Privacy Policy

This Policy describes how Libertizy processes your personal data, in accordance with Regulation (EU) 2016/679 (GDPR) and French Law No. 78-17 of 6 January 1978, as amended (the “French Data Protection Act”, Loi Informatique et Libertés). Given the nature of the service, some of the data processed is sensitive data (relating to sex life or sexual orientation): it is subject to enhanced protection and is processed only with your explicit consent.

1. Data Controller

The data controller is the company that publishes the Libertizy website, Pixinov, a brand operated by the company Maxelik. Contact details: contact@libertizy.com. Full registration details are available in the Legal Notice. [To be completed by the publisher: legal form, share capital, RCS/SIREN registration number, and registered office address of the data controller.]

2. Data We Collect

• Identification and account data: e-mail address, username, password (encrypted), date of birth, and declaration of legal age.
• Profile data: profile type, description, approximate location, physical characteristics and, where applicable, preferences and practices freely provided by you — the latter of which may constitute sensitive data.
• Content: photographs, videos, exchanged messages, and editorial contributions you publish.
• Verification data: information provided to obtain the badge (control payment or video call).
• Transaction data: subscription, token, and listing history, billing data. Card data is never stored by Libertizy; it is processed directly by our payment provider.
• Technical data: IP address, connection logs, device and browser type, cookies, and trackers.

3. Purposes and Legal Bases

• Creating and managing your account, providing the service — legal basis: performance of the contract (Terms of Service/Terms of Sale).
• Processing of sensitive data (orientation, preferences relating to sex life) — legal basis: your explicit consent, revocable at any time.
• Managing payments, subscriptions, and billing — legal bases: performance of the contract and compliance with our legal obligations (in particular accounting and tax obligations).
• Verifying profiles, combating fraud and fake accounts — legal basis: legitimate interest in ensuring the security and trust of the community.
• Moderation, security, handling of reports, and abuse prevention — legal bases: legitimate interest and compliance with our legal obligations (the LCEN and the Digital Services Act (DSA)).
• Age verification for access to explicit content — legal basis: compliance with a legal obligation (the SREN law and the ARCOM framework).
• Sending information and the newsletter — legal basis: your consent (double opt-in), withdrawable at any time.
• Audience measurement and service improvement — legal basis: your consent for trackers that are not strictly necessary.

4. Retention Periods

• Account and profile data: for the entire lifetime of the account, then deleted after a reasonable period following account closure (a 30-day reactivation window is provided).
• Messages and content: for as long as necessary to provide the service, then deleted or anonymised.
• Connection logs: kept for up to one year, in accordance with legal obligations (the LCEN).
• Accounting documents and invoices: kept for ten years, in accordance with legal obligations.
• Proof of consent (age of majority, waiver of the right of withdrawal, marketing consents): kept for as long as necessary for evidentiary purposes.
• Data of suspended or banned members: kept for a limited period for the purposes of preventing repeat offences and managing abuse, before final deletion.

5. Recipients and Processors

Your data is never sold. It is accessible to our authorised teams (support, moderation) and to technical service providers acting as processors, under a contract compliant with Article 28 of the GDPR:

• Payment provider (Stripe): secure processing of card payments.
• E-mail delivery provider (Brevo): transactional e-mails and the newsletter.
• Hosting provider (o2switch, France): hosting of the site and data.

Some service providers may be established outside the European Union. Where applicable, such transfers are governed by appropriate safeguards (the European Commission’s standard contractual clauses or an equivalent mechanism). Hosting of the site’s data is provided in France.

6. Cookies and Trackers

The site uses cookies that are strictly necessary for its operation (session, security, language preference), for which your consent is not required, as well as, subject to your agreement, audience-measurement and functionality cookies. A consent banner allows you, from the moment you arrive, to accept, refuse, or configure non-essential trackers. You may change your choice at any time.

7. Security

We implement appropriate technical and organisational measures to protect your data: encryption of data in transit, access control, segregation, and enhanced protection of private media, served exclusively via a time-limited signed link and rendered non-indexable. Profile photographs and videos are not accessible via direct access and are blurred for visitors who are not logged in.

8. Reports

When you send us a report, we collect your email address, the name or nickname you provide, the description of the facts and the reference of the content or account concerned. This data is used solely to examine the report, to acknowledge receipt and to inform you of the outcome. A non-reversible technical fingerprint of your connection address is kept for the sole purpose of preventing abusive submissions; your connection address itself is never recorded. This information is kept for the duration of the review, then for no more than twelve months after the case is closed. The processing is based on our legal obligation to provide a notification mechanism and on our legitimate interest in ensuring the security of the service. You have the rights of access, rectification and erasure set out in section 9.

9. Your Rights

In accordance with applicable regulations, you have the right of access, rectification, erasure (right to be forgotten), restriction, objection, and portability of your data, as well as the right to withdraw your consent at any time and to set guidelines for what happens to your data after your death. Some of these rights can be exercised directly from your personal account area (editing and deleting your profile, managing consents, exporting your data). You may also write to us at contact@libertizy.com. We may need to verify your identity before responding, within a period of one month.

10. Data Protection Officer

For any question relating to the protection of your data, you may contact our data protection representative at contact@libertizy.com. [To be completed by the publisher: state whether a Data Protection Officer (DPO) has been appointed and, if so, their contact details.]

11. Complaints

If, after contacting us, you consider that your rights are not being respected, you have the right to lodge a complaint with the French data protection authority (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 — www.cnil.fr.

12. Changes to This Policy

This Policy may be updated to reflect changes to the service or to applicable regulations. The applicable version is the one published on this page. Last updated: [to be completed upon publication].

Governing Language

This page is a translation provided for information purposes only. Only the French version is authoritative; in the event of any discrepancy of interpretation between the French version and a translated version, the French version shall prevail. This document remains governed by French law.