Privacy & Cookies Policy
This Privacy & Cookies Policy (the "Policy") dated May 30, 2023, replaces all previous policies. Please take the time to review before you continue to use our products and services.
This Policy applies to any information you provide to us, including through this website, our mobile apps, communications by email and through social media, by telephone and in person. It also covers any information we receive from third parties.
By using our products and services, including browsing our websites, registering or logging in, you agree we may use your information as outlined in this Policy. If you do not wish to have your information used in line with this Policy, you must not use our products and services and not otherwise provide us with your information.
West Circle Ltd operates the software platform located on Pervert.chat (the "Platform").
Information we may collect and process about you
- Information you provide to us, including by way of example only, your username, email address, and date of birth
- Your IP address
- Information about accounts you've visited, products and services you've clicked on or shown an interest
- Information provided by other companies who have obtained your permission through their own privacy policies to share information about you
- Information about your interaction with the Platform including any advertisements
- Information we collect using cookies stored on your device about your use of the Platform and/or selected third-party websites.
- Information we collect or remember using technologies similar to cookies, such as device identifiers on your mobile device.
- Technical information from your device relating to the service you receive
- Information relating to the location of your device.
How we may use your information
By accessing the Platform, you agree that we may collect, hold, use or otherwise process your information (including personal information) for the purpose of providing you with those products and services you request or access, and developing our business. By providing us with your email address, you agree to receive emails from us or sent on our behalf providing you with messages regarding your account including, but not limited to, purchase confirmations, renewal confirmations and warnings, alerts you may have requested to receive including alerts regarding other user's streaming broadcasts or content submissions), and newsletters. Should you determine to provide an email address, you may change your email address at any time.
Fraud Prevention Services
We use third-party services in connection with preventing fraud and other damage to our system. As such we may provide such services with your IP and device data should your account be terminated for fraud or behaviour which is damaging to our Platform. This information will be retained indefinitely for the protection of our Platform and users.
How we may use your information in specific products or services
General account registration: You are not required to provide any information to use the Platform. You may choose to create an account with the Platform. In such an event, you will be required to provide a username, birthdate to verify you meet our minimum age requirements, and your gender. This information, along with any details you decide to include in your account profile, will be publicly displayed in connection with your username.
Contributor registration: If you decide to create a "Contributor" account (an account that can receive digital currency from other Platform users), you will need to provide a colour copy of your current government-issued photo identification. We store this information under UK law. Additionally, you will be asked to provide "pay to" information, such as a bank account or home address. You may also need to provide certain taxpayer information. As per the legal requirements, we comply with reporting all payments made to Independent Broadcasters to the appropriate tax authorities.
Message boards, blogs, and other public forums
The Platform offers message boards, blogs, and other user-generated content facilities, along with user profiles. Anything you share through these means is considered public information. Please exercise caution when deciding to disclose personal information.
When we provide services that use your device's location, we may allow certain users to block individuals in specific locations from accessing their content based on IP addresses.
Certain Information Use Out of Our Control
If you choose to stream or upload any content to our Platform, please note that we cannot control how other users may use that content. We also have limited control over how other users may use any personal information you share with them. Be cautious when discussing your location, name, account information, or other identifying details. For privacy reasons, we recommend using a unique username that is not directly tied to your social media accounts or real name.
How we may share your information
Your username will be associated with all your activities on the Platform, including messages sent, shared content, and streamed content. Your gender information will be used to categorize your account and the content you share, making it easier for site users to find. We use your IP addresses, device data, and other usage information to optimize the Platform. Your usage history may also be utilized by our internal algorithm to recommend other Platform users to you. We may share your information with third parties we contract with to provide specific services on our website, such as third-party hosting services and site optimization services. If you provide "pay to" information, it will only be shared with third parties (e.g., our bank) as necessary to process payments to you. Your government identification, if provided, will be shared as required by applicable law or upon your written request. However, we reserve the right to share any account information we deem appropriate in response to written requests from law enforcement or other third parties, if we suspect illegal activity, or if we determine it necessary to protect the rights or property of Pervert.chat, our users, or third parties.
Safeguards and security for your information
We have implemented measures to protect the security of your personal information from unauthorized access or use, including encryption technology.
If you request the deletion of your personal data, it will be deleted in accordance with our data retention policy and applicable laws and regulations. To prevent abuse of our system, we will retain device and IP data related to your account for a certain period to prevent you from creating a new account. If you have tokens in your account at the time of deletion, by requesting deletion, you agree to forfeit those tokens to us and acknowledge that you are not entitled to a transfer or refund of such tokens. To initiate the deletion of your personal data and the closure of your account, it is imperative that you directly contact us through the official email address [email protected]. We strictly require all requests to be made exclusively via this channel. Our dedicated team will promptly attend to your request and ensure the proper and timely execution of the necessary actions as per your instructions.
Biometric and AV Documents Policy
Biometric Data Collection and Storage Policy
This Biometric Data and AV Documents Collection and Storage Policy (the "Policy"), applies to your use of West Circle Ltd's ("we," "us," or "our") interactive chat platform available through Pervert.chat (the "Platform"). Please review this policy before submitting your AV Documents. In this context, "AV Documents" refers to all images you may submit to us, directly or through a third party, for the purpose of complying with our age verification requirements. These requirements currently include a clear color image of your unexpired government-issued photo identification containing a recent and recognizable photo of you, along with a live burst/series of images taken of your 'Selfie'. Your 'Selfie' will be displayed on your account's age verification page and used by the Pervert.chat compliance team to ensure compliance with the platform's terms related to your broadcasts and/or Affiliate Referral payouts.
By submitting your AV Documents, you agree that we may generate and use biometric data based on your AV Documents as outlined in this Policy. If you do not want your information used in accordance with this Policy, you must not submit AV Documents.
What is Biometric Data
Biometric data refers to any biological characteristics of a person or information based on such characteristics. It includes characteristics like "biometric identifiers" and "biometric information" as defined in the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq. "Biometric identifier" refers to a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. "Biometric information" refers to any information, regardless of how it is captured, converted, stored, or shared, based on an individual's biometric identifier used to identify the individual.
Biometric Data We May Collect and Process
When you submit AV Documents directly to us or through a secure third party, a three-dimensional scan of your facial geometry will be captured. You will be prompted to take a short burst/series of images of your face using the camera on your mobile device or an internet-connected webcam. We, either directly or through a secure third party, may also collect similar face geometry during your live video broadcasts on the Platform to compare it with the biometric data collected during AV Documents submission.
Why is Biometric Data Collected?
We collect and use your biometric data for age verification purposes to prevent underage and unauthorized use of the Pervert.chat platform. This information helps ensure that the individual providing AV Documents is the same person depicted in the documents and accessing the associated account(s).
How is Your Biometric Data Stored?
The photo of your face from your AV Documents (the "Selfie") will be cropped and stored separately from the original AV Documents. It will be made available to our team of reviewers through a secure, closed-ended system to confirm your identity within your account. Your AV Documents with your date of birth and real name will be stored separately in a secure system. Only members of our team involved in age verification and routine audits will review your AV Documents. Any biometric data generated from your AV Documents (the "Biometric Data") will also be securely stored separately from your Selfie. The Biometric Data will only be used to verify your identity and, when the technology is implemented, to automatically review your live and recorded content for confirmation of your presence.
How Long Is Your Biometric Data Stored?
Your Biometric Data will be retained for the same period as your AV Documents, as required by 18 USC § 2257 and its regulations (the "Regulations"). As of the date of this Policy, the Regulations stipulate that age verification documentation must be retained for a period of seven (7) years from the last time content was available through your account(s).
No Obligation to Accept AV Documents
Despite anything to the contrary in this Policy, we reserve the right to specify the government-issued identification that may be accepted, based on your location and our sole determination of the reliability of such documentation. For example, handwritten and/or paper documents are not accepted. Additionally, as detailed throughout the Platform, particularly during the age verification process, acceptable government-issued identification must contain a recent and recognizable photo of you. Photos of you as a young minor or photos taken several years ago, regardless of your current age or age at the time the image was taken, may be rejected under this requirement. Furthermore, recent images that do not reflect alterations (such as surgeries, piercings, tattoos, or other modifications, whether temporary or permanent) in your face may also be rejected.
What are cookies and how do they work?
Cookies are small files that are downloaded to your computer or mobile device when you visit a website. These cookies are then sent back to the website each time you revisit it, allowing the website to recognize and tailor your experience accordingly.
Do we use other technologies similar to cookies?
In addition to cookies, our website, apps, and emails may contain small invisible images referred to as 'web beacons' or 'tracking pixels.' These function similarly to cookies, helping us understand when specific parts of a webpage are viewed. Our apps may also utilize device identifiers, which are unique numbers on your device that enable us to remember your device.
Cookies enhance your browsing experience by enabling various useful features on websites. There are different types of cookies that serve distinct purposes:
i. Necessary cookies: These cookies are essential for you to navigate the website and use its features. Without these cookies, certain requested services cannot be provided. They may gather information about you for the purpose of remembering your browsing history or allowing you to stay logged in during your visit.
ii. Functionality cookies: These cookies remember the choices you make on the website, such as your preferred language or region. They enhance your experience by offering improved features like content recommendations and limiting the frequency of specific advertisements.
iii. Performance cookies: These cookies help us understand how users interact with our products and services. They track popular pages to assist other users in finding relevant content.
Contacting us and accessing your personal information
If you wish to review or obtain a copy of the personal information we hold about you, or if you have any queries or comments about this Privacy & Cookies Policy, please contact us using the following details:
Please note that we reserve the right to charge an administration fee, within the limits allowed by law, for fulfilling requests to access personal information.
Changes to this Privacy & Cookies Policy
We reserve the right to make changes to our Privacy & Cookies Policy. Any updates to this policy will be posted here and will become effective as of the revised effective date. By continuing to use our website or platform, you signify your acceptance of these changes.
For privacy and security reasons, we will require certain information to verify your identity as the account holder before fulfilling your request. If we cannot verify the provided information, such as your email address or other relevant details associated with your account, we may be unable to complete your request. To ensure your privacy, responsive information will only be sent to the email address associated with the subject account. Please note that the term "assigned to an account" refers to the email address used to receive account security notifications, such as account recovery instructions.