Privacy policy

Privacy Policy HotDiscreetShemales

HotDiscreetShemales takes your privacy very seriously, treats all your personal information with great care, and assures you that your personal data will only be used in accordance with this Privacy Policy. This Privacy Policy sets out how HotDiscreetShemales uses and protects any information that you provide HotDiscreetShemales when you use our website and our services. In short, we use your personal data to offer you our services, to get in touch with you, to inform you about our service and to be able to make you personal offers. If you have questions regarding the use of your personal data please contact us through compliance@festivusmedia.com.

Who is HotDiscreetShemales?

HotDiscreetShemales provides a service by means of a platform (“Platform”) where users can get in touch and communicate with each other through messages. The services of HotDiscreetShemales are provided by Festivus Media B.V. Festivus Media B.V. is located at Bezuidenhoutseweg 161 (2594 AG) ‘s-Gravenhage and is registered with the Chamber of Commerce under number 60194235. Festivus Media B.V. is responsible for the manner in which your personal data is being collected, used and stored.

The Data we Process

Account and messages
In order to make use of our Platform, you need to create an account. To create your account we ask you to provide us with your name, email address and password. This information is mandatory. You can also add extra information, such as your profile picture, telephone number, location, gender, age, date of birth, physical characteristics, relationship status and sexual orientation or flirt preferences. Your extra information is saved in your account and you can update or delete this information at all times. Furthermore, this extra information may qualify as special category of personal data which we only process based on your consent. You are at all times entitled to withdraw your consent by sending an email to compliance@festivusmedia.com. Please be advised that if your messages to users of the Platform contain (special) personal data, we process that data in order to provide you the service.

Payment details
In order to gain full access to the Platform, which among other things includes the option of sending and receiving messages, you need to buy credits. For this purchase we process your payment details which include your phone number. In order to process your payment, you will be transmitted to the website of your bank, credit card company or other payment provider. You will be transferred back to the Platform once you have completed your payment.

Contact form
You can contact us by using the contact form on the Platform. In this contact form we ask you to provide us with the following information: name, email address and message. We use this information to reply to your questions, request and complaints.

Newsletter
You can sign up for our newsletters. If you have signed up for the newsletter, we will use the email address you provided to send you our newsletter. If you no longer wish to receive newsletters, you can use the unsubscribe option included in each newsletter.

Personal offers
On the basis of the personal information collected by Festivus Media BV, a profile is created. Based on this profile, we try to tailor our offers to you as well as possible. These offers are sent to you by email.

For this we use:

  • The functionalities that you use;

  • Your surfing behaviour on the website;

  • The amount that you spent on credits;

  • Your flirt preferences;

  • Data collected by using cookies.

  • This use of your personal data is based on your consent. If you no longer wish your information to be used for this purpose, you can withdraw your consent by sending an email to compliance@festivusmedia.com.

    Statistical research
    Festivus Media BV wishes to deliver services of the highest quality. In order to accomplish this Festivus Media BV needs to perform statistical research. Based on the outcome of the research we can make adjustments to our services and/or the Platform. Festivus Media BV uses your personal data for this statistical research. The results of the research are always aggregated. This means that the data in the research results can no longer be traced back to you.

    Automatically generated data
    Festivus Media BV requires certain information in order for the Platform to work as optimal as possible (for example, to display content correctly and to keep the Platform secure). That is why we collect automatically generated data on your use of the Platform. This information consists of:

  • the device type (i.e. tablet or smartphone) you use;

  • the IP address (and geolocation) of your device;

  • operating system of your device;

  • browser software you use;

  • web pages you visit;

  • the internet service provider that you use.


  • Third party disclosure
    We will not provide your personal data to third parties without your consent, unless the following cases apply:

  • We provide your personal data to (sub)processors (inter alia the hosting party and entities that employ the people that reply to your messages) which may process personal data under the responsibility of Festivus Media B.V. Festivus Media B.V. assures that it has contractually guaranteed that these (sub)processors will not process data outside the scope of this Privacy Policy, and that technical and organizational measures are taken to safeguard your personal data against (inter alia) unintentional loss or destruction or damage of your personal data.

  • We may provide your personal data to any third parties if you have explicitly consented to the transfer for these parties to process your personal data, and/or insofar as this information cannot be traced back to you.

  • We may provide your personal data to third parties inhase we are obligated to do so under applicable law and/or regulations, as a result of a lawsuit and/or if we believe that this is necessary to protect our rights.
  • What we do with your information?

    We will process your personal data for the following purposes and on the basis of the following legal grounds:

    Purpose Legal basis
    Account & MessageTo provide the Platform and its functionalities to you and to bring you in contact with profiles that match your preferences.The processing is necessary for the performance of a contract to which you are party. In case special categories of personal data are being processed, the processing is based on your consent.
    Contact formTo answer any questions and / or to be able to contact you.The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, i.e. in order to provide its (customer) services to you.
    Newsletter To subscribe you to our mailing list and send you updates on our service.The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, i.e. in order to send you the newsletter to which you subscribed.
    Personal offerTo send you personal offers The processing is based on your consent.
    Statistical researchto generate statistical data and to (anonymously) use this data for research purposes.The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, i.e. in order to provide the website as user friendly as possible and to improve our services.
    Automatically generated informationTo secure, adjust and improve the Platform.The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, namely for information security.
    Third party disclosureTo provide information about you to third parties and/or to give access to third parties to information about you, providing,
    this is necessary for the execution of the services;
    you have given your consent; or
    this is necessary based on law and/or regulations, as a result of a lawsuit and/or if it is necessary to protect our rights.
    The processing is necessary for the performance of a contract to which you are party;
    you have given consent to the processing of your personal data for this purpose;
    the processing is necessary for compliance with a legal obligation to which Festivus Media BV is subject.

    Can this privacy statement be amended?

    This Privacy Policy may be amended from time to time. The amendments will be published on the Platform. Should any material change be executed, you will be informed of such change.

    Complaints or questions?

    In case you have any complaints or questions with regard to this Privacy Policy and the manner in which Festivus Media BV processes your personal data, you have the right to report this via compliance@festivusmedia.com. In case you and Festivus Media BV are not able to resolve your complaint(s) with regard to the aforementioned data processing, you are also have the right to file a complaint to the competent Data Protection Authority.

    Updated: August 2019