Effective Date: April 21, 2020

Last Modified: March 25, 2019

xNetwork Ltd is the publisher and operator (referred to as the “Company”, “we”,
“our” or “us”) of the lecoinporno website(s), https://lecoinporno.fr/
(referred to as the “Website”). The Company is committed to protecting your privacy and handling your
personal data in an open and transparent manner. The personal data that we collect and process will vary
depending on how you use the Website.
This privacy policy:
  1. provides an overview of how the Company collects and processes your personal data and tells you
    about your rights under the EU General Data Protection Regulation (“GDPR”);
  2. is directed to natural persons who are: (a) visitors of the Website (referred to in this privacy
    policy as “Browsers”), and (b) individuals who have registered as members of the Website by creating
    their own account (referred to in this Website as “Members”). Both Browsers and Members must be aged
    eighteen (18) years and over or must have attained the age of majority in their respective
    jurisdiction. All persons who do not meet these criteria are strictly forbidden from accessing or
    viewing the contents of the Website. We do not knowingly seek or collect any personal information
    from persons who have not attained the age of eighteen (18).
For the purposes of this privacy policy:
  1. when we refer to “personal data” or “personal information” we mean data which identifies or may
    identify you and which may include, for instance, your email or IP address;
  2. when we refer to “processing” we mean the handling of your personal data by us, including
    collecting, protecting and storing your personal data; and
  3. when we refer to “sensitive data” we mean personal data which may reveal information about racial or
    ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental
    health, sexual life, genetic or biometric data.

  • 2. How we collect your personal data

    We obtain your personal data mainly through any information you provide directly to us
    through our Website. Below is a list of ways we collect your personal data:
    1. when you visit and/or use our Website;
    2. when you complete our registration form,
    3. when you post materials or upload content;
    4. when you take part in surveys or report a problem with our Website; or
    5. when you contact with us via email, post or other ways of communication.

  • 3. If you fail to provide personal data

    Where we need to collect and process your personal data in order to provide you with our
    services and you fail to provide that data when requested, we may not be able to provide
    you with access to our Website and/or the services we offer. In this case, we may have
    to suspend your access to the Website or, if you are a Member, prohibit any access to
    non-public areas of the Website or restrict the operation of your account and the
    services we provide to you.

  • 4. Personal data that we collect and process

    We will collect different categories of personal data from you depending on your level
    of interaction with our Website. We will limit the collection and processing of
    information to information necessary to achieve one or more of our legitimate purposes
    as identified in this privacy policy.
    1. Personal data we collect and process from Browsers
      1. Technical Data, including your Internet Protocol (IP) address,
        your browser type and version, time zone setting and location, browser plug-in
        types and versions, smart device information, mobile phone network information,
        operating system and platform and other technology on the devices you use to
        access this Website;
      2. Usage Data, including your communication preferences and
        information about how you use our Website including the services you viewed or
        searched for, page response times, download errors, length and number of visits
        and page interaction information (such as scrolling, clicks and mouse-overs) as
        well as the links you clicked on or used.
      3. User Submitted Data, including data collected for a specific
        function, for instance a contest or a survey; and
      4. Consents, including any permissions, consents or preferences
        that you give to the Website.
    2. Personal data we collect and process from Members
      1. All personal data we collect from Browsers, set out in paragraph 4(a) above;
      2. Identity and Contact Data, including username or similar
        identifier, password and email address. We may also collect a Member’s photo or
        video, if such is uploaded to a Member’s profile;
      3. User Submitted Data, including data collected at your
        discretion for a specific function, for instance your username and password,
        your interests, preferences, feedback and survey responses, or any text, images,
        videos, blog posts, forum comments or other content or media you choose to
        upload on the Website;
      4. Marketing Data, including preferences in receiving marketing
        from us and third-parties; and
      5. Communications, including information on how and what methods
        we use in order to communicate with you through electronic and verbal
        correspondence.
    We may also collect, use and share aggregated data such as statistical or demographic
    data for the purpose of customizing our marketing efforts or the use of our Website.
    Aggregated data may be derived from your personal data but is not considered personal
    data as this data does not directly or indirectly reveal your identity. For instance, we
    may aggregate your Usage Data to calculate the percentage of users accessing a specific
    Website feature, to generate statistics about our users, to calculate ad impressions
    served or clicked on, or to publish visitor demographics. If we combine or connect
    aggregated data with your personal data so that it can directly or indirectly identify
    you, we will treat the combined data as personal data which shall be used in accordance
    with this privacy policy.

  • 5. Automated personal data collection

    As you navigate through and interact with our Website, we will automatically collect
    Technical Data about your equipment, browsing actions and patterns. We collect these
    data by using cookies and other similar technologies.

  • 6. Why we need your personal data and how we use it

    We will only use and share your personal information where it is necessary for us
    to provide you with our lawful services in accordance with this privacy policy. We
    would like to ensure that you fully understand why your information may be used.
    We will most commonly use your personal data in the following circumstances:
    1. where we need to perform our services to you, as necessary in accordance with
      our Website’s Terms of Use;
    2. where it is necessary for our legitimate interests (or those of a third party)
      and your interests and fundamental rights do not override those interests;
    3. where we need to comply with a legal obligation; and/or
    4. where you have given us your consent.
    Below, we describe these circumstances in further detail.
    1. Performance of our services to you
      1. Provision of services (Members Only)
        We may collect and process your personal data where it is necessary in order to present our Website and
        its contents to you, including any interactive features on our Website and to provide you with
        information or services that you request from us.
        Please note that if you do not agree to provide us with the requested information, it may not be
        possible for us to continue to operate your account and/or provide you with the services we provide to
        our Members.
      2. Customer management (Members Only)
        We may collect and process your personal data where it is necessary in order to manage a Member’s
        account, to provide customer support and notices to Members about their account and subscription,
        including expiration and renewal notices, and notices about changes to our Website or any services
        we offer or provide through it.
    2. Legitimate interests
      1. Customization of content (Members Only)
        We may collect and process your personal data where it is necessary in order to perform
        research and analysis about your use or, or interest in, our Website content and/or
        services, so as to develop and display content and advertising tailored to your interests on
        our Website.
      2. Analytics
        We may collect and process your personal data where it is necessary in order to determine
        whether users of the Website are unique, or whether the same user is using the Website on
        multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages
        viewed and demographic patterns.
      3. Functionality and security
        We may collect and process your personal data where it is necessary in order to diagnose or
        fix technology problems, and to detect, prevent and respond to actual or potential fraud,
        illegal activities, or intellectual property infringement.
      4. Other legitimate interests
        In addition to the above, we may process your data, to the extent required for our business
        needs in order to:
        1. develop new services on our Website as well as analyze and target new markets;
        2. protect our legal rights and interests (including legal claims and preparing our defense
          in litigation);
        3. monitor, maintain and improve internal business processes, information and data,
          technology and communication solutions and services;
        4. ensure network information security, including monitoring Browsers’ and Users’ access to
          our information technology for the purpose of preventing cyber-attacks, unauthorized use
          of Website and prevention or detection of crime;
        5. send you relevant marketing information (including details of other services provided by
          us which we believe may be of interest to you), but only where you are a Member of the
          Website;
        6. monitor the performance and effectiveness of our services and the Website; and
        7. assess the quality of our customer services.
    3. For compliance with legal obligations
      When you visit and/or use and/or register in our Website (and throughout your relationship with us),
      we are required to comply with certain legal and regulatory obligations which may involve the
      processing of your personal data. This may include processing to:
      1. perform checks and comply with laws relating to fraud;
      2. identify other infringements of our Terms of Use; and
      3. manage contentious regulatory matters, investigations and litigation.
    4. You have provided your consent
      We will only ask for your consent when we wish to provide marketing information to you in relation
      to our services which we believe may be of interest and of benefit to you, but only where you are a
      Browser.
      You have the right to revoke your consent at any time. However, any processing of personal data
      prior to the receipt of your revocation will not be affected.

  • 7. Who we share your personal data with

    It is our policy not to use or share personal data about you in ways unrelated to those described in
    this privacy policy without also providing you with an opportunity to opt out or otherwise object to
    such unrelated uses. However, we may disclose personal data about you, or information regarding your
    use of the services or the Website to third parties for any of the reasons set out hereinabove, or
    if we are legally required to do so, or if we are authorized under our contractual and statutory
    obligations. When we disclose your personal data to service providers, we will ensure that they are
    bound by a contract requiring them to comply with their GDPR obligations. Under the circumstances
    referred to above, recipients of personal data may be, for example:
    1. members of our corporate group which operate partner websites such as lecoinporno.fr,
      to the extent this is necessary for the purposes set out in this privacy
      policy and to enable you to have access to certain features;
    2. service providers;
    3. governmental and regulatory bodies, including law enforcement authorities, in connection with
      enquiries, proceedings or investigations by such parties or in order to enable the Company to
      comply with its legal and regulatory requirements. We specifically reserve the right to disclose
      any and all information to law enforcement in the event that a crime is committed or suspected
      or if we are compelled to do so by lawful criminal, civil or administrative process, discovery
      requests, subpoenas, court orders or writs;
    4. buyers or other legal successors in the event of a merger, divestiture, restructuring,
      reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a
      going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal
      information held by us about our Website Members and Browsers is among the assets transferred.
      Should such a sale or transfer occur, we will use reasonable efforts to ensure that the entity
      to which we transfer your personal data uses it in an manner that is consistent with this
      privacy policy; and/or
    5. legal or other professional consultants.
    We may also disclose aggregated information about our users, and information that does not identify
    any individual, without restriction. We also may share aggregated information with third-parties for
    conducting general business analysis. This information does not contain any personal data and may be
    used to develop content and services that we hope you and other users will find of interest.
    Please note that we have never sold and will never sell your personal data to third parties.

  • 8. Members’ Profile

    Members should be aware that all information directly provided on the Website when they create an
    account is public and can be viewed by all other Members and Browsers of the Website, unless
    otherwise stated. Even if a Member’s profile does not contain any personal information, there is a
    possibility of identification by others through other information on the Member’s profile.
    Accordingly, Members should understand that they are in control of all of the information they
    upload on the Website and/or display on their profile and are fully responsible for any consequences
    arising out of such information.

  • 9. Security of your personal data

    We take appropriate security measures (including physical, electronic and procedural measures) to
    safeguard your personal data from unauthorized access and disclosure. For instance, only authorized
    employees are permitted to access personal data, and they may do so only for permitted business
    functions. In addition, we use encryption in the transmission of your personal data between your
    system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to
    your personal data. However, please be advised that we cannot fully eliminate security risks
    associated with the storage and transmission of personal data as we cannot guarantee that our
    security measures will prevent third-party hackers from illegally obtaining this information.
    You are responsible for maintaining the secrecy of your unique password and account information at
    all times. We are not responsible for circumventions of any privacy settings or security measures
    contained on the Website.

  • 10. Information we transfer

    Some of our external third parties are based outside the European Economic Area (“EEA”) so the
    processing of your personal data will involve a transfer of data outside the EEA.
    Whenever we transfer your data outside the EEA, we ensure a similar degree of protection is afforded
    to it by ensuring at least one of the following safeguards is implemented:
    1. We will only transfer your personal data to countries that have been deemed to provide an
      adequate level of protection for personal data by the European Commission.
    2. Where we use service providers outside the EEA, we may use specific contracts approved by the
      European Commission which give personal data the same protection it has in the European Union.
    3. Where we use providers based in the US, we may transfer data to them if they are part of the
      Privacy Shield which requires them to provide similar protection to personal data shared between
      the European Union and the US.
    We may additionally, in rare occasions, transfer your personal data to a party outside the EEA where
    we have your prior explicit consent to do so or where such transfer is necessary for the provision
    of our services to you.

  • 11. Marketing information

    We may process your personal data so as to inform you about existing and/or future services that may
    be of interest to you by sending you periodic announcements with details on existing and/or new
    services and/or programs.
    You have the right to object at any time to the processing of your personal data for marketing
    purposes, by clicking at the opt-out link at the bottom of any marketing emails we send you.
    We can only use your personal data to promote our services to you if we have your explicit consent
    to do so, or in certain cases such as for example when you are a Member of our Website, if we
    consider that it is in our legitimate interest to do so. You may also occasionally receive marketing
    communications from our affiliates, but only provided you have given your explicit consent in
    receiving such communications.
    Even if you inform us that you no longer wish to receive marketing material, you will still receive
    from us system notices and other information specifically related to your account from time to time.

  • 12. How long we keep your personal data for

    We will only keep your personal data for as long as necessary to fulfill the purposes we collected
    it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We
    may retain your personal data for a longer period in the event of a complaint or if we reasonably
    believe there is a prospect of litigation in respect of our relationship with you.
    To determine the appropriate retention period for personal data, we consider the amount, nature and
    sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of
    your personal data, the purposes for which we process your personal data and whether we can achieve
    those purposes through other means, and the applicable legal requirements.
    Where we no longer need to process your personal data for purposes set out in this privacy policy,
    we will delete your personal data from our systems. However, we may keep your data for longer if we
    cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your
    privacy is protected and that your data are only used for those purposes.
    If you have questions about our data retention practices, please contact us electronically by
    sending as an email at [email protected].

  • 13. Your data protection rights

    We want to make sure you are aware of your rights in relation to the personal data we process about
    you. We have described those rights and the circumstances in which they apply further below.
    1. Access: This enables you to get access or receive a copy of the personal data
      that we hold about you and to check that we are lawfully processing it.
    2. Correction: If you believe that any of the information that we hold about you
      is inaccurate or incomplete, you have a right to request that we correct the inaccurate personal
      information.
    3. Erasure: You may request that we delete your personal information if you
      believe that:
      1. we no longer need to process your information for the purposes for which it was
        provided;
      2. we have requested your permission to process your personal information and you wish to
        withdraw your consent; or
      3. we are not using your information in a lawful manner.
      As a result of deleting your personal information, you will lose access to most of our
      services.
      Grace period: There is a 45 day grace period
      before we proceed with erasure. During this Grace Period you will be allowed to restore your
      account. The grace period functionality allows you not to lose any important information and
      options by mistake. After the expiration of the grace period however, your account will be
      deleted.
    4. Right to object: You have the right to object to the processing of your
      personal data where we are relying on a legitimate interest and there is something about
      your particular situation which makes you want to object to processing on this ground. If
      you exercise your right to object, we will no longer process your personal data unless we
      can demonstrate compelling legitimate grounds for the processing which override your
      interests, rights and freedom or for the establishment, exercise and defense of legal
      claims.
      If you object to processing for direct marketing purposes, then we
      shall stop the processing of your personal data for such purposes.
      Depending on the circumstances, we may need to restrict or cease
      processing your personal data altogether or, where requested, delete your personal data.
      Please note that if you object us processing your personal data, we may have to suspend the
      services we provide to you.
    5. Restriction: You have the right to request the restriction of processing of
      your personal data. This enables you to ask us to restrict the processing of your personal
      data if:
      1. it is not accurate; or
      2. it has been used unlawfully but you do not want us to delete it; or
      3. it is not relevant any more, but you want us to keep it for use in possible legal
        claims; or
      4. you have already asked us to stop using your personal data but you are waiting for us to
        confirm if we have legitimate grounds to use your personal data.
      Please note that if you request us to restrict processing of your personal data, we may have
      to suspend the services we provide to you.
    6. Right to portability: Where we have requested your permission to process
      your personal data or you have provided us with information for the purposes of entering
      into a contract with us, you have the right to receive the personal data you provided to us
      in a portable format. You may also request us to provide it directly to a third party, if
      technically feasible. We are not responsible for any such third party’s use of your account
      information, which will be governed by their agreement with you and any privacy statement
      they provided to you.
    If we ask for your consent to use your personal data, you can withdraw your consent at any time.
    Please note that in case of a withdrawal of your consent you may no longer be able to use several
    functionalities of our Website and our services.
    Please note that some requests to delete certain personal data will require the deletion of your
    account as a Member as the provision of Member accounts is inextricably linked to the use of certain
    personal data (e.g. your email address). Also note that it is possible that we require additional
    information from you in order to verify your authorization to make the request and to honor your
    request.
    To exercise any of your rights, or if you have any other questions about our use of your personal
    data, please contact us electronically by sending us an email at [email protected].
    We endeavor to address all your requests promptly.

  • 15. Our communication with you

    If you have any questions about this privacy policy or our information-handling practices, please
    contact us electronically at [email protected].

  • 16. Right to complain

    If you have any questions about this privacy policy, or wish to lodge a complaint about how your
    personal data is used by the Company, you may contact us electronically at the email address
    [email protected].
    Upon receipt of your complaint, we will investigate it and respond to you within a reasonable time.
    You also have the right to complain to the data protection supervisory authority of the country in
    which you reside, provided that such country is a Member State of the European Union or is located
    within the EEA.

  • 17. Our policy towards minors

    Our Website is not directed to individuals under the age of eighteen (18) or the applicable age of
    majority in the jurisdiction from which the Website is accessed and we do not knowingly collect
    personal data from minors. If you become aware that your child has provided us with personal data,
    please contact us electronically at [email protected]. If we become aware that a minor has provided
    us with personal data, we will take steps to remove such information and terminate that person’s
    account immediately.

  • 18. Third-party links

    Our Website may include links to third-party websites, plug-ins and applications. Clicking on those
    links or enabling those connections may allow third parties to collect or share data about you. We
    do not control these third-party websites and are not responsible for their privacy statements. We
    specifically disclaim responsibility for their content, privacy practices and terms of use, and we
    make no endorsements or representations about their accuracy, content or thoroughness. When you
    leave our Website, we encourage you to read the privacy policy of every website you visit.

  • 19. Changes to this privacy policy

    We reserve the right to update, revise, amend and/or modify this privacy policy at any time in order
    to reflect any changes to the way in which we process your personal data or changing legal
    requirements.
    Although we will notify you when major changes are made to this privacy policy, you are expected to
    periodically review the most up-to-date version found at https://lecoinporno.fr/politique-de-confidentialite/ so you
    are aware of any changes. The date of the latest version of the privacy policy will appear at the
    top of the webpage hosting the policy.

  • 20. Cookies

    As we have briefly mentioned in this privacy policy, our Website uses small files known as cookies
    to make it work better in order to improve your experience.