Legal › Privacy Policy
Privacy Policy
1. Who We Are
1.1 This Privacy Policy explains how GLOBAL ENTERPRISE CLOUD SYSTEMS ("GECS", "we", "us", "our"), a company organised under the laws of the Republic of Panama with its registered address at Show street address, Panama City, Republic of Panama, trading as "AdultSense", collects, uses, discloses, retains and protects personal data.
1.2 GECS operates the AdultSense advertising marketplace at adultsense.com, the client portal and an ad server that delivers advertising to independent third-party websites ("Publisher Websites"). GECS is an intermediary: it does not own, operate or control Publisher Websites, and each Publisher is responsible for its own privacy practices and notices.
1.3 For the purposes of the EU General Data Protection Regulation ("GDPR"), the UK GDPR and the UK Data Protection Act 2018, and comparable laws elsewhere, GECS is the controller of the personal data described in this policy, except where it processes personal data on behalf of a client as a processor under the Data Processing Addendum.
1.4 Contact for all privacy matters: Show email, subject line "Privacy request". Where applicable law requires GECS to appoint a representative in the European Union or the United Kingdom, their details will be provided on request via Show email.
2. Scope
2.1 This policy covers personal data relating to: (a) visitors to adultsense.com and the public guest marketplace; (b) prospective and approved business clients (Advertisers and Publishers) and their directors, employees and contractors; (c) individuals who contact us, including those submitting abuse, copyright, Digital Services Act or legal notices, and individuals who are the subject of such notices; and (d) end users of Publisher Websites to whom advertising is delivered through our ad server ("End Users").
2.2 Our services are intended exclusively for businesses and for adults. We do not knowingly collect personal data from anyone under 18 (see section 15).
2.3 This policy should be read together with our Cookie Policy, the Terms of Service and, for clients whose data we process on their behalf, the Data Processing Addendum. If there is a conflict between this policy and a signed agreement with a client concerning that client's data, the agreement prevails to the extent of the conflict.
3. Personal Data We Collect
3.1 Account and business data: name, job title, company name, registered address, company registration and tax or VAT identifiers, business email address, telephone number, Telegram handle if you choose to link Telegram notifications, website URLs and any other information supplied in the account request form or company details used on invoices.
3.2 Account activity data: login records, IP addresses and device information used to access the portal, purchases, reservations, offers, proposals, auction bids, renewal decisions, price change notices sent to you, invoices, credits, notification preferences, support correspondence and portal settings.
3.3 Transaction data: invoice amounts, currency (USD), due dates, payment status and the references needed to reconcile payments made by the methods made available on the Platform. GECS does not store full payment instrument details.
3.4 Advertising content: ad code, creatives, landing page URLs and related materials submitted by Advertisers, which may incidentally contain personal data (for example, images of performers or contact details on landing pages).
3.5 Publisher data: for Publishers, details of the positions made available, payout details and statements, and the information needed to verify site ownership and control.
3.6 Website visitor data (adultsense.com): IP address, browser type, device information, pages viewed, referring URL, timestamps and cookie identifiers.
3.7 End User data (ad delivery): when our ad server delivers an advertisement on a Publisher Website it receives technical data automatically transmitted by the browser, including IP address (which we may truncate or use to derive approximate country and region), user agent, device type, operating system, browser language, referring page URL, timestamps and, where permitted, a cookie or similar pseudonymous identifier used for frequency capping, counting unique impressions, rotation and invalid traffic detection. We do not intentionally collect names, email addresses or other directly identifying data of End Users, and we do not collect precise geolocation.
3.8 Notice and complaint data: contact details, the content of notices, evidence, sworn or good-faith statements and identity information provided in abuse, copyright, trademark, Digital Services Act or other legal submissions, together with our decisions and statements of reasons.
3.9 Verification and compliance data: identity and ownership verification information, sanctions and restricted-party screening results, and evidence of age and consent you provide when we request it.
3.10 Special category data: we do not seek to collect special category or sensitive personal data. Because the Platform relates to adult advertising, some data (for example, the fact that a browser was served an adult advertisement) could be regarded as revealing information about sex life or sexual orientation. We do not use ad-delivery data to infer such characteristics about individuals and we limit processing to the purposes set out in section 5.
4. How We Collect Data
4.1 Directly from you when you complete the account request form, use the portal, submit ad code, communicate with us or submit a notice.
4.2 Automatically through cookies, server logs and our ad server when you visit adultsense.com or when advertising is delivered on a Publisher Website.
4.3 From clients, for example contact details of Advertiser or Publisher staff, and from Publishers in respect of their websites and positions.
4.4 From third parties, such as sanctions screening sources, fraud and invalid traffic detection services, public company registers and, in the case of notices, the person submitting the notice.
5. Purposes and Legal Bases
5.1 The table below sets out the main purposes for which we process personal data, the categories of data involved and the legal bases we rely on under the GDPR and UK GDPR. Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms.
| Purpose | Data categories | Legal basis |
|---|---|---|
| Reviewing account requests and approving or denying applications | Account and business data; verification data | Steps prior to entering a contract (Art. 6(1)(b)); legitimate interests in admitting only legitimate businesses (Art. 6(1)(f)) |
| Operating accounts, the marketplace, offers, proposals, auctions, reservations and renewals | Account, activity and transaction data | Performance of contract (Art. 6(1)(b)) |
| Issuing invoices, recording payments and issuing credits | Account, transaction data | Performance of contract; legal obligation for accounting and tax records (Art. 6(1)(c)) |
| Reviewing ad code and creatives before activation | Advertising content | Performance of contract; legitimate interests in lawful, safe advertising; legal obligation where content laws apply |
| Delivering advertising, frequency capping, rotation and unique impression counting | End User data | Legitimate interests in operating the ad service; consent where required by ePrivacy rules (collected by the Publisher) |
| Producing statistics and reports for clients and marketplace estimates | End User data (aggregated); activity data | Legitimate interests; performance of contract |
| Detecting invalid traffic, fraud and abuse; securing the Platform | Activity data; End User data; visitor data | Legitimate interests in security and integrity; legal obligation where applicable |
| Sending service notifications by email or Telegram | Account data; notification preferences | Performance of contract; legitimate interests |
| Sending news and announcements about the Platform | Account data | Legitimate interests (business-to-business); consent where required by law |
| Handling abuse, copyright, trademark and DSA notices, complaints and appeals | Notice and complaint data | Legal obligation (Art. 6(1)(c)); legitimate interests in protecting rights holders and users |
| Reporting child sexual abuse material and responding to authorities | Notice data; End User and content data | Legal obligation; legitimate interests and vital interests of victims (Art. 6(1)(d)) |
| Sanctions, anti-bribery and record-keeping compliance | Verification data | Legal obligation; legitimate interests |
| Enforcing our terms and establishing, exercising or defending legal claims | All relevant categories | Legitimate interests |
| Analytics and improvement of adultsense.com | Visitor data | Consent where required; otherwise legitimate interests |
5.2 Where processing is based on consent you may withdraw it at any time without affecting the lawfulness of processing before withdrawal. Where processing is necessary for a contract and you do not provide the data, we may be unable to open or maintain your account.
5.3 We will not use personal data for a new purpose that is incompatible with the purpose for which it was collected without informing you and, where required, obtaining your consent.
6. Cookies and Similar Technologies
6.1 We use cookies, local storage and similar technologies on adultsense.com, in the portal and in our ad server. Details of categories, purposes, durations and controls are in our Cookie Policy.
7. Recipients and Sub-processors
7.1 We do not sell personal data for money. We disclose personal data only to the categories of recipients below, and only to the extent needed for the purposes in section 5.
| Category of recipient | Purpose | Data shared |
|---|---|---|
| Hosting, data centre and infrastructure providers | Running the website, portal and ad server | All categories processed on our systems |
| Content delivery and network security providers | Fast, secure delivery and protection against attacks | Visitor and End User technical data |
| Email delivery and messaging providers (including Telegram where you opt in) | Sending notifications and correspondence | Contact details, message content |
| Invalid traffic and fraud detection services | Identifying bots and fraudulent activity | End User technical data, activity data |
| Analytics providers | Understanding website use | Visitor data (aggregated where possible) |
| Accounting, tax and payment reconciliation service providers | Bookkeeping and reconciliation of payments made by the methods made available on the Platform | Transaction and account data |
| Professional advisers (lawyers, auditors, insurers) | Advice, audit and claims | Relevant categories as needed |
| Advertisers and Publishers | Reporting and resolving delivery or notice issues | Aggregated or de-identified statistics; business contact details where necessary |
| Persons submitting or subject to notices | Notice-and-action and counter-notice procedures required by law | Notice content; contact details where law requires |
| Authorities, courts, regulators, NCMEC, the IWF and similar bodies | Legal compliance and protection of victims | Data required by law or lawful request |
| Successors and acquirers | Merger, acquisition, restructuring or sale of assets | Relevant categories, subject to equivalent protection |
7.2 Our service providers act on our documented instructions under written contracts that require confidentiality, appropriate security and, where they act as processors, terms meeting Article 28 GDPR. Clients may obtain a description of current sub-processor categories and locations by contacting Show email.
7.3 Aggregated statistics shown in the marketplace (traffic estimates, trends and top countries) do not identify individuals.
8. International Transfers
8.1 GECS is based in the Republic of Panama and our service providers may be located in other countries, including the United States and member states of the European Union. Personal data may therefore be transferred to, and processed in, countries whose data protection laws differ from those of your country.
8.2 Where we transfer personal data from the European Economic Area, the United Kingdom or Switzerland to a country not recognised as providing an adequate level of protection, we rely on appropriate safeguards, principally the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum (or the Swiss equivalent), together with a transfer risk assessment and supplementary technical and organisational measures such as encryption and access controls where needed. Where a recipient is certified under an applicable data privacy framework recognised as adequate, we may rely on that certification.
8.3 In limited cases we may rely on a derogation, for example where a transfer is necessary for the establishment, exercise or defence of legal claims.
8.4 You may request a copy of the relevant safeguards (with commercially sensitive information removed) by contacting Show email.
9. Retention
9.1 We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, accounting and reporting requirements. Our standard retention periods are:
| Record type | Retention period |
|---|---|
| Raw ad server logs (including full IP addresses) | 90 days, then aggregated or anonymised |
| Portal access and security logs | 12 months |
| Financial records (invoices, payments, credits, statements) | 7 years after the end of the financial year to which they relate |
| Account and business data | Life of the account, then up to 7 years where linked to financial records or legal claims |
| Aggregated, anonymised statistics | Indefinitely (no personal data) |
| Abuse, copyright and DSA notices, decisions and statements of reasons | At least 6 months after the final decision (so that complaints and appeals can be handled), and longer where needed for legal claims or regulatory obligations |
| Records relating to suspected child sexual abuse material | As required by law or by law enforcement |
| Account requests that were denied | 12 months |
| Website analytics data | Up to 13 months |
| Age, consent and verification records supplied to us | Life of the account plus the period required by applicable law |
9.2 When a retention period ends we delete or irreversibly anonymise the data, unless a legal hold, investigation or claim requires us to keep it longer.
10. Your Rights (EEA, UK and Similar Laws)
10.1 Subject to conditions and exceptions under applicable law, you have the right to: (a) access your personal data and receive a copy; (b) rectify inaccurate or incomplete data; (c) erasure; (d) restrict processing; (e) data portability for data you provided to us that is processed by automated means on the basis of contract or consent; (f) object to processing based on legitimate interests, including profiling, and object at any time to direct marketing; (g) withdraw consent; and (h) not be subject to decisions based solely on automated processing that produce legal or similarly significant effects.
10.2 To exercise your rights, email Show email with the subject "Privacy request". We may need to verify your identity before acting. We respond within one month, which may be extended by two further months for complex or numerous requests, in which case we will tell you why.
10.3 End Users: because we generally hold only device-level, pseudonymous data, please include the IP address, device, browser and approximate dates concerned, or the cookie identifier, so we can locate relevant records. In many cases we will be unable to identify you from the information available; if so, we will tell you, and in accordance with Article 11 GDPR we are not required to collect additional data solely to identify you.
10.4 Requests are free of charge, but we may charge a reasonable fee or refuse a request that is manifestly unfounded or excessive.
11. Rights in Other Countries
11.1 GECS is established in the Republic of Panama and handles personal data under Panamanian law (Law 81 of 2019 on Personal Data Protection) and, where they apply, the laws described in section 10. We give every person the same core choices regardless of where they live: you may ask us to tell you what personal data we hold about you, give you a copy, correct it, delete it, or stop using it for advertising measurement where that is not needed to deliver the service or prevent fraud.
11.2 We do not sell personal data for money. Ad delivery on Publisher Websites uses pseudonymous identifiers to cap frequency, rotate Advertisements, measure delivery and detect fraud. To ask us to stop using your identifiers in this way, email Show email with the subject "Advertising opt-out".
11.3 Submit requests to Show email with the subject "Privacy request". We may need to verify your identity before acting and will respond within a reasonable time, and in any event within any period required by the law that applies to your request. If we decline a request, we will explain why and you may ask us to reconsider by replying with the subject "Privacy appeal".
12. Security
12.1 We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include encryption in transit, least-privilege access controls, authentication protections for the portal, logging and monitoring, network segmentation, backups, confidentiality obligations on personnel and service providers, and periodic review of our measures.
12.2 No system is completely secure. If we become aware of a personal data breach likely to result in a risk to individuals, we will notify the relevant supervisory authorities and affected individuals where and as required by law.
12.3 You are responsible for keeping your account credentials confidential and for notifying us immediately at Show email of any suspected unauthorised access.
13. Automated Decision-Making
13.1 We use automated systems to detect invalid traffic and fraud, apply frequency caps and rotation, and assist in screening creatives and notices. These systems may cause traffic to be excluded from statistics or content to be flagged for review.
13.2 We do not make decisions based solely on automated processing that produce legal or similarly significant effects on individuals. Decisions with significant effect on a client account, such as suspension or termination, and decisions to remove content following a notice, are reviewed by a human. You may contest any such decision through the complaint process described in our Abuse Reporting Policy.
14. Children
14.1 The Platform is restricted to businesses and adults. We do not knowingly collect personal data from children. Advertising delivered through our ad server is intended solely for adult audiences on Publisher Websites, whose operators are required to implement age assurance appropriate to their websites and applicable law. If you believe a minor has provided us with personal data, contact Show email and we will delete it.
15. Third-Party Websites
15.1 Advertisements delivered through our ad server link to Advertisers' websites and appear on independent Publisher Websites. Those websites and any technologies they use are governed by their own privacy policies, and GECS is not responsible for their practices.
16. Complaints
16.1 If you have a concern about our handling of personal data, please contact Show email first with the subject "Privacy complaint" so that we can try to resolve it.
16.2 You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU or EEA member state of your habitual residence, place of work or place of the alleged infringement, or with the UK Information Commissioner's Office.
17. Changes to This Policy
17.1 We may update this policy from time to time. The "Last updated" date shows when it last changed. We will give account holders at least 15 days' notice of material changes by email or in the portal before they take effect, except where a change is required sooner by law.
18. Contact
18.1 GLOBAL ENTERPRISE CLOUD SYSTEMS, Show street address, Panama City, Republic of Panama. Email: Show email (subject "Privacy request"). Where applicable law requires GECS to appoint a representative in the European Union or the United Kingdom, their details will be provided on request via Show email.
GLOBAL ENTERPRISE CLOUD SYSTEMS · Show street address, Panama City, Republic of Panama · Show email