Privacy Policy

This policy was last updated on August 23, 2024

What do we collect?

Types of information we collect may include:
- Email address and password
- Profile information you submit including, by way of example, your date of birth or age, images and videos, location, bio information, looking for information, gender and gender preference, height, weight, hair color, ethnicity, religion, living situation, profession, and income
- Purchase information such as hashed partial credit card number, date and time of transaction, amount of transaction and IP and device information from which the purchase is made
- Contacts with other users including interactions with other user's profiles, such information may include any images, chat, or videos you may directly send to another user through the Site even though such image is not posted to your profile
- "Friends" or "favorites" as identified by you
- Content purchased or sold through your account, as applicable
- Your device information (e.g., device model, operating system version, device date and time, unique device identifiers, mobile network information, and browser information)
- Government-issued photo identification
- Payment information
- Interactions related to your account including interactions with customer support, whether through CamSoda or another platform or service including, if offered, by telephone
- 2 factor authentication information
- Site browsing history, usage, and access time data and other analytical information using cookies or other similar technologies as described below
- Geo-location, including IP address
- Login and logout history

Electing not to provide any or certain information may limit the assistance, products, services or information we are able to provide.

How do we use the data we collect?

Profile information, friends/favorites, contacts/interactions with other users, content purchased and/or sold through your account (as applicable) and browsing history are all used to provide and maintain your account. This information may also be used in connection with fraud inquiries and identification.
Email address and password are used to identify and locate your account and to protect it from being accessed by others.
Device and IP history data are used for Site optimization as well as fraud detection.
Purchase history and data are collected in order to service your account with the Site as well to comply with payment processor and card issuer rules. The information in also retained in connection with fraud detection.
Your two factor authentication information will be maintained and used to secure access to your account.
Interactions related to your account, including with customer service, are used for business purposes including the ongoing provision of the site and support in connection with the site.
Government-issued photo identification are retained in compliance with applicable law including with respect to age verification.
Payment information and history are retained in compliance with law and record keeping requirements.
We may use certain information, as well as third-party providers who help us with our marketing efforts, to provide you with marketing content, to deliver relevant and targeted marketing to you, and to determine the effectiveness of our marketing.
We may use de-identified information to improve the Site.

How this information is shared

Generally speaking, your email address may be shared with a third party in order to service our relationship messages. Your email address will only be used by such third party in order to deliver to you messages like purchase confirmations, communications from other users and special deals from the Site.
In connection with chargebacks or other fraud issues, we may share your account, purchase, login and all other data in order to determine if a charge is legitimate or fraudulent.
As noted below, all profile information is shared through your account page and considered public, non-private information.
We may disclose certain de-identified information to providers and advertising networks in connection with marketing the Site.

Third Party Payment Processors

As and when you determine to make a purchase from the Site, you will be sent to a webpage where you will securely submit your payment information to one of our third-party payment processors. Such payment processor's handling of your data is outside of the terms of this Privacy Policy. In connection with such purchase, we will receive certain information, including a partial hashed copy of your payment information, together with the purchase you made.

Use of information by other users

This Privacy Policy does not relate to how other viewers/users of the Site may use or retain your information. You should consider all information and content visible through your profile public information. Further, you should consider any information you determine to share through chat messages, through any forums, interactions with other user profiles, interactions with your own profile, or any information you otherwise share with other users/viewers of the Site through any mechanism to be public information and not covered by this Privacy Policy.

Biometrics and Age Verification

Collection and Storage

This Biometric and Age Verification Collection and Storage Policy (the "Policy") last updated as of the date above relates to your submission of AV Documents to CamSoda (“we," "us," or "our") in connection with your use of the interactive, streaming video and text communication platform available through CamSoda.com (the “Site”). It is important that, prior to submitting any AV Documents to us, you fully review, understand, and agree to this Policy. As used herein "AV Documents" refers to all images you may submit to us either directly or through a third party intended to comply with our age verification requirements.
AV Documents Requirements

Currently we require that anyone who wishes to be eligible to receive digital credits from other users of the Site submit two clear color images. One image must be a clear, legible, color image of your valid, government-issued identification (the “ID Image”). The identification must contain, at a minimum, your date of birth, your legal name, and a recent and recognizable photo of you. Identification not containing this minimal information will be rejected. The second image must be a clear color image of you as you appear at the time you are submitting your image (the “Selfie”). Neither image may be altered, retouched, or otherwise altered or changed. If we, in our sole discretion, believe you may have in anyway altered or changed an image submitted in connection with your AV Documents, including through use of a filter, your submissions will be immediately rejected, and you may be terminated from the Site.

The Selfie will be shown in a secure internal portal, viewable to content review and age verification team members, for ongoing age verification and content review to confirm compliance with the Site’s Terms & Conditions. The Selfie and ID Image will jointly be visible in a secure internal portal viewable on a more restricted basis as needed in compliance with applicable law and any banking and card association requirements.

In connection with our review and evaluation of AV Documents submitted to us, either we or a third-party contracted by us, may generate biometric data based upon the AV Documents. If you do not wish to have your information used in line with this Policy, you must not submit AV Documents.

What is Biometric Data?

Biometric data is any biological characteristics of a person, or information based upon such a characteristic, including characteristics such as those defined as "biometric identifiers" and "biometric information" under the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq. "Biometric identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. "Biometric information" means any information, regardless of how it is captured, converted, stored, or shared, based on an individual's biometric identifier used to identify an individual.

Biometric Data We May Collect and Process

As briefly noted above, when you submit AV Documents to us, either directly or through a secure third party, including Jumio Corporation or Incode Technologies, Inc., a three-dimensional scan of your face geometry will be generated. Additionally, optical character recognition may be used in reviewing your ID Image data to generate text records related to such ID Image for age verification compliance purposes.

Why is Biometric Data Collected?

Your biometric data is generated and collected in furtherance of our age verification procedures and practices, which exist to prevent underage and other unauthorized use of the Site. This information is used to further ensure that the individual providing the AV Documents is the person depicted in such documents and the person accessing the account(s) with which such documents are associated.

How is Your Biometric Data Stored?

Your Selfie will be stored separately from your original AV Documents and made available through a secure, close-ended system to our compliance and age verification team to confirm that you are the person appearing through your account. Your ID Image will be stored separately in a secure system. Your AV Documents will only be reviewed by members of our team engaged in age verification, routine audits of previously submitted age verification, and as noted above, as necessary for compliance with applicable law and other requirements under our banking relationships and card association requirements. Any and all biometric data generated from your AV Documents (the "Biometric Data") is also stored securely and separately apart from your Selfie. The Biometric Data will only be used in connection with the age verification review process.

How Long is Your Biometric Data Stored?

Your Biometric Data will be retained for the same period as your AV Documents which documents are retained as required by 18 USC § 2257 and its regulations (the "Regulations"). As of the date this Policy is written, the Regulations require that the AV Documents be retained for a period of seven (7) years from the last time content was available through your account(s).

Unique Code

We reserve the right to, either directly or through a third-party, generate a unique code based on the AV Documents and Biometric Data to be used for internal account linking and in connection with the age verification process. To be clear, this unique code will not contain all or any part of your Biometric Data nor will it contain the data from your ID Image. The unique code permits for the easy association of accounts and updating your records as and when your identification is updated by you as required herein.

No Obligation to Accept AV Documents

Notwithstanding anything herein to the contrary, we reserve the right to specify which government-issued photo identification may be accepted based upon your location, our interpretation of applicable law/regulation and other requirements, and our sole determination of the reliability or risk of such documentation. We further reserve the right to require a second form of valid government-issued photo identification for further age verification as and when we determine appropriate, including based upon your location, our sole determination of the risk associated with any specific piece of documentation, and other factors we deem appropriate.

Your Responsibility Regarding AV Documents

You agree that you are responsible for updating and replacing your AV Documents as and when necessary, including, by way of example only, when your government-issued identification expires, if you move and update your address, if you have a name change, if you have your gender updated, your identification is revoked or destroyed, and/or non-insignificant changes in your appearance.

Non-Personal Information

We may disclose de-identified information for any lawful basis including to help us improve the Site.

Data Retention

All data collected from and about users is retained in compliance with our internal data retention policy in order to comply with applicable law, regulations, and obligations as well as for fraud detection purposes. If we receive a request to delete your personally identifying information, all information will be deleted in compliance with law and rules related to card issuers and payment processing.

For questions about data privacy, please contact our DPO as follows:
For EU persons: eudpo@camsoda.com
For non-EU persons: dpo@camsoda.com

To request a copy of your data or to request we delete your data, please contact our DPO as follows:
For EU persons: eudpo@camsoda.com
For non-EU persons: dpo@camsoda.com

California Residents

Under the California Consumer Privacy Act, California residents have a right to request a copy of the following:

The categories of information we have collected about you;
The categories of sources of the information we have collected about you;
The purpose for which we have collected such information about you;
A copy of the personally identifying information we have collected about you; and,
To be informed if we have sold or disclosed your personally identifying information to a third party and for what purpose.

Although we are not a California company, we will provide this information to California residents for free up to two times per twelve month period. When provided, the responsive information will be for the twelve-month period prior to the date of your request. For your privacy, prior to providing such information, we may require certain information from you to confirm it is the accountholder requesting such information. Also, to protect your privacy, responsive information will only be provided to the email address on file for your account.

If you are a California resident and would like to request any of this information, you may do so by calling us or emailing us as follows:

Toll-Free Number: 866-762-7270
Email Address: support@camsoda.com

Cookies

This Site, like many other websites, makes use of “cookies” (and other similar tracking technologies including pixels, scripts, and tags), which are small pieces of data placed on your device by the Site including by our third-party partners. These cookies and similar tracking technologies are used to track the activity on the Site and to store certain information to do things like track the advertiser who referred you to our Site, record when you have logged in so you don't have to keep re-entering your login information each time you click a link, allow us to suggest content you might enjoy based upon content you have previously viewed, tailor the advertisements you see, secure your account when someone has attempted to guess your password, and for analysis purposes to learn how all our users interact with our Site in order to improve our Site and Service. If you do not wish to use cookies, please check your security settings in your internet browser or contact your internet browser's customer support, however, this may cause some portions of the Site to become unavailable.

Withdrawal of Consent

If you would like to withdraw your consent at any time, you may do so by requesting account deletion. For fraud prevention, in order to request your account and/or data be deleted, you must be able to log into your account.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website and update the "Last Updated" date at the top of this Privacy Policy. We will also provide you with notice of the modification by email. If you disagree with the revised Privacy Policy, you may cancel your account. If you do not cancel your account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Website will be subject to the revised Privacy Policy.