1. Who We Are (Controller)

The website erogreek.com is operated by Synden s.r.o., which acts as the data controller for all personal data processed through this website.

For any questions or requests concerning your personal data, please contact us at the email address above. A formal Data Protection Officer appointment is not required under applicable regulations given the scale of our processing activities.

2. What Data We Collect & Why

a) Account & Identity Data

Username, email address, hashed password, date of birth, gender, profile picture, biography, service description, and approximate location (city/region).

Purpose: Account creation and delivery of Platform services. Legal basis: Performance of contract (Art. 6(1)(b) GDPR).

b) Advertiser Profile Data

Appearance attributes, services offered, pricing, availability, and other information voluntarily added to your Ad profile, which may include sensitive data categories such as sexual orientation or preferences.

Purpose: Publishing your Ad on the Platform. Legal basis: Explicit consent (Art. 9(2)(a) GDPR). You may withdraw consent by removing the information or deleting your account.

c) Usage & Technical Data

IP address, device and browser details, login timestamps, pages visited, clicks, and interactions.

Purpose: Platform operation, security, fraud prevention, age verification, and service improvement. Legal basis: Contract performance and legitimate interests (Art. 6(1)(f) GDPR).

d) Communications Data

Messages sent through Platform support channels.

Purpose: Providing support and resolving disputes. Legal basis: Contract performance.

e) Payment & Billing Data

Billing address, payment method type (no card numbers stored), transaction history, and invoicing records.

Purpose: Processing credit purchases, accounting, and tax compliance. Legal basis: Contract performance and legal obligation (Czech accounting legislation — 10-year retention).

f) Marketing Communications

Email address and communication preferences.

Purpose: Sending newsletters, promotional offers, and Platform updates. Legal basis: Explicit consent. You may withdraw consent at any time using the unsubscribe link in any marketing email.

g) Cookies & Tracking Data

See our separate Cookie Policy for full details.

3. Who We Share Your Data With

We share personal data only where necessary for Platform operation. We do not sell personal data. Recipients include:

• Hosting & infrastructure providers — EEA-based servers or protected by Standard Contractual Clauses (SCCs);
• Brevo — transactional and marketing email delivery; EU–US Data Privacy Framework participant;
• Sightengine — automated image content moderation; US-based, protected by SCCs;
• Google Analytics — website analytics (only with your consent); Dublin-based;
• Meta Pixel — advertising measurement (only with your consent);
• Payment processors — EEA-based or SCC-protected;
• Law enforcement & regulatory authorities — when legally required or to protect against illegal activity.

All third-party processors are bound by Data Processing Agreements (DPAs) ensuring GDPR-compliant handling.

4. International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), we rely on one of the following mechanisms:

• European Commission Standard Contractual Clauses (SCCs);
• EC adequacy decisions for the destination country; or
• EU–US Data Privacy Framework participation (where applicable).

Sightengine (image moderation), Google Analytics, and Meta Pixel involve transfers to the United States, each covered by SCCs. You may request details of specific safeguards at contact@synden.com.

5. How Long We Keep Your Data

After the applicable retention period, data is securely deleted or irreversibly anonymised.

6. Your Rights Under GDPR

As a data subject you have the following rights:

• Right of access — obtain a copy of your personal data;
• Right to rectification — correct inaccurate or incomplete data;
• Right to erasure ("right to be forgotten") — request deletion where legally permissible;
• Right to restrict processing — limit how we use your data in certain circumstances;
• Right to data portability — receive your data in a structured, machine-readable format;
• Right to object — object to processing based on legitimate interests or for direct marketing;
• Right to withdraw consent — withdraw consent at any time without affecting prior lawfulness;
• Right to lodge a complaint — complain to a supervisory authority (see Section 7).

To exercise any right, contact us at contact@synden.com. We respond within 30 days. No fee is charged except for manifestly unfounded or excessive requests.

7. Right to Lodge a Complaint

You have the right to lodge a complaint with the Czech data protection supervisory authority:

If you reside in another EU member state, you may also lodge a complaint with the supervisory authority in your country of residence.

8. Automated Decision-Making & Profiling

The Platform may use algorithmic ranking to determine Ad placement order based on factors such as tier, boost status, activity, and relevance signals. This constitutes profiling but does not produce legal or similarly significant effects — it affects the visibility of your Ad only.

You may object to profiling-based ranking by contacting contact@synden.com.

9. Minors

The website erogreek.com is strictly for persons aged 18 and over. We do not knowingly collect data from minors. If you believe a minor has registered on the Platform, please report this immediately to contact@synden.com. We will delete the account without delay.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, services, or applicable law. Where changes are material, we will notify registered users by email or platform notice at least 14 days before the changes take effect. The current version is always available at erogreek.com/legal/privacy.php.