Privacy Policy

Below, we explain you our Privacy Policy that describes how, under what legal conditions and why we treat the personal data of our users, always protected by our commitment to privacy and security of information of our users’ data, based on the principles of confidentiality, integrity, transparency, and availability.

Its purpose is that users of www.myescorthub.com.com (hereinafter, MYESCORTHUB.COM) are informed of the uses and processing of their personal data, including images of the user, where appropriate, if this provides, for the creation, edition, design and publication of an “Ad” as a companion or escort in MYESCORTHUB.COM, managing the registration as a registered user of the portal, as well as sending information and newsletters on information related to our services based on the legitimate interest of TUFFY DIGITAL SOLUTIONS LLC (hereinafter, TDS).

The Privacy Policy may be updated periodically to clarify or reflect new practices in the management of the privacy of our users or legal changes that may apply. All changes to the Privacy Policy will be notified to users through notices on its own website so that you have access and knowledge of them.

2.1. Data controller

(TDS) is responsible for processing your personal data, who collects, processes, and uses the personal information of the users of this Website (MYESCORTHUB.COM) in accordance with this Privacy Policy.

2.1.1. Data Protection Officer

Due to the type of data processed by TDS, and in accordance with article 37 of the GDPR, as the data controller, we must appoint a Data Protection Officer (DPO), whose data is made available to users:

E-mail: info@myescorthub.com

2.2. Situations in which we treat information about our users

2.2.1. When we collect your personal data:

We treat your data whenever:

• You visit our website.
• You contact us through the e-mail address or through the different contact forms available on the website.
• You interact, connect or link to our website through social networking tools, blogs or other websites.

2.2.2. What personal information we may treat:

We give you information about the data we may process when you interact with us:

• Personally Identifiable and Contact Information.
  We will treat your basic identification data (name and surname) and the contact data to locate you (e-mail and/or telephone) when you voluntarily provide them to us via e-mail and the different contact forms or other means of communication that we make available to you.
• Technical information about your device and internet connection.
  Through logs and other tools, we record information about the device and your internet connection, including the operating system used and other unique identifiers. This type of information is generally used in aggregate form to analyze how you use our website and the services offered through it, and to make improvements in our service.
• Information on the use of our services.
  We record the activity you carry out on the website, as well as the visits you make for the purposes of, among others, preventing fraud, improving our services and providing personalized services, recommendations and advertising.
• Location information.
  By using our services, you will have the possibility of using geolocation services that will allow us to better adjust the services we offer you.

2.3. Purposes of the processing of personal data

In view of the foregoing, and by virtue of the formalised relationship between the parties, the user is informed and accepts that his/her professional data, as well as those considered to be of a personal nature, are published in MYESCORTHUB.COM for the communication of the same to any person interested in accompanying or escort services.

TDS informs that professional data, as well as those that may be considered special categories of data according to regulations, including images or videos, communicated by the user, will be used for the following specific and concrete purposes:

• Contact the user.
  In the event that you use any of the forms available to contact us, and after accepting the privacy policy, you give us your consent so that the personal data and other information you provide us with in this form will be used to contact you and deal with queries, requests for information, complaints, suggestions and other questions that you put to us through the means available for this purpose (e-mail, contact forms, etc.).
• Process the registration in the portal as a registered user.
• Publish and publicly communicate in MYESCORTHUB.COM the personal data provided for the contracted service.
• Management, intermediation and administration of offers and published announcements.
  TDS will process the data of MYESCORTHUB.COM users who send communications and messages to the Advertisers through the web. In these cases, the data will only be used to manage such communication between Advertisers and users.
• Receive, manage and process requests received via content report channels. Upon receiving a request through this channel, TDS will check the veracity of the report and, in the event that irregularities are detected in its content, take the necessary measures to proceed to remove the content and take the necessary actions.
• Transfer of the “advertisement” to other related websites.
  Communication to related websites will only take place with those websites with which TDS has signed collaboration agreements. The lack of authorization on the part of the user to communicate the “Advertisement” to third parties may lead to the impossibility of providing the services in accordance with the quality standards and with the dissemination results expected by the user.
• Improve our services and statistics.
  We may also use the information you provide to analyze your use of our services and to obtain information about behaviors and interactions through the use of cookies. For more information, please see our Cookie Policy.
• Market Analysis.
  We may also use your data to analyse and understand market trends so that we can improve, develop and personalise our website and services. Such analysis may be carried out directly or through third parties who analyse such data at our request (such processing will be subject to the relevant data processing agreements which will guarantee the confidentiality and integrity of the data). This type of analysis allows us to intuit possible needs of our users that are then translated into promotional activities of our services in a more concrete and personalized way.
• Prevention of abuse and fraud.
  We will also use the data to control and prevent any form of abuse of our services, such as fraudulent activities, denial of service attacks, sending spam, unauthorized access to our users’ accounts, as well as any other practice that is contrary to the General Terms and Conditions of Use of our website.

2.4. Obligation to provide us with your personal information or not:

TDS informs that the delivery of all data required for registration as a user or for the publication of an advertisement is mandatory to manage the registration, insertion or publication of escort ads, offering the services as a companion, TDS may deny registration to the interested party who does not provide such data.

2.5. Requirements for the supply of personal data:

• Minimum age.
  To provide personal data via the website you must be over the age of majority (18 years).
• Third party data.
  If you include personal data of other people, you must inform them of the points contained herein and have their consent, prior to inclusion.

2.6. The storage period of your personal data

All your personal data will be treated and kept to the extent strictly necessary to comply with the law or the purposes we have indicated at the time of collection or for the duration of the contractual or commercial relationship, if any.

Once the data has been cancelled or the existing contractual or commercial relationship has ended, we may keep them for the period necessary to guarantee the exercise of our legal obligations and to resolve disputes.

In any case, when your data is no longer relevant to the purposes for which it was collected, it will be deleted or anonymised, including any registration or other backup information.

2.7. Data accuracy

The user is solely responsible, in any case, for the veracity of the data provided, TDS reserving the right to exclude from the registered services any user who has provided false, vague or inaccurate data, without prejudice to other actions that proceed in law.

The user expressly declares that the data, including images, sent to TDS are its property, assuming any liability generated otherwise.

For the purposes of this contract, the use of nicknames or pseudonyms to identify users on the portal shall not be considered untrue, provided that this does not constitute an obstacle to knowing the real identity of the users or to carrying out the corresponding charges for the services contracted to TDS.

2.8. User rights

2.8.1. As a user you can:

• Revoke the consent given for the processing of your data, at any time, when it has been the legitimate basis for the processing.However, withdrawal of consent shall not affect the lawfulness of processing based on consent prior to withdrawal.
• Require us to access any personal information we have about you and ask us to update, rectify or cancel it, where applicable.
• Ask us for the portability of your data and to transmit them to another data controller, where appropriate.
• Require us to refrain from further use of any personal data we have about you, and/or limit the treatment in certain circumstances.
• Oppose the treatment of your data.

Given that the links that we have enabled in emails that we send have the function of unsubscribing advertising if you want to make use of any of your rights you can direct yourself to us through the enabled links that you will find in emails and communications from TDS or through postal mail at the following address: Boulevard Shipchenski Prohod, Number 18, Floor 3, Office 301, Slatina, Sofia 1113, Bulgaria or info@myescorthub.com. Remember to provide as much information as possible about your request: Name and surname, e-mail address you use for the account that is the subject of your request.

2.8.2. Protection of rights before the Supervisory Authority:

In a case of violation of your right to the protection of personal data, you can contact the national Control Authority, which is the Bulgarian Commission for Personal Data Protection, to initiate the appropriate procedures in claim and/or defense of your rights.

2.9. Recipients of your personal data

In general, your personal information is confidential, so it is not shared with third parties. However, in certain circumstances it may be necessary to share your personal information when we are required to comply with a legal obligation or when providing services to you requires the use of service providers with access to the information, for example, providers of web-related technology services. Below, we inform you who are the recipients of your personal data:

2.9.1. Public bodies

We may disclose to the competent public authorities the Data and any other information in our possession or that is accessible through our systems and is required in accordance with the laws and regulations applicable to the case. All this in order to prevent abuse of services or fraudulent activities in the services provided through our website.

For this reason, the personal data you provide us with may be stored and made available to administrative or judicial authorities.

2.9.2. Service providers

TDS may have contracted different services with suppliers that access personal data. All suppliers have signed agreements for the processing of personal data, limiting their processing to the purposes of the service and always under the security measures established by current legislation.

2.9.3. International Data Transfers

TDS may use servers or cloud computing service providers located outside the European Economic Area, particularly in the USA, to host the web platform for managing the ads. In this respect, the selected suppliers will at all times comply with the maximum guarantees regarding the processing of personal data, in particular, certified in the Privacy Shield EU – USA. More information at www.privacyshield.gov.

2.9.4. Third Party Privacy Policies

This Privacy Policy only refers to the collection, processing and use of information (relating to personal data) by us through your interaction with our website. Other third party websites that you may access through links from TDS have their own privacy policies. We encourage you to be aware of the privacy policies offered by these third parties before providing them with any personal information.

2.10. Confidentiality and security measures:

TDS guarantees the maximum reserve and confidentiality of the communications carried out with the user, as well as the due and diligent treatment of the personal data given by the user.

TDS undertakes not to reveal any confidential information, nor to inform about any data object of treatment, except in cases in which the law expressly requires it, in the cases exposed in the section of Transfers or when they are required of the competent public authorities in accordance with the legal and regulatory provisions applicable to the case.

TDS has implemented the necessary security measures to ensure the effective use and processing of personal data provided by the user, safeguarding the privacy, confidentiality and integrity of them and makes use of the technical means necessary to prevent alteration, loss, unauthorized access or processing of their data, depending on the state of technology at all times, as well as the scope of control of TDS.

TDS may modify the content of its privacy policy at any time in accordance with any changes in legislation, case law or the interpretation of the Bulgarian Commission for Personal Data Protection that may occur.

This Privacy Policy was amended on 25 May, 2023.

3. Information about data protection

First layer

Second layer