Operator: Synden s.r.o.
Rybná 716/24, 110 00 Praha 1, Czech Republic
IČO: 23005408
Commercial Register: Městský soud v Praze, oddíl C, vložka 419828
Email: contact@synden.com
1. SCOPE AND CONTRACTING PARTY
These Terms & Conditions govern the use of the platform VelvetCircle.com, operated
exclusively by Synden s.r.o. (“we”, “us”, “the platform”).
By registering and using VelvetCircle.com, you (“user”, “you”) enter into a binding
contract with Synden s.r.o.
These Terms apply to both free and paid use of the platform.
2. ELIGIBILITY
Use of VelvetCircle.com is restricted to natural persons who:
(a) are at least 18 years of age; and
(b) are legally capable of entering into binding contracts in their jurisdiction.
By registering, you confirm that you meet both conditions. We reserve the right to
verify age at any time and to terminate accounts where eligibility cannot be confirmed.
3. REGISTRATION AND ACCOUNT
Registration requires the provision of accurate, complete, and current information.
You are responsible for keeping your account information up to date.
You must keep your login credentials confidential. You are responsible for all
activity carried out under your account.
You may create only one account per person. Multiple accounts may be terminated
without notice.
4. DESCRIPTION OF SERVICES
VelvetCircle.com provides an online platform for adults to create profiles, discover
other users, and establish contact. The platform offers both free features and paid
premium memberships.
The specific features included in free and paid tiers, current pricing, and billing
intervals are set out on the pricing page at velvetcircle.com/pricing.
We do not guarantee matches, contacts, or any specific outcome from use of the
platform.
5. PAID MEMBERSHIPS AND BILLING
Paid memberships are subject to the pricing and billing terms displayed at the time
of purchase. Prices include applicable taxes where required by law.
Cancellation and withdrawal rights are governed by our Cancellation Policy, which
forms part of these Terms.
6. USER CONTENT
You retain ownership of all content you upload to VelvetCircle.com (“user content”).
By uploading content, you grant Synden s.r.o. a non-exclusive, limited licence to
store, display, and transmit that content solely for the purpose of operating the
platform and providing the service to you. This licence ends when you delete the
content or close your account, subject to any applicable retention obligations.
You are solely responsible for your user content. You warrant that your content:
(a) does not infringe third-party intellectual property rights;
(b) does not depict or involve any person who has not given their consent;
(c) does not contain content that is illegal under applicable law; and
(d) does not depict minors in any context.
We reserve the right to remove content that violates these conditions.
7. PROHIBITED CONDUCT
The following are prohibited on VelvetCircle.com:
(a) Uploading, sharing, or distributing content that is illegal under applicable
law, including content depicting minors, non-consensual content, or content
inciting violence or hatred.
(b) Harassment, threats, or abuse of other users.
(c) Impersonating another person or entity.
(d) Creating fake profiles or providing false information.
(e) Using the platform for commercial solicitation, spam, or advertising without
our prior written consent.
(f) Attempting to circumvent technical security measures or access systems you
are not authorised to access.
(g) Automated access to the platform (scraping, bots, crawlers) without prior
written consent.
Violations may result in immediate account suspension or termination.
8. PROHIBITION OF HUMAN TRAFFICKING, SEX TRAFFICKING, SEXUAL EXPLOITATION, AND CHILD ABUSE
8.1 Zero-Tolerance Policy
VelvetCircle.com maintains an absolute zero-tolerance policy toward human trafficking, sex trafficking, sexual exploitation, and child abuse in any form. This clause constitutes a binding, non-waivable condition of use. No user may invoke any other provision of these Terms to limit or excuse conduct prohibited under this clause.
8.2 Absolute Prohibitions
The following conduct is strictly and unconditionally prohibited on this platform:
(a) Human trafficking: recruiting, transporting, transferring, harbouring, or receiving any person by means of threat, force, coercion, abduction, fraud, deception, or abuse of power for the purpose of exploitation in any form, including forced labour and sexual exploitation.
(b) Sex trafficking: causing, facilitating, inducing, financing, or profiting from the commercial sexual exploitation of any person, including through escort arrangements, prostitution, or any other form of sexual commerce, regardless of whether the individual appears to consent.
(c) Sexual exploitation: engaging in, soliciting, offering, advertising, or facilitating any form of sexual exploitation of any person, including using this platform as a medium for such activity, whether directly or indirectly.
(d) Child sexual abuse and exploitation (CSAE): creating, distributing, soliciting, possessing, or sharing child sexual abuse material (CSAM) in any form; grooming any person under the age of 18 for sexual contact; or using this platform in any way to contact, recruit, manipulate, or exploit any person under the age of 18 for any sexual purpose whatsoever.
8.3 Mandatory Reporting
We are legally required to report any known or suspected instances of child sexual abuse material (CSAM) to the relevant national authority and, where applicable, to the National Center for Missing & Exploited Children (NCMEC), and to cooperate fully with all law enforcement agencies in any related investigation. Users who encounter content or conduct on this platform that they reasonably believe constitutes human trafficking, sex trafficking, sexual exploitation, or child abuse are required to report it immediately to:
Email: contact@synden.com
Subject: URGENT – Trafficking/Exploitation Report
Users should also contact relevant national law enforcement or emergency services without delay. Failure to report known violations of this clause where legally required to do so may itself constitute a criminal offence under applicable law.
8.4 Consequences of Violation
Any user found to be in violation of this clause will be subject to:
(a) Immediate and permanent account termination without notice or refund;
(b) Preservation and disclosure of all relevant account data, communications, metadata, and content to competent law enforcement authorities;
(c) Civil liability for damages suffered by any victim or third party arising from the user’s conduct on this platform; and
(d) Criminal referral to the competent authorities in the user’s jurisdiction and/or the jurisdiction of any victim. Synden s.r.o. expressly reserves the right to pursue all legal remedies available under applicable law, including injunctive relief, financial damages, and the recovery of legal costs.
8.5 Regulatory Compliance
This clause is enacted in compliance with, and incorporates by reference, the obligations imposed by the following applicable legal instruments:
(a) EU Directive 2011/93/EU on combating the sexual abuse and sexual exploitation of children and child pornography;
(b) EU Directive 2011/36/EU on preventing and combating trafficking in human beings and protecting its victims;
(c) EU Digital Services Act (Regulation 2022/2065), including obligations relating to illegal content detection, reporting, and removal;
(d) Czech Act No. 40/2009 Coll. (Criminal Code), in particular Sections 168 (trafficking in human beings), 187 (abuse of a child), and 192–193 (child pornography and sexual coercion); and
(e) Any other applicable national or international law prohibiting trafficking in persons, sexual exploitation, or child abuse. Nothing in these Terms limits or waives any obligation imposed by mandatory law. Compliance with this clause is a non-negotiable condition of accessing and using this platform.
9. CONTENT MODERATION & SAFETY POLICY
9.1 Overview
Synden s.r.o. is committed to maintaining a safe, respectful, and lawful environment
on VelvetCircle.com. This section describes how we moderate content, protect users,
and handle abuse reports. It constitutes publicly accessible documentation in
accordance with our obligations under the EU Digital Services Act (Regulation
2022/2065, DSA).
9.2 Content Standards
All content uploaded to or shared via VelvetCircle.com must comply with these Terms,
our community guidelines, and applicable law. We do not permit content that is:
(a) illegal under applicable national or EU law;
(b) sexually explicit involving minors or non-consenting persons;
(c) threatening, harassing, abusive, or defamatory;
(d) inciting hatred, violence, or discrimination on any protected ground;
(e) designed to deceive or defraud other users; or
(f) otherwise harmful to the safety or wellbeing of users or third parties.
9.3 Moderation Approach
We employ a combination of proactive and reactive content moderation measures,
including:
(a) Automated detection tools to identify potentially illegal or policy-violating
content at the point of upload;
(b) Human review of flagged content, abuse reports, and escalated cases;
(c) Ongoing monitoring of platform activity for systematic violations or
coordinated harmful conduct.
Moderation decisions are made in accordance with our internal guidelines and
applicable law. Content found to be in violation of these Terms may be removed,
restricted, or referred to law enforcement without prior notice to the user.
9.4 Reporting Abuse
Any user who encounters content or conduct on VelvetCircle.com that they believe
violates these Terms or applicable law is encouraged to report it immediately using
the following channels:
Email: contact@synden.com
Subject: Abuse Report – [brief description]
Reports should include: a description of the content or conduct, the date and
location (e.g. profile URL or message reference) where it was encountered, and, if
applicable, a screenshot or other supporting evidence.
We will acknowledge receipt of all abuse reports within 5 business days and take
appropriate action without undue delay. For reports involving potentially illegal
content, we will prioritise review and, where required, report to competent
authorities.
9.5 User Protection Measures
We implement the following measures to protect users from harm:
(a) Technical safeguards including secure account authentication and encryption
of sensitive data in transit and at rest;
(b) Options for users to block, mute, or restrict contact with other users;
(c) Account verification measures to reduce the prevalence of fake or impersonation
profiles;
(d) Proactive removal of accounts engaged in harassment, exploitation, or other
harmful conduct; and
(e) Cooperation with law enforcement authorities in cases involving threats to
user safety or criminal conduct.
9.6 Consequences of Violations
Users found to have uploaded or distributed content in violation of this policy may
be subject to:
(a) Content removal without notice;
(b) Temporary suspension or permanent termination of their account;
(c) Reporting to competent law enforcement authorities; and
(d) Civil or criminal liability where applicable under law.
9.7 Appeals
If you believe that content you uploaded was removed, or that your account was
suspended or terminated, in error, you may submit a request for review in accordance
with Section 16.4 of these Terms (Redress for Content Moderation Decisions).
10. NOTICE AND ACTION — ILLEGAL CONTENT
If you encounter content on VelvetCircle.com that you believe to be illegal, you
may submit a notice to:
Email: contact@synden.com
Subject: Illegal Content Notice
Your notice should identify the content and explain why you believe it to be illegal.
We will assess notices and take action where warranted without undue delay.
This mechanism is provided in accordance with the Digital Services Act
(EU Regulation 2022/2065, DSA).
11. ALGORITHMIC SYSTEMS
VelvetCircle.com uses automated systems to suggest potential matches to users based
on profile information provided. The principal parameters used are: location, age
range, and stated preferences.
You have the right to object to profile-based processing where it significantly
affects you. Please refer to our Privacy Policy for details on your rights.
12. MODIFICATIONS TO THE PLATFORM AND TERMS
We may update these Terms to reflect changes in applicable law, platform features,
or our business. Where changes are material, we will notify you by email at least
14 days before the new terms take effect.
Your continued use of the platform after the effective date of updated Terms
constitutes acceptance of those Terms. If you do not accept the updated Terms,
you may terminate your account before the effective date.
We may modify, suspend, or discontinue features of the platform. Where this
materially affects a paid subscription, we will offer you the option to cancel
with a pro-rata refund for the affected period.
13. TERMINATION
You may terminate your account at any time via account settings or by contacting us
at contact@synden.com.
We may suspend or terminate your account if you materially breach these Terms,
after giving you reasonable notice where legally required. In cases involving
illegal content or serious harm, suspension may be immediate.
Upon termination, your access to the platform and any associated data will be
handled in accordance with our Privacy Policy.
14. LIABILITY
We are liable without limitation for damages caused by intent or gross negligence,
and for damages arising from injury to life, body, or health.
For damages caused by ordinary negligence, our liability is limited to foreseeable,
contract-typical damages.
Mandatory liability under applicable law — including liability for defective digital
services under EU Directive 2019/770 — is not affected by the above.
We are not liable for user content or for the conduct of users towards each other.
We do not guarantee uninterrupted availability of the platform.
15. GOVERNING LAW AND JURISDICTION
These Terms are governed by the law of the Czech Republic, without prejudice to
any mandatory consumer protections applicable in the user’s country of residence
under EU law.
For disputes with consumers residing in the EU, the mandatory consumer protection
laws of the consumer’s country of residence apply in addition to Czech law where
they provide greater protection.
Disputes may be brought before the courts of the Czech Republic or, at the
consumer’s option, before the competent courts of the consumer’s country of
residence within the EU.
16. CONSUMER DISPUTE RESOLUTION
16.1 Commitment to Fair Resolution
Synden s.r.o. is committed to resolving complaints promptly, fairly, and
transparently. This section sets out the full complaints and dispute resolution
process available to users, in compliance with the EU Digital Services Act
(Regulation 2022/2065, DSA) and applicable consumer protection law.
16.2 Internal Complaints Process
If you have a complaint relating to:
(a) a decision we have made regarding your content or account (e.g. content
removal, account suspension or termination);
(b) our alleged failure to comply with applicable law;
(c) a billing, subscription, or service issue; or
(d) any other matter arising from your use of VelvetCircle.com,
you may submit a complaint to us free of charge using the following contact details:
Email: contact@synden.com
Subject: Complaint – [brief description]
Post: Synden s.r.o., Rybná 716/24, 110 00 Praha 1, Czech Republic
Your complaint should include: your registered email address, a clear description
of the issue, the date(s) on which the issue occurred, and any supporting
information or evidence.
16.3 Acknowledgement and Response Timeframes
We will handle all complaints as follows:
(a) Acknowledgement: We will acknowledge receipt of your complaint within 5
business days of receiving it.
(b) Initial response: We will provide an initial substantive response within
14 calendar days of receipt, either resolving the complaint or explaining
why further time is required.
(c) Final response: Where a complaint requires further investigation, we will
provide a final written response within 28 calendar days of receipt. If we
are unable to resolve the matter within this period, we will notify you in
writing with reasons and an estimated timeframe.
(d) Content moderation decisions (DSA Art. 20): Complaints relating to content
removal, account restriction, or suspension will be handled without undue
delay, with priority given to complaints concerning potentially illegal content
or serious harm.
16.4 Redress for Content Moderation Decisions
If we have removed your content, restricted your account, or taken any other
moderation action, you have the right to request an internal review of that
decision. Your request should:
(a) be submitted within 6 months of the date of the decision;
(b) clearly identify the content or account affected;
(c) explain why you believe the decision was incorrect; and
(d) include any supporting information.
We will review the decision and provide a reasoned written response. Where we
determine that the original decision was incorrect, we will reverse or adjust it
without undue delay.
16.5 Out-of-Court Dispute Resolution (DSA Art. 21)
If your complaint is not resolved to your satisfaction through our internal process,
you have the right to refer your dispute to a certified out-of-court dispute
settlement body under Article 21 of the DSA.
A list of certified dispute settlement bodies will be published by the relevant
Digital Services Coordinator. We will cooperate in good faith with any such
proceedings, though we are not bound in advance to accept the outcome.
16.6 External Consumer Dispute Resolution
You may also refer unresolved complaints to the following bodies:
Czech Trade Inspection Authority (ČOI)
Website: www.coi.cz
Competent for consumer disputes involving traders established in the Czech Republic.
EU Online Dispute Resolution (ODR) Platform
Website: https://ec.europa.eu/consumers/odr
Email for ODR purposes: contact@synden.com
Available to consumers residing in the EU for disputes relating to online
contracts.
We are not obliged to participate in alternative dispute resolution proceedings
before the ČOI or the ODR platform, nor are we willing to do so, unless required
by applicable law. However, we commit to cooperating with any competent regulatory
authority in the exercise of its supervisory functions.
16.7 Judicial Redress
Nothing in this section limits your right to bring a claim before the competent
courts. You may bring proceedings either before the courts of the Czech Republic
or, if you are a consumer residing in the EU, before the courts of your country
of residence, in accordance with Section 15 of these Terms.
16.8 DSA Transparency Reporting
In accordance with our obligations under the DSA, Synden s.r.o. publishes periodic
transparency reports on content moderation activities, complaints received, and
actions taken. These reports are available at velvetcircle.com/transparency or
upon written request to contact@synden.com.
17. SEVERABILITY
If any provision of these Terms is found to be invalid or unenforceable, the
remaining provisions remain in full force. The invalid provision shall be replaced
by the closest valid provision that reflects the original intent.
18. CONTACT
Synden s.r.o.
Rybná 716/24
110 00 Praha 1
Czech Republic
Email: contact@synden.com