We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the clubcrossdressing.com website (“Website” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and CowGoMoo Web Solutions Ltd (doing business as “ClubCrossDressing”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
1. Automatic collection of information
When you open the Website, our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, information you search for on the Website, access times and dates, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
2. Collection of personal information
You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Website, you may be asked to provide certain Personal Information (for example, your e-mail address). We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any online forms on the Website. When required, this information may include the following:
(a) Personal details such as, country of residence, etc.
(b) Contact information such as email address, etc.
(c) Account details such as user name, unique user ID, password, etc.
(d) Geolocation data such as latitude and longitude.
(e) Any other materials you willingly submit to us such as articles, images, feedback, etc.
Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as public databases and our joint marketing partners. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.
3. Use and processing of collected information
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
(a) Create and manage user accounts
(b) Fulfill and manage orders
(c) Deliver products or services
(d) Improve products and services
(e) Send administrative information
(f) Respond to inquiries and offer support
(g) Request user feedback
(h) Post customer testimonials
(i) Administer prize draws and competitions
(j) Enforce terms and conditions and policies
(k) Protect from abuse and malicious users
(l) Respond to legal requests and prevent harm
(m) Run and operate the Website and Services
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies:
(1) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law;
(2) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
(3) processing is necessary for compliance with a legal obligation to which you are subject;
(4) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
(5) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
It is important you understand that we cannot be held responsible for personal information you choose to disclose on the site and to other members which we have not specifically required for you to complete your profile. We collect data such as IP address, date you joined, date and time you last logged in and accessed the service and device types and other information such as web browser and PC or mobile platform.
4. Billing and payments
We use third party payment processors to assist us in processing your payment information securely. Such third party processors' use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
5. Managing information
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below.
6. Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes.
We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.
7. Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
Accounts can only be deleted by our staff using the administration control panel. You can request the deletion of your account anytime by sending an email to our support team using the contact form. Please note that deletions are permanent and you will lose all data. This process is not reversible. Once we delete your account, your profile will no longer be visible on the site and service but we may keep your data for 28 days (or as required by law) before deleting permanently. We may also retain your data offline (local machine in our offices) or remotely encrypted for 28 days. This includes private messages and posts.
Legal Justification: Should the data be required by the Authorities in cases such as (but not limited to) abuse, fraud and scamming.
8. Transfer of information
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section.
9. The rights of users
You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following:
(a) you have the right to withdraw consent where you have previously given your consent to the processing of your information;
(b) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent;
(c) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing;
(d) you have the right to verify the accuracy of your information and ask for it to be updated or corrected;
(e) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it;
(f) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us;
(g) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
10. The right to object to processing
Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
11. Data protection rights under GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights and ClubCrossDressing aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
(a) You have the right to request access to your Personal Information that we store and have the ability to access your Personal Information.
(b) You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request us to complete the Personal Information you believe is incomplete.
(c) You have the right to request the erase your Personal Information under certain conditions of this Policy.
(d) You have the right to object to our processing of your Personal Information.
(e) You have the right to seek restrictions on the processing of your Personal Information. When you restrict the processing of your Personal Information, we may store it but will not process it further.
(f) You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
(g) You also have the right to withdraw your consent at any time where ClubCrossDressing relied on your consent to process your Personal Information.
(h) You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
12. California privacy rights
In addition to the rights as explained in this Policy, California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please contact us.
13. How to exercise these rights
Any requests to exercise your rights can be directed to ClubCrossDressing through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
14. Cookies
The Website and Services use "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
We may use cookies to collect, store, and track information for statistical purposes to operate the Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services. Click here to learn more about cookies and how they work.
15. Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. The Website and Services do not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
16. Newsletters
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
17. Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
18. Privacy Features
It is our intention to give you the best possible exposure and increase interactivity amongst members and potential members. Therefore, when you create a profile or upload content, the default privacy settings are set to be viewed by "everyone". We however appreciate that some users may require some privacy. Therefore we offer privacy options on our Site in the "My Settings" area.
Below is a list of current privacy options on offer. Each offers a different level of privacy.
(a) Everyone - Viewable by visitors to the site, bots and crawlers such as Google, Yahoo etc.
(b) Registered Users - Viewable only by members who are logged in to the site.
(c) Friends - Viewable only by people who you have added to your friends list.
(d) No-one - Viewable only by yourself.
Please note: we cannot guarantee that these privacy features will not malfunction, break or will work consistently. We urge users to exercise caution and to not disclose any identifiable information on images, profiles or any other publicly accessible areas of the Site. No advice or information, whether oral or written, obtained by you from us or through the Service shall create any warranty not expressly made herein.
19. Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that
(a) there are security and privacy limitations of the Internet which are beyond our control;
(b) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and
(c) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
20. Data breach
In the event we become aware that the security of the Website and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.
21. Requesting the data held by us
We ask very little Personally Identifiable Information (pii) therefore any information requested by us would be very limited to:
(a) email address you created your account with which may have been superseded by a new one if you changed it.
(b) date of birth which is used to display your age (not date of birth) on your public profile.
(c) IP address you joined with or logged in with.
(d) Current images relating to your account.
All the pii can easily be accessed via your own profile editor and account settings. There are some information we certainly would be unable to release to you including information that would likely reveal personal information about other users. These notably include but are not limited to messages you received on our service and site, which are not provided out of concern for the privacy of the senders.
It is important to also mention that to protect your data, we would be obliged to ask you for a copy of a government issued ID document such as a passport or driving license to establish proof that you are who you say you are. We would also ask you to blank out certain sensitive parts of the document so it is not visible to us.
In some cases, we may require further verification of your identity, for example, if the materials you provide us do not establish your identity as being linked to the account in question.
22. Requesting more info or making a privacy related complaint.
If you have any questions regarding our Privacy Policy, please feel free to contact us using the contact link here. If you are unsatisfied with our response please feel free to contact the Information Commissioner's Office (ICO) by visiting https://www.ico.org.uk
23. Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page, send you an email to notify you. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
24. Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
Contacting us
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact form.
This document was last updated on July 26, 2021