- an email address
- a username
- a password
Last modified: July 22, 2021
Table of Contents
- Who Decides "How" and "Why" Your Personal Data is Processed?
- What Personal Data do We Process?
- Why do We Process Your Personal Data?
- How do We Protect Your Personal Data?
- How long do we retain your personal data?
- With Whom do We Share Your Data?
- Your rights under GDPR
- Information for California Residents
- How to Contact Us?
When you decide to register on Oranum and use our services, we will collect some of your personal data.
Please be assured that we are fully dedicated to the protection of your personal data.
We operate our site and our services in compliance with applicable data protection laws, including the EU General Data Protection Regulation (“GDPR“) and the California Consumer Privacy Act (“CCPA“). For more information, please see Section 7 “YOUR RIGHTS UNDER GDPR“. If you are a California resident, please also see Section 8 “INFORMATION FOR CALIFORNIA RESIDENTS.“
You can contact us if you have any questions about our privacy practices or about what we are doing with your personal data. We will be happy to assist you in any way we can.
Who Decides "How" and "Why" Your Personal Data is Processed?
The following companies decide how and why your personal data is processed, and for GDPR purposes, are “Joint Controllers”:
JWS Americas S.à r.l.44, Avenue John F. Kennedy, L-1855 LuxembourgGrand Duchy of LuxembourgRegistered with the Luxembourg Trade and Companies Register under the number: B 249539.
JWS International S.à r.l.44, Avenue John F. Kennedy, L-1855 LuxembourgGrand Duchy of LuxembourgRegistered with the Luxembourg Trade and Companies Register under the number: B 249539.
What Personal Data do We Process?
We collect, use, share, transfer, and store different types of your personal data as a result of your visit of and/or use of our services on our site.
The personal data we collect includes the following:
Personal Data You Provide
When you create an account on our site, we require important details including:
Billing Support & Customer Support
We collect all information you choose to share with our Billing & Customer Support Teams, like:
- your personal e-mail
- the services, the Expert or username associated with your request
- your comments or opinions about an Expert
- your conversations with the Support Team
More generally, when you communicate with us in any other way, we will collect whatever information you choose to provide.
When you purchase coins to participate on our site, depending on the payment method you choose, we may collect and process your identification information (full name, country, ZIP code) and payment information. As regards your payment information, note that we only store the last four digits of your payment card number and the expiration year/month.
Personal Information from Site Use
We collect and process certain information about you when you are using our services and our site.
This means that, when you visit our site or use our services, even if you have not created an account or logged in, we collect certain information, including:
We collect information about your activity on our site and about how you interact with features on our site. If you are a Member, we may link this information to your personal identity (e.g. for fraud detection purposes). The data we collect includes:
- Activity history
- Special features used, e.g.,
- Rated a Broadcaster
- Added a Broadcaster to your favorites
- Video/Voice Call with a Broadcaster
We collect information about your conversations with Broadcasters, including:
- Broadcaster screen name
- Time and date of communication
- Method of communication (e.g. Messenger etc.)
For technical purposes, to prevent violation of our Terms & Conditions and to defend against complaints and legal claims, we store on our system the chat logs and may review them.
In case you turn on your camera or microphone in private chat, we never record or keep in any way your camera feed or audio. We also do not allow Broadcasters to record or capture your camera or audio feeds during private shows. Such action is prohibited on our site.
Please note that when you are using Video/Voice Call to contact offline Broadcasters, your conversation is not recorded or stored in any circumstances. Please be advised that we are not responsible for your experience or the content of these private calls.
Log Data & Device Information
We automatically collect log data and information from/about your computer, phone or other device you use to access our services/site, including:
- IP address
- Date and time you logged in
- pages viewed
- Features used
- Hardware / Software / Internet browser used
- operating system / application version used
- Cookies / other technologies that may uniquely identify your device / browser
If you are using a mobile device, we might also collect:
- data that identifies your mobile device
- device-specific settings and characteristics
- location details
- app crashes and other system activity
Cookies / Other Technologies
For cookies which are not considered as necessary for the use of this website, we ask your explicit consent before placing these on your device (i.e. the banner that was displayed on your device when you entered our website for the first time). Keep in mind, though, that blocking cookies may negatively affect your experience on our site.
Data Collected by Third Parties
The following are situations where your personal data has been collected by a third party:
When discussing with our Billing Support and Customer Support teams, a Broadcaster may provide some information about you, which will be collected.
External Partners' Ad Networks
Partner ad networks help us to promote our site. They may collect information about your interactions with our ads on our behalf.
Internal Partner Ad Network
Our group manage an ad network and promotional tools/programs. Third parties affiliated partners may contact us with information about your interactions with our ads and promotional tools published/used on their sites or affiliated sites (i.e. sites with partial or full reproduction of our primary site).
Public Personal Data
We collect publicly available information about you only when it is necessary to prevent fraud and illegal activities on our site (e.g., when we suspect that you are using a false or stolen credit card, when we witness child abuse cases, or pedophile activity, etc.).
This data may comprise publicly available information you share on social media like Facebook, your blog and/or site, and any other public data available on the internet.
This information is always associated or combined with the data we collect through our site to finalize our investigation before reporting any fraud and/or illegal activity to the authorities. We never use publicly available data for any other purpose.
Special category of data
This means data of a sensitive nature, the exposure of which would significantly impact your fundamental rights and freedoms; for example, it could be used against you for unlawful discrimination (e.g., your philosophical or religious interests/beliefs).
When you use our site and purchase services (e.g., live cam, private chat, buy a Broadcaster surprises, etc.), we process and store sensitive information related to your activity (e.g., the Broadcaster category, the content unlocked, etc.) in order to provide you with the services you requested.
Due to the explicit meaning of each category name (e.g. Chinese astrology, reiki, clairvoyance, angel communication, etc…), as well as the types of Broadcasters you request services from, it is possible, although not certain, that the chosen categories indicate your philosophical or religious beliefs.
You may revoke your consent regarding this processing by contacting the Support Team as indicated in Section 10 “HOW TO CONTACT US?“. However, please note that such revocation means that you will not be able to log into your account and use the services, as we will not be able to provide you with the services without processing such information.
We understand that the information we have about you may not explicitly reflect the reality of your life outside of the site. Your online preferences may only show a punctual interest. In order to provide you with the utmost level of data protection, we categorize such type of data as sensitive, which is highly protected and handled with the utmost care.
Because your online philosophical or religious interests and other data related to them are essential aspects of privacy, we are maintaining very high technology security standards. We are regularly proceeding with controls and assessments of our security measures, to guarantee a trustworthy environment.
Why do We Process Your Personal Data?
We use the information we collect for the following purposes:
- Basic information
We primarily use the data you give us when creating your online account to open and manage this account. The account then allows you to use features, buy coins and benefit from and paid services.
Your account will also allow you to exercise control over your personal data. Through your account, you can manage your purchases, benefit from special offers, and manage your account settings.
We process this information to perform the contract that we have with you and provide you with the services you request. If you fail to provide the minimum details required, we will not be able to create your account and allow you to use our services.
- Basic information
Improve and promote our services
To understand how we can improve our services and find better ways to promote our services to others, we collect your personal data for the following purposes:
- Analytics & Statistics
We use the information you provide us with and that we collect ourselves to detect general trends regarding the preferences/habits of our users. This helps us to generate statistical reports on our customers' activity including those based on country and purchases. The information in these reports is in aggregate form and cannot be used to identify individuals.
We use your data for testing, troubleshooting and improving the functionality and quality of our online entertainment services. Our main goal is to optimize our site and services, making them easier and more enjoyable to use.
We also use your log data to provide search functionality and display the results of your search. In order to make our services useful, the rank and the relevance of the results obtained may be improved based on attributes we determined (e.g. the newest content published by Broadcasters, the live status of Broadcasters).
As mentioned in Section 2.3 , we have external partners who help us to promote our sites.
We process this information with the legitimate interest of developing and improving our site and users' experience, as well as promoting our site and services.
- Analytics & Statistics
Customer Relationship Management
Customer relationship management is key to any service and included in this term is any contact we have with you. The following are related instances where we collect and process your personal data:
Customer Support & Billing Support
Customer Support and Billing Support operates 24/7. By sharing your personal data with our Customer Support and Billing Support teams, we will be able to provide you with your answers, and any help you may require, more efficiently.
All your communications with the teams and any information you provide, including comments about our Broadcasters, are stored and reviewed so that we may respond to your request. This way we can ensure the full compliance of all users with our Terms & Conditions.
Some of the recorded communications with you will be used for training purposes within the Customer Support and Billing Support Teams, so that we can provide you with excellent customer service.
Please be aware that our Customer Support and Billing Support teams will have access to all information that has been collected about you. By having this access, we ensure that our Customer Support and Billing Support teams have everything they need to give you an appropriate and efficient response.
Please note that Customer Support and Billing Support will use various means to contact you including email and phone, as appropriate.
Please note that we may contact you through emails or other appropriate means, to inform you of any changes regarding our site or announcements relating to your subscription (e.g., successful account creation).
We have a legitimate interest in improving our users' experience and delivering appropriate customer services to you.
We use your identification data and payment information to process transactions. This may depend on which payment method you choose, but is case for most methods.
Please note that depending on the payment method you choose, your payment will be processed by affiliates of our group or third party payment processors/service providers as explained in section 6.5 “Payment providers and financial institutions".
The use of your personal data is strictly necessary in this instance in order to execute any payments and provide you with the credits or services you have purchased (i.e. to perform the contract we have with you).
Ensure a safe and Trusting Environment
To protect you and our business, we use your personal data in the following ways:
- To detect and prevent fraud/illegal activities.
- To detect potential breaches of our Terms & Conditions and any other relevant rules
- For security & risk assessment (e.g., authentication & verification of identity)
We have a legitimate interest in keeping you and our business safe and ensuring compliance with the T&Cs/rules, which attempt to guarantee this.
Marketing / Information messages
Generally, when you sign up to use our sites, we will send you informative messages and marketing to keep you up to date with the release of new features and/or services, special promotions, offers, etc...
To evaluate the success of our marketing initiatives, we may pseudonymize your email address and use it to generate statistics. These would be in the form of aggregated data, not personal information (e.g., number of users per country who receive marketing communications).
Your email will be further used to send survey participation requests, so that we learn more about your experience and satisfaction or suggestions for improvements to our service.
We have a legitimate interest in keeping you informed and in the outcome of our marketing campaigns. You can, of course, unsubscribe from receiving our marketing and informative emails at any time, using a link contained within the emails themselves. You can also opt-out contacting the Support Team as indicated in Section 10 “HOW TO CONTACT US?“. However, this may mean that you miss out on special offers and information regarding new services.
Comply with any legal requirements and enforce our legal rights
We may rely on a legal obligation to process your personal data. For example, we must retain your transaction information to maintain legally required accounting records.
We may also use your information to respond to requests from competent authorities or given our legitimate interest to establish, exercise or defend legal claims. If necessary, we would use your data to investigate issues with the relevant bank processing your payment, or with a debt collector, in cases of unpaid transactions, chargebacks or refunds.
We may also combine your data with information lawfully obtained from other third-party sources, for the above purposes.
How do We Protect Your Personal Data?
We implement various security measures, technical and organizational, to ensure the protection of your personal data against unauthorized access, modification, disclosure or deletion.
We periodically test our IT systems, conduct penetration tests and implement data loss prevention systems against leakage, theft and data breach.
Our site incorporates reasonable security technologies in order to ensure the safety of its users and the safekeeping of their related information.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We do not normally retain personal data of Guests for more than ten to fifteen days, though this period is typically shorter (depending on traffic volume). Any information collected to verify your identity in connection with a request (e.g., a request to access your data) will only be kept for a short time, typically no more than five days. Otherwise, we will retain your personal data for as long as we consider it necessary:
Provision of Services
To enable us to provide you with our services and for you to use them, including maintaining your member account.
Legal Obligation Compliance
For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that in accordance with Luxembourg legislation, financial information will be kept for a minimum period of 10 years (even though shorter retention periods may apply as the case may be).
Legitimate Interests and Business Conduct
- Establishing, exercising or defending legal claims
We retain your chat logs and log data, device and usage information for a maximum period of 120 days from your last purchase on the site.
Fraud/illegal activity detection and prevention:
We blacklist all former usernames for a certain period; these usernames will not be available for new registrations during that time.
For example, if we suspend or close your account due to fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information will also be kept available in case of ongoing judicial proceedings and/or investigations.
As we have said, the protection of your information and our site from accidental or malicious loss and destruction is one of our top priorities.
Residual copies of some of your personal information will be kept on our backup systems for 30 days.
Some anonymized copies of your information (e.g. log records) may also remain in our database.
If you have a question about any specific retention periods of certain personal data, please contact us via the contact details provided in Section 10 “HOW TO CONTACT US?
Your account with us secures your ability to benefit from and purchase services from the Broadcasters.
The following information about you is automatically available to Broadcasters with whom you interact:
- Your username: Broadcasters will be able to reach you out by searching your username
- If they are one of your favorites: Broadcasters will be able to see a special icon and your username in their account, if you added them in your list of favorites
- If you sent them a surprise
- Coins you spent on them (every Broadcaster will be able to see the coins you spent on them, not on other Broadcasters)
You can choose to share other information about yourself with the Broadcasters (e.g., gender, age, location, interests, etc.). You may also connect your camera in private chat to visually communicate with the Broadcaster or simply turn on your microphone. As a reminder, the Broadcaster is not allowed to record the video or voice data you provide.
Video/Audio in Private Chat:
Please note that no one can access your video feed or audio feed should you decide to turn on your camera or microphone during private chat (see clause 2.2: “Content Information“).
Video/Audio Offline Calls:
As a reminder, your communication is this instance is completely private. Please note that no one can access your video feed or audio feed should you decide to turn on your camera or microphone during private chat.
If you decide to share additional content with the Broadcasters (e.g. pictures), please note that you are fully responsible for the sharing of such information and we cannot be held responsible for any disclosure that you freely made.
Other Users & the Public
If you post comments on a Broadcaster's Live content, other users will see them.
Please be aware that your comments might be seen by other Members watching the Live session.
As well, please be assured that, if you decide to send a private message to the Broadcaster, other users of our site will not be able to access any information about you from the moment you enter into private chat but it will be visible only to him/her.
Entities of Our Company's Group
We share your personal information with the following companies of our group based in Luxembourg, Hungary and the US, as the case may be, as they are helping us to deliver our services to you:
- Jasmin Holding SA, 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
- Docler Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
- Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
- Jasmin SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
- Jasmin IP S.à r.l. Hungary Branch, Expo tér 5-7, H-1101, Budapest, Hungary;
- Docler Services Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
- Docler LA LLC, 10811 Washington Blvd, Culver City, CA 90232, USA;
- Escalion S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
- Duodecad IT Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.
We use carefully selected and trusted third parties, who act as service providers/processors to our site.
As we constantly work on the development and enhancement of the technology to support our site, our third-party processors may regularly change.
Such entities mainly operate in the following areas:
- Business intelligence and analytics
- Marketing & sales
- Customer care
- Fraud prevention
Payment Providers & Financial Institutions
When you purchase coins, depending on your choice of payment method, a third-party bank or a payment processor may process your payment. If this is the case, you may need to share personal data with them in order to complete the transaction.
You may receive transactional emails from this party confirming the order, including dispatch, possible refunds, and follow-up invitations to leave feedback for this party.
If you, or the credit card holder, request a chargeback, in certain circumstances we have to share some information about you and your use of our services with the processing bank, financial institution, payment processor, the credit card holder or any relevant third party.
Fraud Detection & Prevention
We may share information with relevant financial institutions if we consider it strictly necessary for fraud detection and prevention purposes.
Law Enforcement Agencies & Governmental Authorities
To the extent permitted by applicable laws, we may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary for the following:
- To comply with our legal obligations
- Respond to information requests for fraud investigations and other alleged illegal activities
- Enforce and administer our terms and conditions
- Protect our rights and defend ourselves against any claims
Your information may be transferred to another entity of our group (i.e. as a result of reorganization, restructuring, etc.) or third party (i.e. as a result of sale, merger and/or acquisition, etc.) if part (more than 50%) or whole of the business (or related assets) is either directly or indirectly transferred or falling under the control of the new owner.
Your rights under GDPR
Information on the transfer of your personal data outside of the European Economic Area?
As we are a Luxembourg based company, we comply with the EU Data Protection Regulation, “GDPR“. Regardless of whether you are located in Europe or elsewhere, our own location in Europe requires us to comply with GDPR. You can read the entire Regulation here.
If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.
What are Your Rights Regarding Your Personal Data?
Our Support Team will provide you with information on actions taken within one month of the day of receipt of your request. Only in exceptional circumstances, when we face complex and a high number of requests, we may extend this period of response up to two further months.
Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.
Please also understand that, because your privacy is so important for us, our Support Team may need to duly verify your identity and ask you to provide additional information before executing your request.
You have the right to access the personal data we hold about you. You can request a copy of your personal data, free of charge. To exercise this right, you can send an email to email@example.com.
Upon verification of your identity, your request will be sent to our Support Team.
If we consider that your request is manifestly unfounded or excessive (e.g., due to multiple requests in a short period), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you with the information.
Please note that the following is separate from the right to access your data.
In certain cases, you are entitled to request copies of your personal information in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
For clarification, only the following information can be made available:
- The data actively and knowingly provided by you (e.g., e-mail address, username, etc.)
- The observed data provided by you by virtue of the use of the service or the device (e.g., your search history, traffic data and location data).
To exercise this right, you can send an email to firstname.lastname@example.org.
Rectification of inaccurate or incomplete data
You have the right to request that we correct any inaccuracies in your personal data.
For this purpose, you can contact our Customer Support or send an email to email@example.com.
If you no longer want us to use your personal data, you can request that we erase it and close your account. Requests for account cancellation or closure will be considered as a request for the erasure of your personal data. To exercise this right, you can send an email to firstname.lastname@example.org.
Your request will then be sent to our Support Team who will contact you. However, if you face any difficulties, please contact us at any time.
For avoidance of a doubt, when the erasure process starts (notably upon a successful verification of your identity as the owner of the account), you will no longer be able to log in to our site (Oranum.com).
Moreover, if your account is inactive for more than one (1) year, we have the right to terminate your account and proceed with the erasure of your data in accordance with our Terms & Conditions.
Please note that even if you request the erasure of your personal information, we will retain some of it for as long as we consider it necessary for compliance with our legal obligations or other legitimate interests as explained above in Section 5. “HOW LONG DO WE RETAIN YOUR PERSONAL DATA?“.
Right to object
We process your data for a variety of reasons (see Section 3: “WHY DO WE PROCESS YOUR PERSONAL DATA?“).
Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on a legitimate interest. If you object to such processing, we will stop processing your personal data for those purposes.
In specific situations, we may have to refuse the execution of your request. This would only be in the cases where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.
Please keep in mind that objecting to certain uses of your data may disable the use of your account.
Please also remember that you may unsubscribe from receiving our marketing and informative emails at any time, using a link contained within the emails themselves. You can also opt-out contacting the Support Team as indicated in Section 10 “HOW TO CONTACT US?“.
Right to restriction of processing
You have the right to request that we stop processing your data, while we resolve any issues.
This is only possible in the following four cases:
If you contest the accuracy of your personal data, processing would be stopped while we verify your claim.
If you object to a processing activity based on a legitimate interest, you can require the processing operation to be put on hold while we verify your grounds for objection.
You can request the restriction of data processing if you consider your data is being processed unlawfully, but do not wish for your data to be immediately erased.
You can request us to store your data, if you require it to establish, exercise or defend any legal claims, and we have no further need of it.
Despite your request, we may continue to process your data, if we have to establish, exercise or defend legal claims. We will notify you before lifting any restriction.
Right to Lodge a Complaint with a Supervisory Authority**
If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with the relevant supervisory authority (i.e. your local authority or the CNPD).
Information for California Residents
Please note that we do not “sell” your personal data, as that term is defined in CCPA.
Your Right to “Know” and to Request Deletion
You have the right to know the categories and specific pieces of personal data we have collected about you. You have the right to know the categories of sources from which the personal data has been collected, the business or commercial purpose for collecting or selling personal data, and the categories of third parties with whom we share personal data.
You also have the right to request deletion of personal data we've collected or maintain. Please note this right is subject to certain exceptions, including without limitation our retaining information as necessary to protect against malicious, deceptive, fraudulent, or illegal activity, to comply with our legal obligations, and for other internal purposes.
To exercise these rights contact us as provided in Section 10 “HOW TO CONTACT US?“ below. Please note that any requested disclosures in connection with a request to know will only apply to the 12-month period preceding the request, and you are entitled to request disclosure twice in any 12-month period. You may also ask for your data to be provided or exercise your right to delete by deleting your account.
Personal Information Disclosed
You also have the right to know what categories of personal data we've disclosed for a business purpose, and the third parties to whom that information was disclosed.
In the past 12 months, we've disclosed for a business purpose and for different products the following categories of information to the following parties: Usage/device information (including, without limitation, your IP address, as the case may be) to our business intelligence and analytics service providers (e.g., Hotjar, Google Analytics); Payment/transaction data to our customer/payment service providers; Contact information, device/usage information (including, without limitation, your IP address and the website you are coming from, as the case may), information relating to the purchase made (excluding any data relating to your mean of payment, such as credit card information) and information as regards your interactions with the emails we sent to our marketing and sales partners (e.g. Emarsys, marketing partners promoting our site); and identification information, contact information, device and usage information, payment information (as the case may be) to our antifraud service providers and auditing service providers.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please note, however, that the exercise of some of your rights (e.g., to delete your data) may render it impossible for us to continue to deliver services to you.
Your Right to Use an Authorized Agent
You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section 10 “HOW TO CONTACT US?“ below. In order to verify you have authorized an agent we may require a signed, written authorization from you.
Do Not Track
Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will however treat any “do not sell” or similar signals as opt-out requests under CCPA.
If we make any important changes, we will let you know by placing a notice on the relevant site and/or contact you directly, using other methods such as email.
How to Contact Us?
JWS Americas S.à r.l.44, Avenue John F. KennedyL-1855 LuxembourgGrand Duchy of Luxembourg or
JWS International S.à r.l.44, Avenue John F. KennedyL-1855 LuxembourgGrand Duchy of Luxembourg
we are also happy to inform you that we have an employee dedicated to ensuring your privacy, our data protection officer. you can directly reach our data protection officer via email at: email@example.com or mail to the following address: