Data protection declaration

A. Name, address and contact details of the controller

The controller responsible under data protection law for the processing of personal data in the context of the MySugardaddy portal (hereinafter referred to as "the portal") is:

SDC Ventures GmbH

Westfalendamm 237

44141 Dortmund

Germany

Phone: +49 231 9999 55 99

Email: support@mysugardaddy.eu

B. Contact details of the data protection officer

The data protection officer of SDC Ventures GmbH can be contacted as follows:

Fritz und Mark Legal Rechtsanwaltsgesellschaft mbH

Bernhard-Ernst-Str. 12

48155 Münster

Germany

Phone: +49 (0)251-149828-0

Email: datenschutz@fum-legal.de

C. Processing of personal data

The following terms, among others, are used in the following description:

Visitors: Persons (m/f) who access the portal without registering (no use of the portal's functions and services possible).

User: Persons (m/f) who have registered to use the portal and use the portal as part of a user relationship on the basis of the controller's terms of use.

I. Visiting the portal and contact

1. visiting the portal

1.1 Description of the data processing

When you visit the portal, the browser used on your device automatically sends information to the portal server. The following information is collected:

The IP address of the visitor

Date and time of access

Information about the browser type and version used

The visitor's operating system

The visitor's internet service provider

Websites from which the visitor's system accesses our website

This data is also stored â anonymized â in so-called log files of our system. This data is not stored together with other personal data of the visitor

Neither is this data passed on to third parties. In strict compliance with the relevant data protection regulations, only our carefully selected service providers involved in the hosting and maintenance of our systems may be recipients of the data. This takes place on the basis of order processing agreements, through which the service providers are contractually bound and we remain responsible for the processing of the data in this respect.

1.2 Purpose of the data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the visitor's computer. For this purpose, the visitor's IP address must be stored for the duration of the session.

The anonymized storage of data in log files is done to ensure the functionality of the website. The files are also used to optimize the website and to ensure the security of our information technology systems.

1.3 Legal basis for processing

The legal basis for the temporary storage of data is Art. 6 para. 1 lit. f) GDPR. The legitimate interest in data processing required for this consists of the aforementioned processing purposes.

1.4 Duration of processing / deletion of the data

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected or processed. In the case of the collection and storage of data for the provision of the website, this is the case when the respective session has ended

1.5 Right to object

In principle, in accordance with Art. 21 GDPR, you have the right to object to the processing of data in accordance with Section 1.1 at any time on grounds relating to your particular situation. We will then no longer process this data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the establishment, exercise or defense of legal claims.

To exercise a corresponding objection, the visitor can contact us in particular by email using the email address datenschutz@mysugardaddy.eu. In the event of a justified objection, the data will be deleted.

2. contact form and email contact

2.1 Description and scope of data processing

If you have any questions for customer support, you can contact us using the email address provided. In this case, the data transmitted will be used exclusively for processing the respective inquiry. The data will not be passed on to third parties in this context. In strict compliance with the relevant data protection regulations, our carefully selected service providers involved in the hosting and maintenance of our systems may be recipients of the data. This takes place on the basis of order processing agreements, through which the service providers are contractually bound and we remain responsible for the processing of the data in this respect.

2.2 Purpose of the data processing

The processing of personal data from the chat or contact form or your email request is solely for the purpose of processing the contact. If you contact us, this also constitutes the necessary legitimate interest in processing the data. The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

2.3 Legal basis for data processing

The legal basis for the processing of data transmitted in connection with an inquiry (by email or via the chat or contact form) is Article 6(1)(f) GDPR. If the e-mail contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b) GDPR.

2.4 Duration of the processing

The data will be deleted as soon as it is no longer required for the purpose for which it was collected. For the personal data from the chat or the input screen of the contact form and those sent by email, this is the case when the respective conversation or request with the visitor has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified. The data from the chat and the contact form will be deleted no later than one month after the request.

2.5 Right of objection

If the visitor contacts us by email, they can object to the storage of their personal data at any time in accordance with Art. 21 GDPR. In such a case, the conversation cannot be continued

To exercise a corresponding objection or revocation, the visitor can contact us in particular by e-mail using the e-mail address datenschutz@mysugardaddy.eu. The data stored in the course of contacting us will be deleted in the aforementioned cases.

II. registration, profiles and additional paid services

1. registration with MySugardaddy

1.1 Description and scope of processing

In order to be able to use the services and functionalities offered within the framework of the portal, registration as a user is required. For this purpose, we first require the following data:

E-mail address

Date of birth

Gender

Postal code, city, country

Username / pseudonym

Password (encrypted)

Confirmation of acceptance of the terms of use and privacy policy

Confirmation of full age

The following data (log file data) is also stored at the time the registration request is sent:

The IP address of the visitor

Date and time of access

Information about the browser type and version used

The visitor's operating system

The aforementioned data is required for the conclusion or performance of the contract. This data is stored by us and processed for the conclusion and performance of the contract of use for the use of the services or functionalities of the portal.

Age, city, country, gender and user name / pseudonym can only be viewed by registered users via the portal after registration, the other data cannot be viewed.

In strict compliance with the relevant data protection regulations, our carefully selected service providers involved in the hosting and maintenance of our systems may be the recipients of the data. This takes place on the basis of order processing agreements, through which the service providers are contractually bound and we remain responsible for the processing of the data in this respect.

1.2 Purpose of the processing

The purpose of processing the data collected during registration is to conclude and execute the user contract with users regarding the use of the portal and its services and functionalities. The log file data is also used to prevent misuse of the registration and to ensure the security of our information technology systems.

1.3 Legal basis for the processing

The legal basis for the processing of access data collected during registration is Art. 6 (1) (b) GDPR.

1.4 Duration of the processing

After the user contract for the use of the portal's services has been fully processed or the user's profile has been deleted, the data will be deleted or processing restricted to the extent that this is necessary for tax and commercial law retention obligations. The data will be deleted at the latest after expiry of the corresponding statutory retention periods, unless the user has expressly consented to further use of the data.

2. voluntary profile information of the user

2.1 Description and scope of processing

The user creates a user profile for the publicly visible presentation of their person on the portal. To create this profile, the user can enter the data shown on the corresponding input screen (e.g. height, figure, eye color, hair color, profession, contact preferences, etc.).

The aforementioned data is stored and processed for the purpose of performing the contract or for carrying out the functionalities offered within the framework of the portal, in particular for the user's own personal presentation. If the user voluntarily leaves this data, it can be viewed publicly via the portal.

In strict compliance with the relevant data protection regulations, our carefully selected service providers involved in the hosting and maintenance of our systems may be the recipients of the data. This takes place on the basis of order processing agreements, through which the service providers are contractually bound and we remain responsible for the processing of the data in this respect.

2.2 Purpose of the processing

The purpose of processing the data collected during registration is to execute the user contract with the user regarding the use of the portal and its services and functionalities. The log file data is also used to prevent misuse of the registration and to ensure the security of our information technology systems.

2.3 Legal basis for the processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR.

2.4 Duration of the processing

After the user contract for the use of the portal services has been fully processed or your user profile has been deleted, your data will be deleted or processing will be restricted to the extent necessary for tax and commercial law retention obligations. Your data will be deleted at the latest after expiry of the corresponding statutory retention periods, unless you have expressly consented to further use of your data.

3. Purchase of credits, VIP membership and Diamond membership

3.1 Description and scope of processing

Within the framework of the portal, the user has the option of purchasing credits (see description within the framework of the portal) and memberships (VIP and Diamond) against payment, which entitle him/her to use extended services in accordance with the descriptions within the framework of the portal. As part of the order process, we collect the data shown on the order form on the portal. Mandatory information is marked as such, as we require this data to conclude or process the contract and the user cannot complete the order without providing this data.

The payment data required for payment (e.g. name, address, account number, bank code or IBAN and BIC or credit card data, invoice amount, currency and customer number, depending on the selected payment method) are - depending on the payment method - transmitted by us to the respective payment service named in the payment process or the user is forwarded directly to the respective payment service to enter the data as part of the payment process. In this respect, we also refer to the data protection provisions of the relevant payment service.

In this context, depending on the payment method, payment data may be forwarded to the following payment services:

Instant bank transfer:

Sofort GmbH

Theresienhöhe 12

80339 Munich

Germany

Credit card:

Novalnet AG

Feringastrae 4

85774 Unterföhring

Germany

Sepa

Novalnet AG

Feringastrae 4

85774 Unterföhring

Germany

In addition, we use the name and address of the user for the purpose of identity and credit checks or to assess the risk of non-payment and transmit these to

Bürgel Wirtschaftsinformationen GmbH & Co. KG

P.O. Box 500 166

22701 Hamburg

Germany

To obtain information relevant to creditworthiness. In this way, we receive information to assess the risk of non-payment on the basis of a scoring. The scoring is based on a mathematically and statistically recognized and proven procedure, in which your aforementioned inventory data and, if applicable, data on your previous payment history are included in different weightings. Depending on this information, we will then offer you a payment method or different payment methods. For more information in this regard, please contact the aforementioned credit agency.

You have the right to express your opinion on the decision of the credit check and may also request that the decision be subject to a manual review. To do so, please use the contact details listed above under point A.

Furthermore, the data collected during the ordering process will not be passed on to third parties.

In strict compliance with the relevant data protection regulations, our carefully selected service providers involved in the hosting and maintenance of our systems may be the recipients of the data. This is done on the basis of order processing agreements, which contractually bind the service providers and we remain responsible for the processing of the data in this respect.

3.2 Purpose of the processing

The data processing described above is carried out for the purpose of concluding the contract and for the purpose of performing the contract and, if necessary, for credit checks.

3.3 Legal basis of the processing

The legal basis for the processing is Art. 6 para. 1 lit. b) GDPR, with regard to the use for credit checks Art. 22 para. 2 lit. a) GDPR.

3.4 Duration of the processing

After completion of the contract, your data will be restricted for further processing and deleted after expiry of the retention periods under tax and commercial law, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

III. notifications and private messages

1. notifications

1.1 Description and scope of processing

In the context of the purpose of the platform - to enable contact and exchange between users - and the associated performance of the contract, the user's email address is also processed to send the user messages or notifications in connection with the functionalities provided via the portal (e.g. notification of another user's request to be contacted, etc.).

In strict compliance with the relevant data protection regulations, our carefully selected service providers involved in the delivery of the notifications may also be recipients of the data. This is done on the basis of order processing agreements, which contractually bind the service providers and we remain responsible for the processing of the data in this respect.

1.2 Purpose of the processing

The data is processed for the purpose of sending notifications as part of the contractually provided functionalities of the platform.

1.3 Legal basis for the processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR.

1.4 Duration of the processing

After completion of the contract, your data will be deleted unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

2. private messages

2.1 Description and scope of processing

As an essential functionality of the portal, users have the option (in accordance with the provisions of the terms of use) to send private messages to each other via an internal messaging system on the portal and to contact each other in this way.

The messages are sent via a corresponding send form within the portal. In this case, the user only has to enter their message. The user names of the users serve as the sender and recipient ID. Apart from the user names and the message content, no other data of the users involved is included in the transmitted private message.

2.2 Purpose of the processing

The purpose of the processing is the sending of private messages via the portal, which represents an essential functionality of the portal in the context of the user relationship with the user.

2.3 Legal basis for the processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR.

2.4 Duration of the processing

After completion of the contract (membership), your data will be deleted unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

The data of the recipients of the notifications will only be deleted when the corresponding contractual relationship with them has been fully processed.

IV. Cookies, web analysis and social media

1. cookies

1.1 Description and scope of processing

The portal uses cookies. These are small text files that are stored on your end device assigned to the browser you are using and through which certain information flows to the location that sets the cookie.

We use such cookies to make your visit to our portal attractive, to enable the use of certain functions and to be able to show you suitable products.

Some of the cookies used on the portal are deleted again at the end of the respective session, i.e. after you close your browser (so-called session cookies). Other cookies, on the other hand, remain on your end device even after the end of the session and enable us to recognize your browser the next time you visit our portal (persistent cookies).

The duration of the storage of the respective cookies can be found in the overview in the cookie settings of your browser. You can also set your browser so that you are informed about the setting of cookies and can decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. In this respect, we refer to the respective cookie settings in the respective browsers.

However, we would like to point out that preventing the setting of cookies may limit the functionality of our portal.

1.2 Purpose of the data processing

On the one hand, the purpose of the processing is to simplify the use of websites for users. In addition, some functions of our portal cannot be offered without the use of cookies. For these, it is also necessary for the browser to be recognized even after a page change.

Our legitimate interest in the processing of data in accordance with Art. 6 (1) (f) GDPR also lies in the aforementioned purposes.

1.3 Legal basis for the processing

The legal basis for the processing of data using cookies is Art. 6 para. 1 lit. f) GDPR.

1.4 Duration of the processing

The cookies are stored on your end device and transmitted by it to the portal. Therefore, the respective user has full control over the use of cookies. By changing the cookie settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies already stored on your device can be deleted at any time. This can also be done automatically. However, if cookies are deactivated for the portal, it may no longer be possible to use all functions of the portal to their full extent.

2. Google Analytics

2.1 Description and scope of processing

The portal also uses Google Analytics for web analysis. This is an analytics service provided by Google LLC (www.google.de). Google Analytics uses methods that make it possible to analyze the use of our portal by the respective user. This enables us to optimize our offer and adapt it to the needs of the users.

The automatically collected information about the use of the portal by users is usually transmitted to a Google server in the USA and stored there. By activating IP anonymization on our portal, the IP address is shortened before transmission within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The anonymized IP address transmitted by your browser as part of Google Analytics is generally not merged with other Google data.

Google LLC is headquartered in the USA and is certified under the EU-US Privacy Shield. Based on this agreement between the USA and the European Commission, the latter has established an adequate level of data protection for companies certified under the Privacy Shield.

2.2 Purpose of the processing

The purpose of the processing is the analysis of user behavior to optimize the offer and to adapt our portal to the needs of the users. This is also the legitimate interest within the scope of Art. 6 para. 1 lit. f) GDPR.

2.3 Legal basis of the processing

The legal basis for the processing of data in the context of web analysis is Art. 6 para. 1 lit. f) GDPR.

2.4 Duration of the processing

After the purpose of the discontinuation and end of the use of Google Analytics by us, the data collected in this context will be deleted.

You can prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de

Alternatively, you can prevent Google Analytics from collecting data about you within this website by clicking on this link. By clicking on the link above, you download an opt-out cookie. Your browser must therefore allow the storage of cookies. If you delete your cookies regularly, you will need to click on the link again each time you visit this website.

D. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights against us, the controller (unless already set out above under D in connection with the respective processing of your data):

1. right to information

In accordance with Art. 15 GDPR, you can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing is taking place, you can request the following information from the controller:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data being processed;

(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4) the envisaged period for which the personal data concerning you will be stored, or, if specific information on this is not possible, the criteria used to determine that period;

(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

(6) the existence of the right to lodge a complaint with a supervisory authority;

(7) any available information as to the source of the data if the personal data are not collected from the data subject;

(8) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is being transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

2. right to rectification

In accordance with Art. 16 GDPR, you have a right to rectification and/or completion of your data vis-à-vis the controller if the processed personal data concerning you is incorrect or incomplete. The controller must make the rectification without undue delay.

3. right to restriction of processing

Under the following conditions, you may request the restriction of the processing of personal data concerning you in accordance with Art. 18 GDPR:

(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

(3) the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, or

(4) if you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override your grounds

.

Where the processing of personal data concerning you has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. right to erasure

Obligation to erasure

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(1) The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

(2) You withdraw your consent on which the processing was based according to Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground for the processing.

(3) You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.

(4) The personal data concerning you has been processed unlawfully.

(5) The deletion of your personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

(6) The personal data concerning you have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) GDPR, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data

.

Exceptions

In particular, the right to erasure shall not apply to the extent that processing is necessary

(1) to exercise the right to freedom of expression and information;

(2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(3) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h) and lit. i) GDPR and Art. 9 para. 3 GDPR;

(4) for the assertion, exercise or defense of legal claims.

5. right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged pursuant to Art. 19 GDPR to communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

You have the right vis-à-vis the controller to be informed about these recipients.

6. right to data portability

In accordance with Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

(1) the processing is based on consent pursuant to Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and

(2) the processing is carried out by automated means

.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. This may not adversely affect the freedoms and rights of other persons.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR

.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

E. Data security

To secure your data when you visit our website, we use the common SSL (Secure Socket Layer) method in conjunction with the highest level of encryption supported by your browser. As a rule, this is a 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can tell whether an individual page of our website is transmitted in encrypted form by the closed display of the lock symbol in the lower status bar of your browser.

F. Information on profile verification (including biometric data)

For security reasons and to provide you with the best possible user experience, we require our users to verify their accounts and may ask you for your phone number and, in some cases, a photo. We want to make sure you're not a robot! And we also want to prevent fake MSD accounts from being created that can be used for malicious activities and cybercrime - they threaten the MSD network and spoil everyone's fun. We may require this verification to prevent fraud. We will only share your selfie with our photo verification partner, Yoti. (Yoti USA Inc. for users from the USA and Yoti Limited for users who are not from the USA).

If you choose to verify your profile photo, we will scan every photo you submit. This uses facial analysis technology that allows us to check the submitted photo for authenticity and your age and ensure that you are who you say you are. Your verification photos will not be added to your profile. We store the scans so that we can verify you in the future and for documentation purposes until we no longer need them for these purposes.

Yoti does not receive any further information from us and has no possibility to link the selfie with other data. Yoti only processes the selfie to verify its authenticity and your age. Once the verification is complete, Yoti immediately deletes your selfie and no longer uses it. Yoti stores the estimated age only in the form of aggregated and anonymized statistics, i.e. not linked to you, for product performance and reporting purposes and not for any other purpose.