with us.
Persons who visit the Websites without logging in or registering (“Unregistered Users”):
Persons who choose to create an account on P88AV, including persons who sign up in the Model Partner Program (“Registered Users”) and persons who choose to upgrade their account on P88AV to a premium account such that they have access to the content found on P88AV Premium (“Premium users”):
Please use caution in providing user contributions. By providing user contributions you are making that content and information publicly available. User contributions can be read, collected, used, and disclosed by others, and we cannot control who accesses your user contributions or what other users may do with the information you voluntarily post or submit. User contributions are governed by the P88AV terms of use found at terms and the P88AV Premium terms of use found at https://cn.P88AVpremium.com/information/terms.
We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.
Our Websites are not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Websites are accessed (“minors”), and we prohibit minors from using the Websites. As indicated throughout this privacy policy, some users may be asked to provide some information to us and our service providers in order for us to make sure that they are over the age of majority required to have access to the Websites and to view their contents. We do not knowingly process personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at [email protected] to have that minor’s personal information deleted.
The Sources from Which We Process Personal Information
We process Personal Information in the following ways:
Purposes for Which We Process Your Personal Information
We process personal information for the purposes described below.
Our Legal Bases Under Canadian and European Union (EU) Privacy Law
We have the following legal bases under Canadian and EU privacy law for processing your personal data for the purposes described under Purposes for Which We Process Your Personal Information section:
Disclosure of Your Personal Information
We disclose personal information:
Cookies and Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we use automatic data collection technologies to collect website activity data.
We use cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.
We currently use the following types of cookies, which are set by the Websites’ domains, or by other domains we own or control:
Analytics, Functionality and Advertising / Targeting cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of our website. However, if you decline to accept these cookies, some functionality on our Websites may be disabled and can interrupt your access to certain parts of our Website.
Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the Websites, including, by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only for the purpose of providing Google Analytics services to us, and will not use this information for any other purposes. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.
Third-party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on P88AV are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party feature on P88AV or directed to such third-party website. Unless expressly stated otherwise, P88AV does not provide any personal information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access P88AV to provide targeted content.
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
Your Choices About How We Collect, Use and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us.
Your Rights Related to Your Personal Information
Generally, in some regions like Canada, European Economic Area (“EEA”), and the United Kingdom, you have certain rights regarding the personal information we process and that is related to you, including the right:
You may exercise your right to access and deletion using the buttons at the bottom of this page. Additionally, you may, at any time, send us an e-mail at [email protected] to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area or the UK, you have a right to lodge a complaint with your local data protection authority.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases in order to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address).
California Rights and Choices
The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your personal information:
To exercise the rights described above, please use the buttons at the bottom of this page or email us at [email protected] with the email subject line “CCPA Request.” In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request in order for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
We disclose certain categories of California residents’ personal information for our business purposes, as described in the section above titled Disclosure of Your Personal Information.
Resident’s Rights – Jurisdictions in the United States, Where Applicable
We do not sell, trade, or exchange the Registered Users’ personal information with anyone for money.
Biometric Information
We employ third-party service providers to help verify your identity and age and to check background records and the authenticity of identification documents you provide using facial recognition technology. The facial recognition technology creates a mathematical representation of your face and detects facial features from the live scan of your face, your selfie, and the government-issued ID you submit or previously submitted to us. This mathematical representation, which is considered biometric information/identifier/data under the laws of certain states and countries, is not shared by our service providers with us, and is deleted by our service providers 7 days after its creation. Information derived from this mathematical representation, which may be considered biometric information/identifier/data under the laws of certain states and countries, is shared by our service providers with us as further described below.
Your biometric information will be processed to:
We may disclose your biometric information, face scan, selfie, and government-issued ID (including any government-issued ID or selfie you previously submitted to us) with members of our corporate group, and with third-party service providers. These entities may be located in jurisdictions that do not offer the same level of data protection as your jurisdiction. We (and/or any of these entities) may perform facial recognition and process your biometric information from your face scan, selfie, and any government-issued ID, and processing your biometric information for the above purposes.
Biometric information shared by our service providers with us will be stored for as long as you have a P88AV Model Partner Program account. We will delete your biometric information within three (3) years of you deleting your P88AV Model account or withdrawing your consent, subject to any legal obligations we might have.
You will be asked to provide your consent to biometric processing. You may withdraw your consent to this processing at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any processing or disclosure that occurred prior to the withdrawal.
Please note that this section entitled “Biometric Information” applies to relevant users who wish to upload content onto our Websites (through P88AV’s Model Partner Program for example) but does not apply to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to our Websites in order to view the contents found thereon.
Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
We reserve the right to refuse online service through our Websites, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using the Websites you consent to the transfer of information that we process about you, including personal information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer personal information to countries outside of the European Economic Area (“EEA”) or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws. Where relevant, our transfers outside the EEA are made pursuant to standard contractual clauses approved for use by the European Union.
Retention of Personal Information
We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider a number of factors, including what personal data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.
Where we no longer need to process your personal information for the purposes set out in this Privacy Policy, we will delete your personal information from our systems.
Where permissible, we will also delete your personal information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.
Third-Party Links and Sites
If you click on a link to a third-party site, you will be taken to websites we do not control. This policy does not apply to the privacy practices of these websites. Read the privacy policy of other websites carefully. We are not responsible for these third-party practices.
Changes to Our Privacy Policy
We may modify or revise our privacy policy from time to time. If we change anything in our privacy policy, the date of change will be reflected in the “last modified date”. We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our privacy policy, which will be posted at this location, so you are aware of any changes.
Contact Information
If you have any questions about this privacy policy or our information-handling practices, please contact us at [email protected].
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address: [email protected].
Manage My Data
With respect to Data Protection Laws in users' jurisdictions, P88AV Registered Users may request for a copy of their personal data as well as request P88AV to delete their personal data.