PRIVACY POLICY

Last updated: 22 September 2026

1. Introduction

This Privacy Policy explains how Hotwifing.eu collects, uses, stores, shares and protects personal data.

The data controller is:

[Operator Legal Name]
Registered address: [Registered Address]
Registration number: [Registration Number]
Privacy email: [Privacy Email]

Hotwifing.eu is an adults-only dating platform.

Because of the nature of the service, information voluntarily supplied by users may reveal information concerning their sex life or sexual preferences. Such information may qualify as special-category personal data under applicable data protection law.

2. Who May Use the Platform

Hotwifing.eu is intended only for persons aged 18 or over.

We do not knowingly provide accounts to minors.

We may use age or identity verification technologies and third-party verification providers to confirm that users meet our age requirements.

3. Personal Data We Collect

We may collect account data such as:

username;
email address;
encrypted password information;
account type;
membership level;
verification status;
account status.

We may collect profile information voluntarily provided by the user, including:

approximate location;
age;
relationship information;
dating preferences;
interests;
availability;
profile descriptions;
photographs;
private gallery content.

Because this is an adult dating service, certain profile information may reveal a user’s sex life, sexual preferences or sexual orientation.

We may also process:

messages and communication metadata;
reports and moderation information;
likes, interests and invitations;
login records;
IP addresses;
browser and device information;
security logs;
cookie identifiers;
subscription and transaction information.

4. Age and Identity Verification Data

Hotwifing.eu may use an independent service provider for age or identity verification.

Depending on the verification method, that provider may process photographs, identity documents, selfies or other verification information.

Where technically possible, Hotwifing.eu intends to receive only the information necessary to operate the service, such as:

18+ verified: yes/no, verification status and a verification reference.

We aim to avoid retaining copies of identity documents where they are not necessary.

The identity of the age or identity verification provider will be disclosed before production verification is activated.

5. Special-Category Personal Data

Information relating to a person’s sex life or sexual orientation may be treated as special-category personal data under Article 9 GDPR.

Where operation of Hotwifing.eu requires processing such information, we may rely on the user’s explicit consent together with an appropriate lawful basis under Article 6 GDPR.

Explicit consent is collected separately from acceptance of the general Terms & Conditions.

Users may withdraw consent for future processing.

Withdrawal of consent does not make prior lawful processing unlawful.

Withdrawal may mean that we can no longer provide functionality that inherently depends on processing the relevant information.

6. Why We Process Personal Data

We may process personal data to:

create and manage accounts;
verify age and account eligibility;
provide profile and discovery functionality;
operate membership levels;
process subscriptions;
provide messaging and video communication;
manage private galleries;
provide notifications;
process likes, interests and invitations;
prevent fraud and abuse;
investigate reports;
enforce our Terms & Conditions;
protect Platform security;
comply with legal obligations;
provide customer support;
maintain backups;
improve Platform functionality.

We do not use special-category sexual-profile information for third-party behavioural advertising.

7. Legal Bases for Processing

Depending on the processing activity, we may rely on:

performance of a contract;
compliance with legal obligations;
legitimate interests;
consent;
explicit consent where required for special-category data.

Our legitimate interests may include:

account security;
fraud prevention;
abuse prevention;
service integrity;
technical operation;
defence of legal claims.

Where we rely on legitimate interests, we consider whether those interests are overridden by the rights and freedoms of the individual.

8. Couple Accounts

A Couple account may contain information relating to more than one person.

The person creating or managing a Couple account confirms that both adults represented by the account have agreed to:

creation of the Couple account;
use of the information provided;
upload of media concerning them;
relevant Platform processing.

Hotwifing.eu may require both adults represented by a Couple account to complete age, identity or consent verification.

9. Media Consent

Users may upload photographs or other media where permitted.

The person uploading media confirms that every identifiable person depicted:

is at least 18 years old;
was at least 18 when the media was created;
consented to the creation of the media;
consented to its upload to Hotwifing.eu;
has not withdrawn that consent.

If a person credibly reports that media was uploaded without consent, Hotwifing.eu may restrict or remove the content while the matter is reviewed.

10. Photographs and Private Galleries

Profile photographs may have different visibility levels.

Content may be available:

to eligible authenticated members;
only to Premium users;
only to users individually approved by the profile owner.

Private-gallery access is separate from subscription status.

A Premium subscription does not automatically override another member’s privacy choice.

A user may revoke access to a private gallery at any time.

11. Messaging

Private messages are processed so that Hotwifing.eu can transmit and display communications between intended participants and provide safety, reporting and abuse-prevention functions.

Users should avoid sharing highly sensitive personal information unless necessary.

Where a message is reported, authorised moderators may review relevant content where reasonably necessary to investigate the report.

12. Video Calling

Hotwifing.eu may provide video-call functionality through a specialist communications provider.

Depending on the technical implementation, video and audio may be transmitted using third-party communications infrastructure.

Hotwifing.eu does not intend to record private video calls by default.

If recording functionality is introduced in the future, users will be clearly informed and appropriate consent requirements will be implemented.

Users must not record another user without that person’s permission.

13. Payments

Subscription payments may be processed through third-party payment providers.

Payment providers may independently process:

identity information;
payment details;
transaction information;
fraud-prevention information.

Hotwifing.eu normally receives only information required to administer the subscription, such as:

transaction status;
subscription reference;
payment amount;
billing status;
payment date.

Hotwifing.eu generally does not intend to store full payment-card details.

The relevant payment provider will be identified during checkout and in this Privacy Policy before paid subscriptions are launched.

14. Who We Share Personal Data With

We may disclose personal data where reasonably necessary to:

hosting providers;
infrastructure providers;
email providers;
age or identity verification providers;
payment processors;
messaging and video providers;
security providers;
technical support providers;
professional advisers;
competent public authorities where legally required.

Service providers acting as processors are expected to process personal data only for authorised purposes and under appropriate contractual safeguards.

We do not sell users’ personal data to advertisers.

15. International Transfers

Some service providers may process information outside the European Economic Area.

Where applicable law requires safeguards for an international transfer, we will use an appropriate lawful transfer mechanism, such as:

an adequacy decision;
Standard Contractual Clauses;
supplementary technical or organisational safeguards.

16. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, accounting, security or dispute-resolution requirements.

Active account data is generally retained while the account remains active.

When an account is deleted, information that is not required for another lawful reason will be scheduled for deletion or anonymisation.

Limited copies may remain temporarily in secure backups until those backups are overwritten or deleted.

Payment, accounting and tax records may be retained for legally required periods.

Security, fraud-prevention or legal-claim information may be retained for longer where reasonably necessary.

17. Account Deletion

Users may request deletion of their account through available account tools or by contacting:

[Privacy Email]

Deletion normally removes the profile from active use on the Platform.

Certain information may nevertheless be retained where necessary to:

comply with legal obligations;
resolve disputes;
prevent serious abuse;
investigate fraud;
establish, exercise or defend legal claims.

18. Withdrawal of Explicit Consent

Users may withdraw explicit consent relating to optional special-category profile information by using available settings or contacting:

[Privacy Email]

Where a Platform feature cannot lawfully operate without processing the relevant information, withdrawal may require removal of that information or disabling the affected feature.

19. Your Data Protection Rights

Subject to applicable legal conditions and exceptions, users may have the right to request:

access to personal data;
correction of inaccurate data;
deletion;
restriction of processing;
data portability;
objection to certain processing;
withdrawal of consent.

Where processing relies on consent, consent may be withdrawn at any time for future processing.

Requests should be sent to:

[Privacy Email]

We may request reasonable information to verify the identity of the person making the request.

20. Complaints

Users may lodge a complaint with the data-protection supervisory authority responsible for their location.

Where the controller is established in Romania, the relevant authority is:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal — ANSPDCP

Users may also contact Hotwifing.eu directly before making a complaint, if they wish.

21. Security

We use technical and organisational measures intended to protect personal data against:

unauthorised access;
accidental loss;
misuse;
alteration;
disclosure;
destruction.

Measures may include:

HTTPS encryption;
access controls;
account verification;
strong password requirements;
administrative restrictions;
security logging;
backups;
fraud-prevention controls;
login protection.

No online service can guarantee absolute security.

Users are responsible for protecting their passwords and should notify us promptly if they believe their account has been compromised.

22. Data Protection Impact Assessment

Because Hotwifing.eu may process sensitive personal information and intimate media, we may conduct Data Protection Impact Assessments before deploying processing activities likely to result in a high risk to individuals’ rights and freedoms.

23. Automated Decisions and Profiling

Hotwifing.eu may use automated systems to assist with:

spam detection;
fraud prevention;
safety;
ranking;
recommendations;
moderation.

We do not intend to make decisions producing legal or similarly significant effects solely through automated processing without safeguards required by applicable law.

24. Cookies and Similar Technologies

Hotwifing.eu uses cookies and similar technologies required for:

login sessions;
security;
membership functionality;
account preferences;
technical operation.

Optional analytics or marketing cookies, if introduced, will be handled in accordance with applicable consent requirements.

Further details will be provided in a separate Cookie Policy and cookie-preference interface.

25. Children

Hotwifing.eu is not directed to children.

Persons under 18 may not create or use an account.

If we become aware that a minor has created an account or that content involving a minor has been uploaded, we may take immediate action including account suspension, content removal and, where required, reporting to competent authorities.

26. Changes to This Privacy Policy

We may update this Privacy Policy where our service, technology, providers or legal obligations change.

The latest version and effective date will be published on Hotwifing.eu.

Where required by law, users will be informed of material changes.

27. Contact

For privacy questions, data-protection requests or withdrawal of consent, contact:

[Operator Legal Name]
[Registered Address]
Privacy email: [Privacy Email]