1. Who We Are
Operator: Velvet Ventures s.r.o.
Address: Rybná 716/24, 11000 Praha 1, Czech Republic
Email: contact@velvetventur.es
Website: velvetventur.es
If you have any questions about how we process your personal data, or wish to exercise your data‑protection rights, please contact us at the above address or email.
If we appoint a Data Protection Officer (DPO), his/her contact details will be provided here.
2. Which Data We Collect
When you use VelvetCircle.com — e.g. register an account, browse, chat, or use other services — we collect one or more of the following categories of personal data:
- Identity & account data: e.g. username, email address, password (hashed), optional profile information (date of birth or age or age range, gender, sexual orientation, profile picture, biography, interests, location or approximate location)
- Contact data: e.g. email address, phone number (if you voluntarily provide it)
- Usage data: e.g. IP address, device / browser information, login/logout timestamps, pages visited, interactions (e.g. messages, “likes”, profile visits), geolocation or approximate location (if you consent or use location‑based features)
- Communications data: messages you send via our platform, contact requests, support requests or other communication with us
- Payment and billing data (if applicable): e.g. billing address, payment method (if you subscribe or pay for a premium service), transaction history
- Cookies and tracking data: cookies and similar technologies to operate our website, remember preferences, and optionally (if you consent) for analytics or advertising
We collect this data directly from you (when you register, fill forms, use the site) and automatically (e.g. usage data, cookies).
3. Why We Collect & How We Use Your Data
We process your data for the following purposes, under one or more of the lawful bases under the GDPR (e.g. consent; performance of contract; legitimate interests).
| Purpose | What data is used | Legal basis / justification |
|---|---|---|
| Provide and maintain your account and the dating service (matching, messaging, profile, search, site functionality) | Identity data, profile info, usage data, communications | Performance of contract (you use our service) |
| Verification, age-check, safety & fraud prevention | Identity data, usage data, possibly payment/billing data | Legitimate interest / contract performance (to ensure safe use and compliance) |
| Customer support and communications (e.g. support requests, account issues) | Contact data, communications data | Performance of contract / legitimate interest |
| Service improvements, analytics, site‑usage optimization, security monitoring | Usage data, cookies, technical data | Legitimate interest (improving service; securing platform) |
| Marketing, newsletters, promotions (only if you explicitly consent) | Contact data, usage data, preferences | Your consent (you may opt in) |
| Payments and billing (if applicable) | Billing data, payment details, transaction history | Performance of contract |
4. Who We Share Your Data With
To provide our services, we may share your data with:
- Service providers and sub‑processors: hosting providers, database and storage providers, cloud infrastructure, payment processors (if applicable), analytics providers, email providers, customer‑support or messaging providers, security service providers.
- Third‑party partners (only if you consent), e.g. marketing partners, advertisers.
- Law enforcement or regulatory authorities, if required by law or in response to legal requests (e.g. in cases of abuse, fraud, or other legal issues).
We require that any third parties processing your data on our behalf commit to appropriate data‑protection and confidentiality obligations (e.g. via Data Processing Agreements).
5. International Transfers
If your personal data is transferred to a recipient located outside the European Economic Area (EEA), we will ensure this is done only under appropriate safeguards — for example using Standard Contractual Clauses, or to a country recognized as having adequate data‑protection laws.
We will inform you which countries are involved (or provide a mechanism for you to request this information).
6. How Long We Keep Your Data (Retention Periods)
We retain your personal data for as long as necessary to provide the services you have requested — i.e. for the duration of your account — and for a reasonable period afterwards (e.g. to comply with legal, tax or accounting obligations, to prevent abuse, or for security).
When data is no longer needed, or after you request deletion (see below), we will delete or anonymize it, unless there is a legitimate reason to retain it (e.g. to comply with a legal obligation, or to resolve disputes).
7. Your Rights under GDPR
As a data subject in the EU, you have the following rights:
- Right to access — you can request a copy of the personal data we hold about you.
- Right to rectification — you can ask us to correct inaccurate or incomplete data.
- Right to erasure (“right to be forgotten”) — you may request deletion of your personal data under certain conditions.
- Right to restrict processing — you can ask to limit processing (e.g. if you contest accuracy, or object to our use).
- Right to object — you may object to processing based on legitimate interests (or marketing) at any time.
- Right to data portability — you can request your personal data in a structured, commonly used, machine-readable format.
- Right to withdraw consent — if processing is based on your consent, you can withdraw it at any time (without affecting prior processing).
- Right to lodge a complaint — if you believe we violate applicable data‑protection laws, you have the right to file a complaint with a relevant supervisory authority.
To exercise these rights, please contact us via the contact details in Section 1.
8. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to operate and improve the service.
- Essential cookies: necessary for the functioning of the login, account management, security, and site navigation. Without these, the service may not be usable.
- Non-essential cookies (analytics, optional features, marketing): we will only set these if you have given explicit consent (e.g. via our cookie banner or preference centre).
You can manage or withdraw your consent anytime via our cookie settings.
You can also disable cookies directly in your browser — but this may affect the website’s functionality.
9. Security of Your Data
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, misuse or disclosure. This includes encryption (e.g. HTTPS), access controls, secure storage, and regular security reviews.
While no system is 100% secure, we commit to promptly investigating and responding to any suspected data breaches. If required by law, we will notify affected users and relevant authorities without undue delay.
10. Automated Decision‑Making / Profiling
If at any point we use automated decision‑making (including profiling) — e.g. for matching suggestions, recommendation features, or behavioural analysis — we will inform you in clear language about:
- the logic involved,
- the significance of that processing, and
- the likely consequences for you as a user.
If you have concerns or do not consent to such processing, you may contact us to object or request human review.
11. Minors and Age Requirement
You must be at least 18 years old (or the legal age in your EU country) to use VelvetCircle.com.
We do not knowingly collect or store personal data of minors. If you believe we have collected data of a person under 18, please contact us immediately so we can delete it.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time (e.g. to reflect changes in our practices or the law).
When we do, we will publish the updated policy on VelvetCircle.com and update the “last modified” date.
If changes are significant, we may also notify you directly (e.g. via email or on‑site notification).
13. Contact & Complaints
If you have any questions about this Privacy Policy, how we handle your personal data, or wish to exercise your rights, please contact us (see Section 1).
If you believe that we have failed to respect your data‑protection rights, you also have the right to lodge a complaint with a competent supervisory authority (e.g. in the Czech Republic or your country of residence).