IT IS IMPORTANT THAT YOU READ THIS PRIVACY POLICY.

Introduction

(further referred to as "Publisher", "our", "we," or "us.") operates this CruelGirlfriend website (further referred to as "Website") and is the controller of the information collected or provided through this Website.

By your access to and use of this Website signifies that you have read, understood and agree to all terms, conditions and provisions within this privacy policy. If you do not agree with any part of this privacy policy or our terms and conditions you must immediately cease access to the website immediately.

If you have any questions about our privacy practices, please use the contact form on this website to get in touch with us. We collect, process and retain personal data to the extent it is necessary to provide users with our service. This privacy policy applies to information we collect:

- on this Website,
- in e-mail, text and other communications between you and this Website,
- when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this privacy policy.

It does not apply to information collected by:

- us offline or through any other means, including on any other website operated by us or any third party (including but not limited to our affiliates, subsidiaries and social media platforms); or
- any third party (including but not limited to our affiliates, subsidiaries and social media platforms), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified by ("Personal Data"). It does not include data that has been anonymised or pseudonymised.

When purchasing a subscription (further referred to "Product") from the join now area of the Website, you are asked to provide your name, address, e-mail address, username and password, payment information including card number and and expiration date.

When users access content and pages within the website, the server on which the website is hosted automatically collects some information about the users, including their IP addresses and, where relevant, their username.

If you submit correspondence to us, whether solicited or unsolicited, such as emails, messages through the contact area of our website or letters, we may collect and store such information into a file specific to you.

We may also maintain records or notes of any communications we have with you regarding your account.

We may also collect aggregated insight data that does not identify you. For example, we may collect aggregated insight data to identify the overall usage of specific areas of our website.

How We Collect Personal Data

We collect data from and about you in different ways - these include:

- Direct interactions with us including the submission of forms on our Website, signing up to a subscription product, posting or uploading content, taking part in surveys, when reporting a problem with our Website, or requesting customer services or support.
- Cookies and other automated tracking tools (Please see Data Obtained With Automatic Data Collection Tools below)
- social media, third parties or publicly available sources. Personal information may be collected about you from various third parties, for example, other websites owned by the Producer or our social media accounts as well as other third parties and public sources.

User Submissions

There may be areas of the Website that allow you to post or submit personal information about yourself and/or others. In addition there may be areas of the website that allow you to communicate with others, make comments, submit reviews or upload content (including but not limited to; images, videos, and audio files). Such interactions are subject to the Website Terms and Conditions.

It is important that you understand that any Personal Data you submit while communicating with others, making comments, submitting reviews or uploading content, will be publicly available and may be read, collected, used, and disclosed by other website users or by us or other third parties without restriction.

In addition, your submissions of publicly available Personal Data may appear on other websites or through search functions. To be clear, if you post your email address, for example, you may receive unsolicited messages.

We are unable to control who is able to view any Personal Data you choose to make visible through communicating with others, making comments, submitting reviews or uploading content and have no control over what other users may do with the information you voluntarily post, so we strongly encourage you to exercise caution with respect to your Personal Data. Once Personal Data has been made public it may not be possible to edit or remove it.

Data Obtained With Automatic Data Collection Tools

We use automatic data collection tools to collect certain information including what device you are using to access our website and its operating system, the browser you are using, how you interact with the website, your IP address, how you reached our website, what pages and content you have accessed, what search words or phrases you have used, and cookie information. The tools we use for automatic data collection could include:

- Cookies (small text files stored in your web browser or downloaded to your device when you visit a website) This Website may use the following types of cookies:

(a) Cookies that are essential for the operation of our Website. (e.g. to determine if a user is permitted to access specific content).
(b) Cookies for analytical purposes which are used to help us improve the Website (e.g. counting the number of active users to ensure we have appropriate infrastructure in place to manage the load)
(c) Cookies to improve functionality cookies which help us create a more personal experience for our users (e.g. remembering previous choices you have made)
(d) User Targeted cookies which record what content a user has accessed. These are used to make the Website more relevant to the users' interests.

Your browser can be set to reject all or some automated cookies but please be aware that if you disable or set your browser to reject automated cookies, some parts of the Website may become inaccessible or will not function properly.

Unless you have set your browser to reject automated cookies, cookies will continue to be delivered to you when your browser accesses our Website.

- Google Analytics. this tool collects and analyses information, including but not limited to your IP address, the device you use to access the Website and its operating system, how you reached our Website, your Website browsing behaviour and usage information, metrics and statistics, and other similar information through the use of cookies. The data collected by Google Analytics may be transmitted to and stored by Google on its servers in the. Google will use this information to analyse your use of the Website, report on your Website activity and manage advertising content.

You can opt out of the Google Analytics by downloading and installing the browser plug-in available at Google Analytics opt-out page.

Use of Third-party Cookies and Other Tracking Tools

Some content on the Website may be controlled by third parties, including the payment processing provider. These third parties may use cookies or other tracking tools to collect data when you access our Website. Unless specifically stated otherwise, our Website does not provide any Personal Data to these third parties, however the information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time, across other websites and other online services.

We have no control over third party tracking tools or how they may be used and we would encourage you to familiarise yourself with the individual privacy policy of each third party you may access.

How We Use Your Personal Data

Your personal data will only be used in the event the applicable local law allows us to so. Usually, we will use your personal data;

(a) to provide the services, customer management and functionality and security as is necessary to perform the services provided to you under our term and conditions and any other contract that you have with us.
(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(c) Where we need to comply with a legal or regulatory obligation.

In general, we do not rely upon consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purposes for Which We Use Your Personal Data

The Personal Data that we collect about you or that you provide to us is used for the following purposes;

(a) to provide customer support and notices to the registered user about their account or subscription, including expiration and renewal information, assisting with lost or forgotten login credentials, and notices about changes to our Website or the Products available on it;
(b) to communicate with you about updates and content that may be of interest to you either from us, our other websites owned by us.
(c) to better understand whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor other metrics such as total number of visitors, volume of data accessed, pages viewed;
(d) to identify and resolve issues with the Website, and to detect, prevent, and manage incidents of actual, suspected or potential fraud, illegal activities, or intellectual property infringement;
(e) to enforce the Website terms and conditions and to comply with our legal obligations;
(f) in any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this privacy policy.

Disclosure of Your Personal Data

We will NEVER disclose your Personal Data except in the limited circumstances described here.

- To specific authorised service providers that perform certain services on our behalf. These services may include, processing credit and debit card payments, fraud detection, and customer services. These service providers may have access to limited Personal Data in order to perform their functions but are not permitted to share or use such data for any other purposes.
- To a buyer or other successor in the event of a change of ownership of the Producer or the Website. In this event, we will ensure all reasonable efforts are made to ensure that the entity to which ownership is transferred has a privacy policy that is consistent with our own.

We reserve the right to access, store and share your Personal Data with regulators, law enforcement or others where we reasonably believe such disclosure is needed to;

(a) satisfy any applicable law, regulation, legal process, or governmental request,
(b) enforce applicable terms of use, including investigation of potential violations thereof,
(c) detect, prevent, or investigate illegal or suspected illegal activities, security or technical issues,
(d) protect against harm to the rights, property or safety of our company, the website, our Website's users, our employees, or others; or
(e) to maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may also, without restriction, share aggregated information (that does not identify any individual) with third parties for the purpose of conducting unspecific business analysis. This information does not contain any Personal Data.

Financial Information

Financial information (including Personal Data) that you have provided to us will only be shared with our third-party payment processors in order to facilitate the purchase of a subscription.

All credit and debit card transactions and such are processed with industry standard encryption through our third-party processor who only use your financial information and Personal Information for that purpose.

All financial data and related Personal Data will never be shared by us with third parties except with your prior authorisation or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions and policies of a third party or to assist any law enforcement authority or court order or subpoena requesting us to or directing us to disclose or help confirm your identity. All such information provided to a third party is subject to their terms and conditions.

Retention of Personal Data

We will only retain your Personal Data for as long as absolutely necessary to fulfil the purposes it was collected for, including (but not limited to) for the purposes of satisfying any legal, accounting, or reporting requirements.

Whilst deciding upon an appropriate retention period for personal data, we take into account the volume, nature, and sensitivity of the personal data, what potential risk of harm exists from its unauthorised use or disclosure, the purposes for which we collect your personal data and whether the same results could be achieved by other means, and any applicable legal requirements.

We will delete your Personal Data from our systems in the event we no longer need to process your Personal Data for the purposes set out in this Privacy Policy.

Where permissible to so, we will agree to delete your Personal Data upon your request.

How We Safeguard Your Personal Data

We take all reasonable physical, electronic and procedural security measures to protect your Personal Data from unauthorised access. For example, only authorised employees are permitted to access the Personal Data we collect, solely for permitted business functions.

Whist every effort is made to safeguard your Personal Data, please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

You are solely responsible for the security and confidentiality of your unique username and password login credentials and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.

Your Options In How We Collect, Use and Disclose Your Personal Data

You have some options with regard to the Personal Data you provide to us.

- You can refuse to provide us with certain Personal Data, but this may impact your ability to use certain features of our Website because this information may be essential in order for you to purchase a subscription, or to obtain customer support for example.
- Your browser can be set to reject all or some automated cookies, or to notify you when cookies are being sent. Please be aware that if you disable or set your browser to reject automated cookies, some parts of the Website may become inaccessible or will not function properly.
- You can opt out of the Google Analytics cookie by visiting the Google advertising opt-out page or by downloading and installing the browser plug-in available at Google Analytics opt-out page.
- when you purchase a subscription to our Website, you may be given the option to decide whether you would like to receive marketing emails, newsletters (or both) from us. if you no longer wish to receive marketing emails or newsletters from us, you may unsubscribe using the mechanism set out in the communication you wish to unsubscribe from. It may take up to fourteen days for us to process your request to unsubscribe. We may also send you other non-marketing e-mail communications, such as service updates, admin notifications, and surveys, which do not offer you the opportunity to opt out of receiving them. Please note that opting out from marketing communications will not affect future subscriptions if you fail to opt out at sign-up.

The Rights You Have Relating to Your Personal Data

Subject to local law, you have certain rights regarding the Personal Data we collect, use or disclose and that is related to you, including;

- to receive information on the Personal Data we hold about you and how such Personal Data is used (right to access);
- to correct erroneous Personal Data we hold about you (right to data rectification);
- to remove your Personal Data (right to erasure/deletion, "right to be forgotten");
- to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable format and to transmit those Personal Data to another data controller (right to data portability)
- to object to the use of your Personal Data where such use is based on our legitimate interests or on public interests (right to object); and
- in some cases, to restrict the use of your Personal Data (right to restriction of processing).

You have the right to withdraw your consent for us to use your Personal Data at any time, however, by doing so you may no longer able to use all of or a significant proportion of our Website its Products.

To exercise any of the rights you have relating to your Personal Data in accordance with the applicable legal requirements and limitations, you may email us at info@cruelgf.com at any time. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.

Please be aware that requests to delete certain Personal Data will require us to delete your user account which may result in all or some parts of the Website becoming inaccessible or functioning incorrectly. We may also require additional information from you in order to confirm your identity in order to satisfy the request.

Changes to Our Privacy Policy

We may amend and update our privacy policy periodically. Whilst we may attempt to notify you when major changes are made to this privacy policy, you are expected to to refer to this page regularly to review the most up-to-date version.

Changes to the privacy policy will be reflected in the "Document date". You agree that you will regularly review this privacy policy and refresh the page when doing so. You agree to note the document date of the privacy policy. If the "Document Date" is unchanged from the last time you reviewed our privacy policy, then it remains unchanged, however, if the date has changed, then it has been updated, and you agree to re-review our privacy policy, and you agree to the new ones. By continuing to access and use the Website after we have uploaded an amended version of our privacy policy, you thereby agree to such amendment.

Cooperation

If you have any questions or concerns regarding this privacy policy or our how we use Personal Data you may email us at info@cruelgf.com . Upon receipt of a written complaint from you, it is our policy to respond to you by email to address your concerns. In the event a resolution cannot be met, we will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve your complaint.

No Rights of Third Parties

This privacy policy does not create rights enforceable by third parties or require disclosure of any Personal Data relating to users of the Website.

Our Policy Towards Minors

Access to this Website is not permitted to individuals under the age of 21 (or the applicable age of majority in the jurisdiction territory from which the Website is accessed) and we do not knowingly collect Personal Data from minors. If you have identified that your child has provided us with Personal Data, please contact us at info@cruelgf.com . If we become aware that a minor has provided us with Personal Data, we take steps to remove such information and terminate their account.

No Error Free Performance

Whilst we have made every attempt to ensure that all of the information within this privacy policy is accurate and up to date, it may occasionally be inaccurate, incomplete or out of date. We do not guarantee an error-free performance under this privacy policy. We will take all reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy.

Contact Information

If you have any questions about this privacy policy or our information-handling practices, please contact us at info@cruelgf.com

Document Date

15th January, 2021