Privacy Notice

Last Modified: August 8th, 2024

Introduction

Aylo Freesites Ltd (hereinafter “we”, “us” or “our”) operates the website brazzers.xxx (hereinafter “Brazzers.xxx”) and is the controller of the information collected or provided via Brazzers.xxx.

Please read this Privacy Notice carefully, as your access to and use of Brazzers.xxx signifies that you have read and understand all terms within this Privacy Notice. We respect your privacy and are committed to protecting your personal data.

If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.

  1. Scope

For the purposes of this Privacy Notice, “process”, “processed” or “processing” means any operation or set of operations performed on personal data or on sets of personal data (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure, or destruction. Information on disclosure of personal data or of sets of personal data may be found in the “Disclosure of Your Personal Information” section below.

This Privacy Notice applies to information we process:

  • on Brazzers.xxx; and
  • on your communications with Brazzers.xxx via email, or otherwise;

 

  1. The Data We Process About You

We may process different kinds of personal data about you:

  • Contact Data: We will only process your email address or any other information which you voluntarily provide to us at your direction for a specific function, namely, to participate in a contest or survey.
  • Communication Data: We process Contact Data and other information that you send to us via email, information provided in the context of support requests or any other inquiries, the content reporting and moderation of content, and our internal complaint handling system.
  • Website activity data: We process information about how you use Brazzers, products and services and interact with content and advertisements, including the pages you visit and search history on Brazzers, and the referring web page from which you arrived on Brazzers from. We process browser and operating system information, devices you use to access Brazzers and your time zone setting. We also process online identifiers. Specifically, we process internet protocol (IP) address information, and we set cookies as explained below in the section on “Cookies and Automatic Data Processing Technologies”.
  • Identifiers: Some users may be asked to provide identifiers (including government-issued photo identification as well as other documentation) to verify that they are over the age of majority required to have access to Brazzers and to view its contents. In such cases, this information is processed by trusted third party age verification service providers. This Privacy Notice does not apply to the privacy practices of these third-party age verification service providers. Read the privacy terms and conditions of these third-party service providers carefully.

We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.

Brazzers prohibits minors from using the platform. Brazzers.xxx is forbidden for persons under the age of 18 years old or the applicable age of majority in the jurisdiction from which Brazzers.xxx is accessed. As indicated throughout this Privacy Notice, some users may be asked to provide some information to us and our service providers for us to make sure that you are over the age of majority required to have access to the Brazzers.xxx. We do not knowingly process personal information from minors.

  1. The Sources from Which We Collect Personal Information

We collect personal information in the following ways:

  • Directly from you: We collect the categories of information listed above directly from you.
  • Automated technologies or interactions: As explained in the section below on “Cookies and Automatic Data Processing Technologies”, we set cookies and other automatic techniques to process website activity data when you visit Brazzers.xxx.

 

  1. Purposes for Which We Process Your Personal Information

We process personal information for the purposes described below.

  • Provision of services: We process identifiers, website activity data to present Brazzers.xxx and its contents to you, including any interactive features on Brazzers.xxx, to provide you with information and products or services that you request from us, to verify your eligibility and deliver prizes in connection with contests and sweepstakes.
  • Customization of content: We process identifiers and website activity data to analyze your use of, or interest in the content, products, or services, to display content and advertising tailored to your interests on Brazzers.xxx.
  • Communications and handling of requests: We process Communication Data and other information as necessary to respond to and resolve any of your requests, including where this is required to ensure compliance with our legal obligations.
  • Analytics: We process identifiers and website activity data to determine whether users of Brazzers.xxx are unique, or whether the same user is using Brazzers.xxx on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.
  • Functionality and security: We may process any of the categories of data we process to diagnose or fix technology problems, to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
  • Platform Safety: To promote safety and security on Brazzers.xxx. We use the information we collect to help protect Brazzers.xxx users from harm and provide safe, secure product.
  • Compliance: We may process any of the categories of data we process to enforce, this Privacy Notice, our terms and conditions and to comply with any legal obligations, namely but not limited to responding to your data subject requests, verify the age of some users having access to Brazzers.xxx, to respond to content reports, and to comply with applicable content moderation and complaint handling obligations.

 

  1. Our Legal Bases under Canadian and European Union (EU) Privacy Law

To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your personal data only where:

 

  • You provide your consent to do so for a specific purpose: for example, when you allow us to show you personalized ads or to send you e-mail marketing. You may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
  • It is necessary to perform our contractual obligations as per our Terms of Service on Brazzers.xxx.
  • It is necessary to comply with legal obligations: for example, we may be required to collect, use, or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters, or litigation.
  • It satisfies a legitimate interest which is not overridden by your data protection interests: for example, to keep Brazzers.xxx safe and secure from fraud and illegal activities.
  • It is used to protect your or others’ vital interests: for example, in case of emergency or to prevent a crime or fraud.
  • It is used for tasks carried out in the public interest: for example, to combat unlawful behaviour where it is in the public interest to do so and where the public interest is laid down by applicable law.

Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.

 

  1. Disclosure of Your Personal Information

We disclose your personal information when necessary to perform the services or for other purposes set out in this Privacy Notice. When we disclose your personal information, we usually rely on the performance of our contract with you as per our Terms of Service, our legal obligation to do so, our legitimate interest (e.g., operating Brazzers.xxx), so long as it doesn’t outweigh your interests or your consent, except when expressly stated otherwise below in the paragraph “To comply with the law or protect our rights or the rights of third parties”. Disclosure of your personal information may also involve transfers of your personal information outside the EEA. To the extent that we need to transfer personal information outside the EEA, we will do so according to the section “Transfers of Your Personal Information to Other Countries” or when necessary for the performance of the services and obligations under the present Terms of Service. The parties to whom we may disclose your personal information include:

  • Our contractors and/or employees: To provide our services to you, our employees and/or contractors may receive access to your personal data only on a need-to-know basis. Such employees and contractors abide by confidentiality obligations.
  • Our corporate group: We may disclose any of the categories of personal information that we collect to members of our corporate group, to the extent this is necessary for the purposes described in this Privacy Notice and generally to operate our business, which includes: customer support, facilitate business development, provide IT, technical and engineering support. You acknowledge that in some cases, members of our corporate group might be established or operate outside the EEA.
  • Service providers: We disclose certain categories of personal information to third party service providers to assist us or perform certain services on our behalf. These third-party service providers may have access or use your information only to perform these tasks on our behalf, such as risk and fraud detection and mitigation, customer service, advertising, analytics, security, hosting or supporting Brazzers.xxx functionality. These service providers may have limited access to personal information needed to perform their functions but are not permitted to process such information for any other purposes. Where required under applicable laws, we have entered into data processing agreements with such service providers to ensure that personal information is only processed securely within our instructions.
  • Legal successors: We may disclose all categories of personal information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Such transactions may be in our legitimate interest, particularly our interest in making decisions that enable our business to develop.
  • To comply with the law or protect our rights or the rights of third parties: We access, preserve and share personal information with regulators, public authorities, law enforcement, government agencies, out-of-court dispute settlement bodies or others where we reasonably believe such disclosure is needed to:
  1. comply with applicable laws, regulations, court orders, government or public authority requests;
  2. enforce applicable Terms of Service, including prevention of potential violations thereof;
  3. detect, prevent, or otherwise address illegal or suspected illegal activities, security, or technical issues;
  4. protect against harm to the rights, property or safety of our company, our users, our employees, or others; or
  5. to maintain and protect the security and integrity of Brazzers.xxx or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose your information to third parties for the above purposes when necessary to comply with legal obligations, perform a task in the public interest (where the public interest is laid down by applicable law), or under our legitimate interests and the interests of the public, including as part of investigations or regulatory enquiries to detect, investigate and prosecute illegal activity.

 

  1. Cookies and Automatic Data Collection Technologies

As you navigate through and interact with Brazzers.xxx, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit Brazzers.xxx.

We currently use the following types of cookies, which are set by Brazzers.xxx:

  • Strictly necessary cookies:These are cookies that are required for the operation of xxx. These include, for example, cookies that enable a user to visit Brazzers.xxx and to check if a user is allowed access to a particular service or content.
  • Functionality cookies:These cookies help us to personalize and enhance your online experience on xxx. This type of cookie allows us to recognize you when you return to Brazzers.xxx and to remember, for example, your choice of language.
  • Analytics cookies:These cookies allow us to recognize and count the number of users and to see how users use and explore xxx. These cookies help us to improve Brazzers.xxx, for example by ensuring that users find what they are looking for easily. Additionally, we use third party session recording technologies that help us better understand our users’ experience, however, the recorded data is pseudonymized.
  • Targeting and Advertising cookies:These cookies record visits of a user on xxx, the pages a user visits and the links a user follows to enable us to make Brazzers.xxx more relevant to the user’s interests and to help us serve ads that might be of interest to the user.

Analytics, Functionality and Advertising/Targeting cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of Brazzers.xxx. However, if you decline to accept these cookies, some functionality on Brazzers.xxx may be disabled and can interrupt your access to certain parts of Brazzers.xxx.

Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.

Do Not Track: Our systems do not recognize browser “Do Not Track” signals.

Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use Brazzers.xxx, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only to provide Google Analytics services to us and will not use this information for other purposes. In addition, Brazzers.xxx uses Google Signals, which are also services provided by Google that help us to run remarketing campaigns, collect more accurate data, and understand in a better way how users engage with Brazzers.xxx on different devices (cross-device activity). Google Signals applies to Google users who accept personalized advertising on their Google accounts. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the  Google Analytics opt-out page or by accepting only necessary cookies.

 

  1. Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on Brazzers.xxx are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party features on Brazzers.xxx or directed to such third-party website. Unless expressly stated otherwise, Brazzers.xxx does not provide any personal information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access Brazzers.xxx to provide targeted content.

You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.

 

  1. Your Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us.

  • You can choose not to provide us with certain personal information, but that may result in you being unable to participate in a contest, promotion, survey, or sweepstakes, communicate with our support teams or initiate other activities on Brazzers.xxx.
  • The Cookie Banner can be utilized to customize your cookie preferences. The Cookie Banner will record when you have consented to our cookies. Your Cookie Banner selection will be kept only for the specific session. The Cookie Banner specifically controls the functionality, analytics, and advertising cookies set by using Brazzers.xxx. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from our website. You can access the Cookie Banner anytime by clicking on the ‘Manage cookies’ option that is located at the footer of Brazzers.xxx.
  • Where we provide personalized services, we may analyze the information you supply, as well as your activity on Brazzers.xxx so that we can offer a more relevant, tailored service. For instance, we could use your videos you watched to provide personalized content recommendations or ads. If you do not want to receive these services, you can switch off the recommendations toggle on the “Personalized Recommendations” page or via the bar at the left of our page.

 

  1. California Rights and Choices

As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, Consumers have the right to:

  • Opt-out of the sale of their personal information, should we sell their personal information;
  • Be informed of certain information concerning our collection and use of their personal information;
  • Request that we delete certain personal information we collected from them;
  • Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
  • Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

Brazzers.xxx does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable consideration. We may however disclose certain personal information with third parties, service providers and entities within our corporate group to enable them to perform certain services on our behalf, and namely to make Brazzers.xxx function properly, as further described in the section above titled “Disclosure of Your Personal Information”.

We respect California residents’ right to exclude personal information from such sharing arrangements and grant them the option to opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to exercise your rights, please use the buttons at the bottom of this page or email us at [email protected]  with the email subject line “CCPA Request”.

In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: any information which we may reasonably request in order for us to verify your identity.

You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.

 

  1. Resident’s Rights – Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange your personal information with anyone for money.

 

  1. Notice to Law Enforcement

The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:

  • The document(s) is uploaded, and all required fields have been filed out adequately on our platform for Legal Service Process located at: https://legalservice.aylo.com/legal/datarequest;
  • The document(s) you are serving is correctly issued to Aylo Freesites Ltd by a valid court of law or equivalent legal or administrative authority to us;
  • The document(s) is also sent by mail at the following address: 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540.

We reserve the right to refuse online service through Brazzers.xxx, namely in cases where the above requirements are not met and require formal legal service at the above address. In such an event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.

 

  1. Transfers of Your Personal Information to Other Countries

We may share the information we collect globally, across our corporate group and with our service providers and other third parties. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms of Service and this Privacy Notice to fix, analyze, and improve our website, products and services. Whenever we transfer personal information to countries outside the EEA and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Notice, as permitted by the applicable laws and based on appropriate mechanisms.

Where applicable, we rely on decisions of the European Commission, known as “adequacy decisions,” recognizing that certain countries offer a level of protection of personal data that is essentially equivalent to the EEA.

In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.

 

  1. Retention of Personal Information

We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider several factors, including what personal data we are processing, the risk of harm from any unauthorized disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, we will delete it from our systems.

For more information on data retention periods, please see the section “Contact Information” below on how to contact us.

Where permissible, we will also delete your personal information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.

 

  1. Third-Party Links and Sites

If you click on a link to a third-party website, you will be taken to websites we do not control. This Privacy Notice does not apply to the privacy practices of these websites. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.

 

  1. Changes to Our Privacy Notice

We may modify or revise our Privacy Notice from time to time. We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our Privacy Notice, which will be posted at this location, so you are aware of any changes, the date of change will be reflected in the “last modified date” mention.

 

  1. Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us at [email protected].

You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.

 

  1. Your Rights Related to Your Personal Information

Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your personal data:

  • Right of access: you have the right to receive information on the personal data we hold about you and how such personal data is used, as well as a copy of your personal data;
  • Right to rectification: you have the right to rectify inaccurate personal data concerning you;
  • Right to be forgotten: you have the right to delete/erase your personal data;
  • Right to data portability: you have the right to receive the personal data provided by you in a structured, commonly used, and machine-readable format and to transmit this personal data to another data controller;
  • Right to object: you have the right to object to the use of your personal data where such use is based on our legitimate interests or on public interests;
  • Right to restriction of processing: you have the right in some cases, to restrict our use of your personal data; and
  • Right to file a complaint: If you are in the EEA or the UK, you also have a right to file a complaint with your local data protection authority.

If we ask for your consent to process your personal data, you have the right to withdraw your consent at any time with effect for the future. Note that, in that case, you may no longer able to use several functionalities on Brazzers.xxx or access Brazzers.xxx in some cases.

 

You can exercise your rights by sending us an e-mail at [email protected]. Please note that we have one month to respond to your request.

 

Prior to processing an access or deletion request of your data, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that personal data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way. Please note that in some cases, we may not have sufficient information to identify you and therefore may not be able to satisfy your request. Additionally, in some cases, to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.