Last Modified: August 10, 2022
Ebraxtech Ventures Ltd. (hereinafter “we”, “us” or “our”) operates under the governing law of Cyprus and is situated at Alekou Konstantinou 56, Strovolos, 2024 Nicosia, Cyprus. It operates the websites https://camarads.com/ (hereinafter “Camarads”) and is the controller of the information collected or provided via the Website.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
The Data We Process About You
We may process different kinds of personal data about you, depending on whether you chose to create an account with us.
Persons who visit the Websites without logging in or registering (“unregistered users”):
Persons who choose to create an account on Camarads and persons who choose to upgrade their account on Camarads to a premium account such that they have full access to the content found on Camarads (“Premium users”):
We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.
The Sources from Which We Process Personal Information
We process Personal Information in the following ways:
Directly from you: We process the categories of information listed above directly from you.
Automated technologies or interactions. As explained in the section below on Cookies and Automatic Data Processing Technologies, we set cookies and other automatic techniques to process website activity data when you visit the Websites or other websites owned by our corporate group.
Purposes for Which We Process Your Personal Information
We process personal information for the purposes described below.
Our Legal Bases Under EU Law
We have the following legal bases under EU law for processing your personal data for the purposes described under Section Purposes for Which We Process Your Personal Information:
Disclosure of Your Personal Information
We disclose personal information:
Cookies and Automatic Data Processing Technologies
As you navigate through and interact with our Websites, we use automatic data processing technologies to process website activity data.
We currently use the following types of cookies, which are set by the Websites’ domains, or by other domains we own or control:
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to process information about how users use the Websites, including by processing website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will process the information only for the purpose of providing Google Analytics services to us, and will not process this information for other purposes. The information processed by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You can learn more on how Google processes data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page.
Third-party Process of Cookies and Other Tracking Technologies
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
Your Choices About How We Process and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us.
You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Websites because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Websites.
As explained in the section Cookies and Automatic Data Processing Technologies, you may set your browser to refuse some or all cookies. In addition, you may opt out of Google Analytics by visiting the Google Analytics opt-out page.
You can opt out of receiving marketing emails from us using the opt-out link provided in our emails. If you are a Registered User, we may continue to send you other types of transactional and relationship e-mail communications, such as emails about your account or orders, administrative notices, and surveys.
You may also delete and deactivate your account with us at any time. If you do so, your profile will no longer be accessible by you. If you later choose to have an account with us, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
Your Rights Related to Your Personal Information
You have certain rights regarding the personal information we process and that is related to you, including the right:
You may exercise your right to access and deletion by, sending us an e-mail at [email protected] to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area or the UK, you have a right to lodge a complaint with your local data protection authority.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases in order to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address).
California Rights and Choices
The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your personal information:
Right to Know: You have the right to request that we disclose certain information about our processing of your personal information over the past 12 months, including the specific pieces of information we processed.
Right to Request Deletion: You have the right to request that we delete any of your personal information we processed from you and retained, subject to certain exceptions set forth in the CCPA.
Right to Non-Discrimination for the Exercise of Your Rights: We will not discriminate against you because you have exercised any of your rights under the CCPA.
To exercise the rights described above, please email us at [email protected] with the email subject line “CCPA Request.” In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your email address that you used to create an account with us, as well as any other information which we may reasonably request in order for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
We disclose certain categories of California residents’ personal information for our business purposes, as described in the section above titled Disclosure of Your Personal Information.
We do not sell California residents’ personal information.
Notice to Nevada Residents/Your Nevada Privacy Rights
We do not exchange Nevada residents’ personal information for money with anyone so they may license or sell the personal information to additional parties.
We may employ third-party service providers to help verify your identity and age and to check the authenticity of identification documents you provide using facial recognition technology. The facial recognition technology creates a mathematical representation of your face and detects facial features from the live scan of your face, your selfie, and the government-issued ID you submit or previously submitted to us. This mathematical representation, which is considered biometric information/identifier/data under the laws of certain states and countries, is not shared by our service providers with us, and is deleted by our service providers 7 days after its creation. Information derived from this mathematical representation, which may be considered biometric information/identifier/data under the laws of certain states and countries, is shared by our service providers with us and is deleted by us as further described below.
Your biometric information will be processed to:
Biometric information shared by our service providers with us will be stored for as long as you have a Camarads Model Partner Program account. We will delete your biometric information within three (3) days of you deleting your Camarads Model account or withdrawing your consent, subject to any legal obligations we might have.
You will be asked to provide your consent to biometric processing. You may withdraw your consent to this processing at any time by emailing us at [email protected] Withdrawing your consent will not affect the lawfulness of any processing or disclosure that occurred prior to the withdrawal.
Please note that this section entitled “Biometric Information” applies to relevant users who wish to upload or send content to our Websites but does not apply to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to our Websites in order to view the contents found thereon.
Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using the Websites you consent to the transfer of information that we process about you, including personal information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer personal information to countries outside of the European Economic Area (“EEA”) or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws. Where relevant, our transfers outside the EEA are made pursuant to standard contractual clauses approved for use by the European Union.
Retention of Personal Information
We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider a number of factors, including what personal data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.
Where permissible, we will also delete your personal information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.
Third-Party Links and Sites
GDPR (General Data Protection Regulation)
In accordance with the General Data Protection Regulation law in the European Union effective May 25, 2018, Camarads users can request a copy of their personal data as well as get Camarads to delete their personal data.