PRIVACY POLICY

Welcome to LustCash’s Privacy Policy

Hi, this is Privacy Policy for LustCash Managed by:

Sky Internet Ltd, Kemp House, 160 City Road, London, EC1V 2NX, UNITED KINGDOM and welcome to our privacy policy. This policy sets out how we handle your personal information if you’re an LustCash user or visitor to our Sites. It applies across LustCash Elements, LustCash Market, LustCash Studio and LustCash Sites

When we say ‘we’, ‘us’ or ‘LustCash’, it refers to the management and staff of LustCash.

The term ‘policy’ shall refer to this Privacy Policy; and

User terms shall refer to the rules for using each of the Sites. The rules vary by product. This means that each product makes the rules separately available and seeks consent to them separately.

The type of personal information we collect

We collect personal information which is necessary for the protection of the client and of the system. We collect the following information:

  • user-names;
  • member names;
  • email addresses
  • IP addresses;
  • photos;
  • payment information

How we collect personal information

An automated system collects a user's information whenever he would access the website. The following instances are the ways when we collect your personal information such as, but not limited to:

  • When you complete membership registration;
  • When you buy or provide items or services on our sites;
  • When you subscribe to a newsletter;
  • When you subscribe to an email list;
  • When you submit feedback;
  • When you complete a survey; or
  • When you send us a communication.

How we use personal information

We will use your personal information:

  • In facilitating and processing transactions that take place on the Sites. This happens when the user would make a purchase on a subscription that is available on our marketplace.
  • Whenever you give us your consent and we need to do any of the following:
    • Provide our end users with marketing information about products and services which we feel may interest their specific needs based on their market behavior;
    • Customize any of our services and websites like the use of cookies which will give a better and more personalized experienced for our users.
    • For any purposes as may be required by law.
    • For the purpose of responding to requests by a competent court of law where the user is under investigation. We are not in any way liable for the sharing of your data for any kind of lawful purpose.
  • When necessary for protecting the interest of the sites and third parties, such as whenever we are:
    • Operating the Sites;
    • Providing you with services described on the Sites;
    • Verifying your identity when you sign in to any of our Sites;
    • Responding to support tickets, and helping facilitate the resolution of any disputes;
    • Updating you with operational news and information about our Sites and services e.g. To notify you about changes to our Sites, website disruptions or security updates;
    • Carrying out technical analysis to determine how to improve the Sites and services we provide;
    • Monitoring activity on the Sites, e.g. To identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;
    • Managing our relationship with you, e.g. By responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
    • Managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
    • Training LustCash staff about how to best serve our user community;
    • Improving our products and services.
    • Providing general administrative and performance functions and activities.

When do we disclose your personal information?

We will disclose personal information only to the following recipients:

  • Any third party users affiliated to the website, the companies that are in the LustCash group, its subsidiaries, and those otherwise financially connected to the group;
  • Authors of any items or services made available to the end user. Personal information shall be used here in order to facilitate support and license validation, including the location of the users;
  • Those providing website and communication facility services such as, but not limited to the following providers:
    • Government regulators in compliance with the regulatory requirements of the government;
    • Identification verification services located in Europe. Nothing that our subcontractors and services providers may also transfer and access such;
    • Information from other countries in which they have operations.
    • Marketing and analytics services which are located in Europe;
    • Payment processing services which are located in the US, Europe and Australia;
    • Security and fraud prevention services which are located in the US and Europe;
    • Subscription management services which are located in the US and Europe;
    • Technical and customer support services which are located in Europe, Australia and Mexico;
    • Website hosting providers which are located in Australia, US and Europe;
  • Company consultants such as our IT experts, legal experts, and anybody under a consulting contract with the company.
  • A potential purchaser of our products and our assets in case of dissolution;
  • A third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity that involves the specific user, as long as there is a court order;
  • A third party, in order to enforce or defend our rights, or to address financial or reputational risks;
  • A rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
  • Other recipients where we are authorized or required by law to do so.

Where we transfer and/or store your personal information

  • The company is based in Europe and in the US so data processing will comply with all of the regulations that the two countries require. General Data Protection Regulation is followed.

    Some of the recipients described in the section above may be based on other countries such as Canada, Philippines, Mexico, Europe, and the US. We do not disclose information without consent.

    In order to fully protect the information of our users, data security compliance and agreements are put into place.

How we keep your personal information secure

  • Secure servers managed by the system and service providers help store any kind of personal information. We occasionally keep hard copies of our files. All of our files are located in Australia, US, and Europe. Any kind of stored personal information is protected in a handful of manners such as:
    • Username and password authentication;
    • Two-factor authentication; and
    • Data encryption where appropriate.

How you can access your personal information

  • Personal information can be accessed by logging into your account. We do not limit a user’s access to his own account where he can also make corrections on any personal information that we store.

    Cancellation of accounts and correction of any errors in data could be done with our support team.

  • Cookies are also controlled by the user. This is accessed and modified through the browser settings and preferences. The user can choose to accept and reject cookies but if the user rejects some parts, the site may not work as intended.
  • Email marketing and newsletters are part of our way of reaching out to users. Should you want to opt out of the list, you can do so by hitting the unsubscribe button.

Cookies and web analytics

  • For more information about how we use cookies, web beacons and similar technologies see our cookie policy on the terms and conditions and for more general information on cookies, see http://www.allaboutcookies.org.
  • When you visit our Sites, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
    • The date and time of your visit to the website;
    • The length of your session;
    • The name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
    • The number of times you access our site within any month;
    • The operating system which your computer uses.
    • The pages which you have accessed;
    • The website which referred you to our sites; and
    • Your IP address or proxy server IP address’;

Information you make public or give to others

  • LustCash shall not be responsible for any improper way that the user gives access to his personal information. When there is proof that a user has provided his personal information outside of the system, we are not in any way responsible for any breach. Sending a message and writing a personal description are some of the ways of sharing such personal information.

    With that, we advise all of our users to think carefully. If giving information to another user via our Sites, ask them how they will handle your information. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

How long we keep your personal information

  • As long as it is necessary in order to provide proper services to the users, we shall retain all personal information. If the user no longer wants to use the user, he can request to close his account and erase any kind of personal information.

    Users should note that if he makes a request for deletion of account, the Sites will retain part of the information that would be necessary to any of the following:

    • Assist with legitimate investigations;
    • Collect fees;
    • Enforce the terms of service;
    • For our legitimate business interests;
    • Prevent fraud;
    • Resolve disputes;
    • Take other actions permitted by law.
    • To comply with the law; and
    • Troubleshoot problems.

    All retained information shall be subject to this Privacy Policy.

When we need to update this policy

  • This Privacy Policy shall be updated based on the needs of the Sites and as required by existing rules and regulations.
  • All of the users will be notified about such changes via email, where required. A copy of the latest version of this policy will always be available on this page.

How you can contact us

  • It is important for us to make this Privacy Policy as inclusive as possible, for any request for change, we are always open.
  • If you want to contact us and let us know what you think about our policy, you can do so via our support team.

If you’re a user or visitor in the European Economic Area these rights also apply to you:

  • For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information. As data controller, we comply with all of the requirements set forth by the GDPR.

How you can access your personal information

  • If you have unresolved concerns you also have the right to complain to data protection authorities. The authorities you can become in contact with should be the authorities of your residence, of where you work, or of any place that you habitually feel that your data privacy is being threatened.
  • Whenever the Sites requires any of your personal information to comply with legal or contractual obligations and you fail to provide such data, then you cannot exercise all of the rights given to those who comply with the requirements.
  • The limitation to your rights would include the right of the Sites to retain some of your data even if you have already withdrawn your consent.
  • Data portability is also given to our users. They can erase, restrict, and demand the way that the data is processed. The user also has the right to object to some processing if he thinks that he is not happy with the usage such as when it is used for purposes of direct marketing.

Both personal information and personal data have the same meaning in the context of this Privacy Policy.

LustCash Privacy Policy v1, effective date 01November 2018