Privacy Policy

The purpose of this privacy policy is to provide you with information concerning the processing of personal data when using our website under www.Victoriamilan.com (hereinafter: Website) and related services. Personal data within the meaning of Art. 4 of the EU General Data Protection Regulation (hereinafter: GDPR) are all information relating to an identified or identifiable natural person, e.g. name, address, email address, etc. Responsible for the processing of personal data within the meaning of Art. 4 (7) GDPR is: Victoriamilan Holding Ltd (address: The Plaza Commercial Centre, Level 8, Suite 5, Bisazza Street Sliema Malta SLM 1640, registration number:C73470 email:support@victoriamilan.com) (hereinafter: Controller or Victoriamilan).

1. Description of the data processing

Victoriamilan is committed to respecting and safeguarding your privacy and the security of your personal information in compliance with applicable laws and GDPR.

In this Privacy Policy, we explain which personal information we collect, how we collect it, and for what purposes. This means, among other things, that we:

  • explain in detail the categories of personal information we collect and how we collect it;
  • clearly state for what purposes and on what legal basis we process personal information;
  • strive to limit the collection of personal information to those needed for legitimate purposes only;
  • first request your express consent to the processing of your personal information in cases where your consent is required;
  • implement appropriate security measures to protect your personal information, and demand the same of parties processing personal information on our instructions;
  • respect your right to request access to and a copy of your personal information and have it corrected or deleted, among other rights you have as further described below.

 

2. Data subject

 

The data subject is You who use our services because you are identifiable natural person based on the personal information you have provided to Victoriamilan.

3. The source from where we Victoriamilan receives the personal information

Victoriamilan receives personal data of the data subjects in two ways.

3.1 Directly from the data subjects (You).

You can share your personal information with us in a number of ways, for instance by:

  • subscribing to our newsletter;
  • communicating with our customer service by e-mail, in writing;
  • registering a profile;
  • participating in a promotion, event, contest or online forum, or by filling out a questionnaire or survey related to Victoriamilan;
  • purchasing service on the Website;
  • cookies placed by Victoriamilan or third parties on your computer or mobile device when you visit our Website and accept the cookies, on which we provide information in information in section 10.

 

3.2 Personal data received from partner websites.

 

Victoriamilan may receive personal data about the data subjects (You) from partner websites which offer services to transfer already existing profiles to other partner sites such as Victoriamilan thereby making the registration process easier and You do not have to fill out your profile again. Victoriamilan only receives Your personal data from partner sites if you have given your consent and have asked for this service.

4. Why do we collect your personal information?

When you choose to register a profile, or otherwise contact us, we will ask you for some personal information about you, as well as some optional information about you. The main purposes for which we use your personal information are:

  • to communicate with you in a personal way, such as responding to your feedback or service requests and register and settle complaints;
  • to send you advertisement communications, special offers in form of newsletters;
  • to manage and maintain your profile on the Website and the Application;
  • to execute an agreement, such as completing transactions, administering and fulfilling your purchases related to our services;
  • to send status updates and service communications;
  • to send out notifications when changes are made to our policies and other (legal) documents which might concern you;
  • to check the validity of chargebacks;
  • to comply with legal obligations.

 

5. Legal bases of the data processing

 

Victoriamilan will only process your personal information where we have a legal basis to do so. The processing of your personal information and their legal bases are the following:

5.1 Victoriamilan processes your personal information necessary for the performance of a contract with you, or to prepare entering into a contract with you at your request namely if you use our services on the Website or in the Application. The legal bases of the data processing is Art. 6. (1) b) of the GDPR.

5.2 If You have given your consent (when registering or in your account settings) to process your personal information to send you newsletters then the legal bases of the data processing is Art. 6. (1) a) of the GDPR. Please note that you consent can be revoked at any time by sending Victoriamilan an email or simply modify the settings in your account. You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

5.3 If You have given your consent to process your personal information to participate in a promotion, event, contest or online forum, or by filling out a questionnaire or survey related to Victoriamilan then the legal bases of the data processing is Art. 6. (1) a) of the GDPR. Please note that your consent can be revoked at any time by sending Victoriamilan an email or simply modify the settings in your account.

5.4 Victoriamilan processes your personal information (such as processing IP-addresses) necessary for legitimate interests pursued by Victoriamilan in order to prevent, detect and/or respond to fraud, abuse of our Website and/or storing additional information to be able to identify You when losing access to your account. The legal bases of the data processing is Art. 6. (1) f) of the GDPR.

5.5 Victoriamilan processes your personal information necessary to comply with a legal obligation (for example, due to fiscal regulation we need to retain certain customer data). The legal bases of the data processing is Art. 6. (1) c) of the GDPR

5.6 Victoriamilan processes certain personal information in relation to the services on the Website or in the Application based your consent [Art. 6. (1) a) of the GDPR]. You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

5.7 Victoriamilan processes certain personal information in relation to chargeback requests. This is necessary for legitimate interests pursued by Victoriamilan to be able to decide the validity of chargeback request of users of the Website. The legal bases of the data processing is Art. 6. (1) f) of the GDPR.

6. Purpose of the data processing, the categories of the personal data and period for which the personal data will be stored

6.1 Personal data processed for the purpose of providing service to you.

6.1.1 When you register on the Website or in the Application the strictly necessary personal information to create an account / profile user name and an email address, gender, seeking gender, height, weight, body type, hair, eyes, looks, facial hair, location.

6.1.2 Please be aware that if you do not provide the necessary information Victoriamilan will not be able to provide its services to you.

6.1.3 In order to be able for you to use every aspect of our service to the fullest you are encouraged to fill out your profile as thoroughly as possible during which you can provide additional personal data (photo). Please note that the legal bases for processing additional personal data that is not required for registration is not in your consent [Art. 6. (1) a) of the GDPR].

6.1.4 The email address you provide during account registration will not be visible or otherwise available to other users. We nonetheless encourage all of our members and users to create an anonymous separate email account. This will help secure your privacy when using this Website.

6.1.5 If you choose to upload an image to your profile, there is a risk of being recognized and linked to your real identity. We therefore advise you to use our unique AnonymousBlurTM feature or other anonymising tools available on our Website to make your face unrecognizable in the photos you choose to upload. This will maintain your anonymous identity while at the same time allowing users to get an impression of your physical appearance.

6.1.6 When you pay via the Website, the Company and sites other than the card processor cannot access your bank account or credit card number. Victoriamilan does not store any credit card sensitive information, and uses Wirecard which is a leading professional payment service for online transaction. Your Wirecard account is secured by BBS ePay.

6.1.7 We provide areas on our site where you can post information about yourself and others and communicate with others or upload content such as photographs (“User Contributions”). Such postings are governed by our Terms of Service. You post and transmit your User Contributions to others at your own risk. Although we limit access to certain pages, and you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons, so we encourage you to exercise discretion and caution with respect to the information you post.

6.1.8 Your personal data will be stored until we provide service to you and you do not request the deletion of your profile. Please be aware that we do not delete your profile just because your subscription has ended.

6.2 Personal data processed for the purpose of sending you newsletters

6.2.1 If you have given us your consent (either when registering or by turning on the newsletter function in your profile) to receive newsletters then we process your profile name and email address for advertisement purposes.

6.2.2 Your personal data for advertising purposes will be processed until you request the deletion of your personal data used for advertising purposes by sending us an email or turning of the newsletter function in your profile.

6.3 Personal data processed for the purpose of participating in a promotion, event, contest or online forum, or by filling out a questionnaire or survey related to Victoriamilan

6.3.1 If you have given us your consent to participate in a promotion, event, contest or online forum, or by filling out a questionnaire or survey related to Victoriamilan your profile name and email address will be purposes.

6.2.2 Your personal data will be processed for these purposes until you request the deletion of your personal data until the purposes is fulfilled / but for a maximum of two years.

6.4 Personal data processed for the purpose of fraud prevention

6.4.1 Victoriamilan during his operation of the Website has encountered several fraud attempts which could have been prevented with fraud prevention monitoring. In order to give you secure and reliable services we need to be able to identify fraudulent or fake profiles so that you will not be victim of scammers, therefore Victoriamilan operates fraud prevention on the Website.

6.4.2 For fraud prevention Victoriamilan needs to monitor certain characteristics of a profile (such as IP address) and communication between users of the site, however this is done in a secure way. The profiles and communication will be analysed by algorithms based on criteria to identify fraud and in case no indication of fraud is detected the communication will be encrypted and sent to the addressee of the communication where only the addressee can decrypt it. All communication between you and other users of the Website is stored encrypted. In case there is no indication of fraud Victoriamilan will not be able to see your communications. In case the fraud prevention algorithms detect fraud the communication will be flagged and sent to our fraud prevention officer to investigate the profile and the communication. If the fraud prevention officer establishes with high degree of certainty that the profile attempted fraud, then Victoriamilan will take the necessary action to counter it.

6.5 Personal data processed for the purpose of legal obligations

6.5.1 Victoriamilan , in order to fulfil its legal (fiscal) obligations has to process your personal data which is necessary to identify your purchases (subscriptions) which include transaction ID, payment details, banking details and Client ID.

6.5.2 Your personal data processed for fulfilling the legal obligations will be processed for 10 years.

6.6 Personal data processed for the purpose of deciding the validity of chargeback requests by users of the Website

6.6.1 Victoriamilan during his operation of the Website has encountered several attempts from users of the Website that requested chargebacks which were unfounded and which could have been prevented with processing a limited amount of personal data in addition to data that is already processed for meeting our legal (fiscal) obligation.

6.6.2 In order for Victoriamilan to be able to decide the validity of a chargeback request Victoriamilan has to process user ID, login date, site activity (anonymized form such as number of winks, number of exchanged messages) membership renewal data, date of last messages and their number in addition to what is already processed for meeting legal (fiscal obligation).

6.6.3 Your personal data processed for deciding the validity of chargeback request will be processed for 12 month after the end of your last membership.

7. Disclosure and Transfer of personal data

7.1 We may share your personal information with third party service providers or agents (called ‘processors’) to perform certain processing activities on our behalf, such as parties involved in executing a purchase agreement (such as payment service providers, customer services or fraud prevention). We will not sell, rent, lease, or provide your personal information to third parties allowing them to use your personal information for their own purposes. We use third party service providers for website hosting, for payment processing, customer service and fraud prevention. Victoriamilan is fully responsible for all the processors.

7.2 Pursuant Art. 28 (2) of the GDPR: Victoriamilan concludes so-called ‘data processing agreements’ with all parties who process your personal information on our behalf, so that they are legally bound to keep your data confidential, to implement appropriate security measures, to notify us if the security of your data has been breached, and other obligations to protect your privacy.

7.3 Victoriamilan may sell (whole or part) of its business to another company. Such transfer of ownership may include the transfer of your personal information to the new owner. Victoriamilan will notify you before such a transfer occurs.

7.4 Furthermore, we will release your personal information if so required by law, where necessary for preventing or combating fraud, where necessary for dispute resolution, or for any other pressing legitimate need which under the circumstances must outweigh your privacy interests, which may include the security of our business and the safety of our staff.

7.5 Victoriamilan makes it possible on the Website to transfer your created profile to other partner websites providing similar services thereby making the registration process on such websites easier. Victoriamilan only transfers your personal data to other sites if you have given your consent and have asked for this service in which case the legal bases of the data processing is Art. 6. (1) a) of the GDPR. After your personal data has been transferred to the partner sites the partner site will be the controller of the personal data to which it has been transferred. We encourage you to visit the privacy policy of the partner website before you consent to the transfer of your personal data.

7.6 If you arrive at our Website via our marketing partners and register a profile on Victoriamilan , then after your registration we provide additional anonymised information for accounting purposes to the marketing partner which contributed to your registration

8. Your Rights

8.1 Based on the request of the data subject (You) in writing or by electronic means Victoriamilan will provide you with the following information [Art. 15 (1) of the GDPR right to access]:

  • what information we are processing about you,
  • purpose of the data processing,
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed,
  • duration of the data processing,
  • your rights.

 

8.2 Furthermore you have the following rights

 

  • Right to rectification and to erasure;
  • Right to restriction of processing;
  • Right to data portability - receive an electronic copy of your personal information for purposes of transmitting it to another company;
  • Right to object.

 

8.3 If you have any complaints about the way we process your personal information, we are glad to help you out. Nevertheless, you have the right to lodge a complaint with a supervisory authority in the member state where you are residing. A list of data protection authorities is available here

 

8.4 In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

8.5 Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).

9. Cookie policy

9.1 When visiting our website, cookies are stored on your computer. Cookies are small text files that are stored by your browser on your device to save certain information. The next time you visit our website on the same device, the information saved in the cookies will subsequently be transmitted either to our website (“First Party Cookie”) or to another website to which the cookie belongs (“Third Party Cookie”).

9.2 Through the information saved and returned, the respective website recognizes that you have already accessed and visited it with the browser you use on that device. We use this information to be able to design and display the website in an optimum way in line with your preferences. In that respect, only the cookie itself is identified on your device. Beyond this extent, your personal data will only be saved upon your express consent or if it is strictly necessary to be able to use the service offered to and accessed by you accordingly.

9.3 This website uses the following types of cookies, the scope and functionality of which are explained below:

  • Strictly necessary cookies
  • Functionality and Performance Cookies
  • Consent based Cookies (e.g. Marketing)

 

9.4 On the Website we use the following cookies

 

 

9.5 Strictly necessary cookies

 

9.5.1 Strictly necessary cookies guarantee functions without which you cannot use our web pages as intended. These cookies are used exclusively by us and are therefore first party cookies. This means that all information stored in the cookies will be returned to our website.

9.5.2 Strictly necessary cookies serve, for example, to ensure that you as a registered user always remain logged in when accessing various subpages of our website and thus do not have to re-enter your login data every time you access a new page.

9.5.3 The use of strictly necessary cookies on our website is possible without your consent. For this reason, strictly necessary cookies cannot be activated or deactivated individually. However, you can deactivate cookies in your browser at any time (see section 10.8).

9.5.4 Legal basis: Art. 6 (1) b GDPR.

9.6 Functionality and Performance Cookies

9.6.1 Functionality cookies enable our website to store information already provided (such as registered name or language selection) and to offer you improved and more personalized functions based on this information. These cookies collect and store only anonymous information so that they cannot track your movements on other websites.

9.6.2 Performance cookies collect information about how our websites are used in order to improve their attractiveness, content and functionality. These cookies help us, for example, to determine whether and which subpages of our website are visited and in which content users are particularly interested.

9.6.3 In particular, we record the number of visits to a page, the number of subpages accessed, the time spent on our website, the order of the pages visited, which search terms led you to us, the country, region and, if applicable, the city from which access is made, and the proportion of mobile devices accessing our websites. We also capture movement, clicks and scrolling with the computer mouse to understand which areas of our website are of particular interest to users.

9.6.4 We do not use this data in connection with your profile or with your name, but only process it as part of statistical data.

9.6.5 As a result, we can tailor the content of our website more specifically to the needs of our users and optimize our offering. The IP address of your computer transmitted for technical reasons is automatically made anonymous and does not allow us to draw any conclusions about the individual user.

9.6.6 Legal basis: Art. 6 (1) f GDPR.

9.7 Consent based Cookies

9.7.1 Cookies, which are neither strictly necessary nor functionality or performance cookies will be used only upon your express consent, e.g. marketing cookies.

9.7.2 We also reserve the right to use information that we have obtained by means of cookies from an anonymous analysis of the usage behaviour of visitors to our website in order to display specific advertising for certain of our products on our own websites. We believe that you as a user benefit from this because we display advertising or content that we think suits your interests based on your surfing behaviour, so that you will see less randomly scattered advertising or certain content that might be of less interest to you.

9.7.3 Marketing cookies come from external advertising companies (third party cookies) and are used to collect information about the websites visited by the user in order to create target group-oriented advertising for the user.

9.7.4 Legal basis: Art. 6 (1) f GDPR.

9.7.5 Opt-out for cookies used for online advertising

You can also manage many companies’ cookies used for online advertising via the consumer choice tools created under self-regulation programs in many countries, such as the US-based https://www.aboutads.info/choices/ or the EU-based http://www.youronlinechoices.com/uk/your-ad-choices.

You can withdraw your consent to the use of consent based cookies individually at any time with effect for the future by adjusting your cookie settings accordingly.

9.8 Administration and deletion of all cookies

9.8.1 You can set your web browser in such a way that cookies are generally prevented from being saved to your device and/or that you are asked each time whether you are in agreement with cookies being enabled. You can also at any time delete cookies that have been enabled again. You can find out how all this works in detail from your browser’s help function.

9.8.2 Please note that generally deactivating cookies may lead to functional restrictions of our Website.

9.9 Google Analytics

9.9.1 The Website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses a specific form of cookie, which is stored on your computer and enables an analysis of your use of our website. The information about your use of this website generated by the cookie is generally transmitted to a Google server in the USA and stored there.

9.9.2 You can prevent the storage of cookies by making the proper setting using your browser software. In addition, you can prevent Google from recording the data related to your use of the website generated by the cookie (including your IP address) and from processing this data by downloading and installing the browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

9.9.3 The Website also uses Google Analytics for a device-independent analysis of visitor flows, which is carried out via a user ID. You can disable cross-device tracking of your usage in your Google Account under “My information”, “Personal information”.

9.9.4 Legal basis: Art. 6 (1) f GDPR.

9.10 Social Plug-ins

9.10.1 Social plug-ins (“plug-ins”) of social networks are used on our websites, in particular the “Share” or “Share with friends” button of Facebook, whose website facebook.com is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland, is responsible for Facebook.com in Europe. The plug-ins are usually marked with a Facebook logo.

9.10.2 Besides Facebook and Instagram, we use plug-ins from “Google+” (Provider: Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA), windowslive (provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

9.10.3 By clicking on the respective button (e.g. “Pass on”, “Share” or “Share with friends”) you agree that your browser will produce a link to the respective social network's servers and transmit usage data to the respective operator of the social network and vice versa. We have no influence upon the nature and extent of the data that is then gathered by the social networks.

9.10.4 The social network provider stores the data collected about you as user profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation takes place in particular (also for not logged in users) for the representation of demand-fair advertisement and in order to inform other users of the social network about your activities on our website. You have a right of objection to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. Through the plug-ins we offer you the possibility to interact with social networks and other users, so that we can improve our offer and make it more interesting for you as a user.

9.10.5 The data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected with us will be directly assigned to your existing account with the plug-in provider. If you click the activated button and, for example, link the page, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button, as this way you can avoid being assigned to your profile with the plug-in provider.

9.10.6 For more information on the purpose and scope of data collection and its processing by the plug-in provider, please refer to the data protection declarations of these providers as notified below. They will also provide you with further information about your rights in this regard and setting options to protect your privacy.

Facebook, Google

9.11 Social Login

9.11.1 To register and log in to your account, you also have the option of authenticating yourself with your existing profile on one of the following social networks, Facebook or Google+, and finally registering or logging in.

9.11.2 For this purpose, you will find on the registration page or login page the corresponding symbols of the respective providers of the social networks supported by our website. Before a connection to the provider is established, you must expressly agree to the process and transmission of data described below:

9.11.3 By clicking on the respective symbol, a new pop-up window (so-called app) opens, in which you must log in with your login data for the social network. After you have successfully logged in, the social network will tell you, which data will be transmitted to us for authentication as part of the registration or login process. If you have agreed to this data transfer, the fields required by us for registration will be filled with the transmitted data. The information we require for registration or login is (i) your name and (ii) your email address

9.11.4 Only after your express consent to the use of the transmitted and required data, your data will be stored by us and used for the purposes as stated within this Privacy Policy. There is no link beyond the authentication process between your customer account created with us and your account on the corresponding social network.

9.11.5 In order to perform the authentication process for registration and login, your IP address is transmitted to the respective social network provider. We have no influence on the purpose and scope of data collection and on the further processing of the data by the respective provider of the social network. For further information, please read the data protection information of the respective provider.

10. Other provisions

10.1 In case Victoriamilan modifies the Privacy Policy, it will publish it on the Website and inform the data subjects about the modification in an email and on the Website with pop up messages.

10.2 Should Victoriamilan process the personal data of the data subjects for a different purpose than for which it was provided Victoriamilan will inform the data subjects prior to such a new processing activity.

10.3 Should Victoriamilan disclose the personal data of the data subjects with other recipients then it will inform the data subjects when it is first disclosed.