Privacy Policy

Last updated: 2026-03-18

PRIVACY POLICY

NOVAREL SOLUTIONS LIMITED
Last updated: March 17, 2026

  1. INTRODUCTION

This Privacy Policy explains how NOVAREL SOLUTIONS LIMITED ("Company", "we", "us", "our") collects, uses, stores, shares, and protects personal data in connection with your access to and use of our platform (the "Platform" or the "Service").

This Privacy Policy applies to all users of the Platform, including visitors, subscribers, fans, creators, and other individuals who interact with our services.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

  1. DATA CONTROLLER

NOVAREL SOLUTIONS LIMITED is the data controller for the personal data processed in connection with the Platform, except where another role is expressly stated.

NOVAREL SOLUTIONS LIMITED is incorporated exclusively in Ireland. Any address in Romania used in connection with our activities is solely a correspondence, administrative, or tax-related address, as applicable, and does not constitute our registered office or legal seat.

Contact details:

NOVAREL SOLUTIONS LIMITED
Registered office (Ireland): [Full Irish Address]
Company registration number (Ireland): [Company Number]
General contact: contact@novarel.com
Privacy contact: privacy@novarel.com

  1. PERSONAL DATA WE COLLECT

We may collect and process the following categories of personal data, depending on how you use the Platform:

3.1 Account and Identity Data

  • full name or display name;

  • email address;

  • date of birth;

  • username;

  • password and authentication-related information;

  • profile information;

  • country and language preferences.

3.2 Identity Verification and KYC Data

Where required for creators or in other compliance-related cases, we may collect:

  • government-issued identity documents, such as passport, identity card, or driver's license;

  • selfie, video selfie, or biometric verification data;

  • proof of address documents;

  • tax identification information;

  • banking or payout details;

  • other compliance-related documentation.

3.3 Payment and Transaction Data

We may collect or receive:

  • billing-related details;

  • transaction history;

  • subscription records;

  • purchase history for PPV content;

  • tip history;

  • payout records;

  • chargeback, refund, and dispute information.

We do not necessarily store full payment card details ourselves. Payment information may be processed by third-party payment processors.

3.4 Platform Usage Data

We may collect information about how you interact with the Platform, including:

  • login activity;

  • device information;

  • browser type;

  • operating system;

  • IP address;

  • referral pages;

  • pages viewed;

  • clicks, actions, and interaction logs;

  • date and time of access;

  • usage patterns and preferences.

3.5 Content and Communications Data

We may process:

  • content you upload, publish, or transmit;

  • private messages and communications sent through the Platform;

  • support requests and customer service correspondence;

  • reports, complaints, or notices submitted through the Platform.

3.6 Technical and Security Data

We may collect and generate:

  • security logs;

  • fraud detection signals;

  • suspicious activity indicators;

  • authentication records;

  • moderation and enforcement records;

  • device or session identifiers.

3.7 Special Categories and Sensitive Data

In limited circumstances and where permitted by law, we may process sensitive or higher-risk data, including:

  • biometric data used for identity verification;

  • data revealing sexual preferences or adult-content-related behavior inferred from use of the Platform;

  • identity verification documentation.

Such data is handled with enhanced safeguards and only where necessary and lawful.

  1. HOW WE COLLECT PERSONAL DATA

We collect personal data:

  • directly from you when you register, verify your identity, make purchases, upload content, communicate with us, or otherwise use the Platform;

  • automatically through cookies, server logs, analytics tools, and similar technologies;

  • from third-party service providers, including payment processors, KYC providers, fraud-prevention tools, hosting providers, analytics vendors, and security partners;

  • from legal authorities, reporting parties, or other users where relevant for complaints, moderation, safety, or legal compliance.

  1. PURPOSES OF PROCESSING

We process personal data for the following purposes:

  • to create and manage user accounts;

  • to provide, operate, maintain, and improve the Platform;

  • to verify identity, age, and eligibility;

  • to process subscriptions, payments, tips, purchases, refunds, and payouts;

  • to detect, prevent, and investigate fraud, abuse, chargebacks, and unauthorized activity;

  • to monitor compliance with our Terms, policies, and legal obligations;

  • to moderate content and enforce safety rules;

  • to respond to legal notices, complaints, copyright claims, and abuse reports;

  • to communicate with users regarding support, service issues, legal updates, and account matters;

  • to personalize user experience and improve features;

  • to comply with tax, accounting, audit, reporting, and regulatory obligations;

  • to protect the rights, property, and safety of the Company, users, and third parties;

  • to establish, exercise, or defend legal claims.

  1. LEGAL BASES FOR PROCESSING

Where GDPR applies, we rely on one or more of the following legal bases:

6.1 Performance of a Contract

We process personal data where necessary to provide the Platform and perform our contract with you, including:

  • account creation and management;

  • content access and delivery;

  • subscription management;

  • payment processing;

  • customer support;

  • creator payout administration.

6.2 Compliance with Legal Obligations

We process personal data where necessary to comply with applicable legal obligations, including:

  • age verification requirements;

  • anti-fraud and financial compliance requirements;

  • tax and accounting obligations;

  • reporting obligations applicable to platform operators;

  • responses to lawful requests from authorities;

  • safety and digital services obligations.

6.3 Legitimate Interests

We process personal data where necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms. These interests may include:

  • maintaining and improving the Platform;

  • fraud prevention and platform security;

  • content moderation and abuse prevention;

  • internal administration and business operations;

  • analytics and service optimization;

  • enforcing our Terms and policies;

  • protecting legal rights and defending claims.

6.4 Consent

Where required by law, we rely on your consent, including for certain cookies, certain marketing communications, or other processing activities for which consent is legally required.

You may withdraw consent at any time where consent is the legal basis, without affecting the lawfulness of processing carried out before withdrawal.

  1. AGE RESTRICTION

The Platform is strictly intended for adults aged 18 and over.

We do not knowingly allow minors to create accounts, access the Platform, publish content, or use paid features. If we become aware that a person under 18 has provided personal data or accessed the Platform, we may take steps to suspend or terminate the relevant account, remove associated content, and delete data as appropriate, subject to legal retention obligations.

  1. IDENTITY AND AGE VERIFICATION

To maintain platform safety, protect against fraud, and comply with legal and payment-related requirements, we may require identity and age verification.

This may include collection and processing of:

  • identity documents;

  • selfies or video selfies;

  • biometric verification data;

  • proof of address;

  • tax or banking information.

We may use third-party identity verification providers to assist with these checks. Verification data may also be used to detect fraud, prevent duplicate or misleading accounts, and ensure that creators and persons depicted in content meet eligibility requirements.

  1. HOW WE SHARE PERSONAL DATA

We may share personal data with the following categories of recipients, where necessary and lawful:

9.1 Service Providers

We may share data with third-party providers that support our operations, including:

  • payment processors;

  • KYC and age-verification providers;

  • cloud hosting and infrastructure providers;

  • analytics providers;

  • security and fraud-prevention vendors;

  • customer support tools;

  • communication and email service providers;

  • legal, accounting, compliance, and audit advisors.

9.2 Legal and Regulatory Authorities

We may disclose personal data where required by law, regulation, court order, legal process, or lawful request from public authorities, including regulators, tax authorities, law enforcement, or supervisory authorities.

9.3 Protection of Rights and Safety

We may share personal data where necessary to:

  • investigate fraud or abuse;

  • enforce our Terms and policies;

  • protect users, the public, or third parties;

  • detect or report illegal content or unlawful conduct;

  • establish, exercise, or defend legal claims.

9.4 Corporate Transactions

If we are involved in a merger, acquisition, financing, restructuring, asset sale, or similar corporate transaction, personal data may be disclosed to relevant parties subject to appropriate confidentiality and legal safeguards.

  1. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries outside the European Economic Area or the United Kingdom where this is necessary for providing the Platform, using service providers, or operating our business.

Where such transfers take place, we will implement appropriate safeguards as required by law, which may include:

  • adequacy decisions;

  • Standard Contractual Clauses;

  • supplementary technical, organizational, or contractual measures;

  • other lawful transfer mechanisms.

You may contact us for more information about the safeguards used for international transfers.

  1. DATA RETENTION

We retain personal data only for as long as necessary for the purposes for which it was collected, including for legal, regulatory, tax, accounting, fraud-prevention, dispute-resolution, and enforcement purposes.

Retention periods may vary depending on the type of data and the context in which it was collected.

By way of example:

  • account information may be retained for as long as your account remains active and for a reasonable period thereafter;

  • transaction and financial records may be retained for the period required by tax, accounting, and audit laws;

  • KYC and verification records may be retained for as long as necessary for compliance, fraud prevention, legal defense, or payment-related obligations;

  • support, moderation, and enforcement records may be retained for as long as necessary to investigate incidents, enforce policies, and defend legal claims.

When personal data is no longer needed, we will delete it, anonymize it, or securely restrict its use, unless continued retention is required or permitted by law.

  1. COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies, pixels, SDKs, local storage, and similar technologies to:

  • operate the Platform;

  • remember user preferences;

  • keep users logged in;

  • analyze traffic and usage;

  • improve functionality and performance;

  • detect fraud and security threats;

  • measure the effectiveness of communications or features.

Some cookies are strictly necessary for the operation of the Platform, while others may require consent depending on applicable law.

You can manage cookies through your browser settings or through any cookie management tools we make available on the Platform.

  1. SECURITY OF PERSONAL DATA

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

These measures may include:

  • encryption;

  • access controls;

  • authentication safeguards;

  • logging and monitoring;

  • secure storage practices;

  • vendor due diligence;

  • internal policies and training;

  • incident response procedures.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

  1. USER RIGHTS

Subject to applicable law, you may have the following rights in relation to your personal data:

  • the right to access your personal data;

  • the right to request correction of inaccurate or incomplete data;

  • the right to request deletion of your personal data;

  • the right to request restriction of processing;

  • the right to object to certain processing activities;

  • the right to data portability;

  • the right to withdraw consent where consent is the legal basis;

  • the right to lodge a complaint with a competent data protection authority.

To exercise your rights, please contact us at: privacy@novarel.com

We may request information necessary to verify your identity before responding to your request.

  1. MARKETING COMMUNICATIONS

We may send service-related communications necessary for the operation of your account or the Platform.

Where permitted by law, we may also send marketing or promotional communications. You may opt out of marketing emails at any time by using the unsubscribe link in the communication or by contacting us.

Even if you opt out of marketing communications, we may still send you non-promotional messages relating to your account, transactions, legal notices, or important service updates.

  1. CONTENT, PRIVATE MESSAGES, AND MODERATION

Because the Platform allows users to upload content and communicate through platform features, we may process content and communications where necessary to:

  • provide the relevant service;

  • maintain platform functionality;

  • investigate abuse, fraud, or policy violations;

  • respond to reports, complaints, or legal requests;

  • protect users and third parties;

  • comply with applicable law.

We do not monitor all user communications in real time, but we may review content, messages, or related metadata where reasonably necessary for safety, enforcement, compliance, fraud prevention, or legal response.

  1. THIRD-PARTY SERVICES AND LINKS

The Platform may contain links to third-party websites, tools, or services, or may integrate third-party functionality. We are not responsible for the privacy practices of those third parties.

We encourage you to review the privacy policies of any third-party services you use or access through the Platform.

  1. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in legal requirements, operational practices, technology, or the Platform itself.

Where required, we will provide notice of material changes through the Platform, by email, or through other appropriate means.

The "Last updated" date at the top of this Privacy Policy indicates when the latest version became effective.

  1. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us at:

NOVAREL SOLUTIONS LIMITED
Registered office (Ireland): [Full Irish Address]
Company registration number (Ireland): [Company Number]

General contact: contact@novarel.com
Privacy contact: privacy@novarel.com
Legal contact: legal@novarel.com
Technical support: support@novarel.com

  1. SUPERVISORY AUTHORITY

If you are located in the European Union or another jurisdiction that gives you the right to complain to a data protection authority, you may lodge a complaint with the competent supervisory authority in your country of residence, place of work, or place of the alleged infringement.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.