Privacy Policy

Effective Date: March 9th, 2025
Last Modified: March 9th, 2025

1. Introduction

Welcome to the Privacy Policy (the “Policy”) for the websites and online services operated by Adam Szokol (“I,” “me,” or “my”). These include, but are not limited to, adamszokol.com and adamszokol.me, along with any subdomains, affiliated model-specific sites, or other online properties (collectively, the “Websites” or the “Platform”). This Privacy Policy is designed to inform you—whether you are a visitor, registered user, or content creator (collectively, “User” or “you”)—about the ways in which I collect, use, store, secure, process, transfer, and disclose your Personal Data (as defined below).

Your privacy is extremely important to me, and I am committed to maintaining robust privacy protections for each individual user in accordance with applicable data protection laws and regulations, including, when applicable, the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR) of the European Union, and Nevada’s relevant privacy statutes. This detailed Privacy Policy aims to explain your rights and how you can exercise them, the type of information I collect about you, how I use and protect such information, and under what circumstances I may share that information with third parties.

By using the Websites, you consent to the data collection, usage, storage, and disclosure practices described in this Policy. If you do not agree with any part of this Privacy Policy, please discontinue your use of the Websites immediately. Your continued use of the Websites constitutes your acceptance of and agreement to all terms described here.

Given the volume of legal and practical considerations, this Policy is quite comprehensive (well over 7,000 words). Please take the time to read it carefully. If you have any questions, do not hesitate to contact me at info@adamszokol.com.

2. Who I Am

  • Name: Adam Szokol
  • Email: info@adamszokol.com
  • Phone: +1 (845) 793-0554
  • Address: 2300 Rock Springs Drive, Apt 1145, Las Vegas, NV, USA
  • EIN: 98-1746218 (Federal Employer Identification Number)
  • NVID: NV20243262283 (Nevada Business Identification Number)

Oracle Corporation provides hosting services for the Websites (address: 2300 Oracle Way, Austin, TX 78741, USA). I also work with Bank of America, N.A. / Bank of America Corporation and with HSBC Bank Australia Limited for certain payment and financial transactions. Additional details about these relationships are contained within this Policy.

3. Scope and Definitions

3.1 Scope

This Privacy Policy applies to the Websites and any services, tools, applications, or functionalities I provide via the Websites. It governs any and all usage by Users, whether or not they register for an account, purchase items or subscriptions, or simply browse as a guest.

This Privacy Policy:

  • Describes the types of Personal Data I collect.
  • Explains how I use that Personal Data.
  • Details the instances in which I share, disclose, or transfer Personal Data.
  • Outlines your rights and choices with respect to your Personal Data (including how to opt out of certain uses).
  • Explains the security measures in place to protect your Personal Data.
  • Discusses international data transfers and relevant compliance obligations.

3.2 Definitions

For clarity and consistency, here are some of the key definitions used in this Privacy Policy. These terms are used in many data protection regulations (like GDPR and CCPA) but can vary in meaning depending on the jurisdiction:

  1. Personal Data: Any information relating to an identified or identifiable natural person (also called a “data subject”). In different jurisdictions, Personal Data may also be called “personally identifiable information” or “personal information.” Examples include your name, email address, mailing address, IP address, device identifiers, or anything else that can be linked back to you individually or combined to identify you.
  2. Processing: Any operation or set of operations performed on Personal Data (e.g., collecting, recording, organizing, storing, retrieving, using, disclosing by transmission, disseminating, aligning, erasing, destroying, etc.).
  3. Controller (GDPR-specific term): The natural or legal person, public authority, agency, or other body that determines the purposes and means of processing Personal Data. For the purposes of the GDPR (if it applies), I am typically the Controller of Personal Data processed via the Websites.
  4. Processor (GDPR-specific term): A natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Controller (e.g., hosting providers, analytics providers, email marketing providers). I use several processors in order to operate the Websites effectively.
  5. Service Providers: Individuals or entities that assist me with various business operations, which may involve the processing of Personal Data on my behalf (e.g., web hosting services, payment processing services, analytics, marketing support). They are typically bound by contractual obligations to protect your Personal Data.
  6. Cookies: Small text files stored on your device by websites you visit, often used to remember your preferences, login sessions, or track your browsing activity. Other related technologies (e.g., web beacons, pixels) are also included when I refer to “cookies.”
  7. CCPA: The California Consumer Privacy Act of 2018 (as amended by the CPRA), which grants California residents specific rights over their Personal Data.
  8. GDPR: The General Data Protection Regulation (EU 2016/679), regulating data protection and privacy for individuals within the European Union. This includes the UK GDPR for the United Kingdom, with certain modifications post-Brexit.
  9. Nevada Privacy: Nevada’s privacy law (SB 220) and other relevant provisions that apply to consumers who are residents of Nevada, offering certain opt-out rights regarding Personal Data sales.

4. Summary of Key Points

In this extended, in-depth Privacy Policy, you will find:

  • What data is collected: Including both data you provide (e.g., contact forms, account creation) and data collected automatically or from third parties (e.g., usage data, cookies, analytics).
  • Why it is collected: To provide services, personalize experiences, comply with legal obligations, and more.
  • How it is used and shared: With service providers, analytics, legal authorities when required, and other third parties as specified.
  • Your rights: Access, correction, deletion, opt-out, data portability, and more, depending on your jurisdiction.
  • Data retention: Criteria for how long we keep your Personal Data.
  • Security measures: Encryption, secure hosting, and procedural safeguards.
  • International data transfers: Data might be stored and processed in the United States and possibly other jurisdictions.
  • Procedures for children: Limitations and compliance with child protection laws (e.g., Children’s Online Privacy Protection Act or “COPPA” in the U.S. and equivalent laws worldwide).
  • Changes to this Policy: Future updates and how I will notify you.

5. Data Collection and Categories of Personal Data

I collect different types of data, some of which may be considered Personal Data under applicable law. These data categories are collected either directly from you, automatically (through cookies, logs, or other tracking technology), or from third-party partners.

5.1 Data You Provide Directly

  1. Contact Information: Such as your name and email address when you fill out contact forms, subscribe to newsletters, or communicate with me (e.g., via email).
  2. Account Creation Data: If you create an account on the Websites, I may collect your username, password, email address, profile picture, and/or phone number (if you choose to provide it).
  3. Transaction Data: If you make a purchase, contribute to a content creator, or subscribe to certain paid features, I may collect billing details, shipping address (when relevant, such as for merchandise), and limited payment information (the bulk of which is typically handled by third-party payment processors like Bank of America or HSBC Bank Australia Limited).
  4. Support Requests and Correspondence: If you contact me for support or participate in a survey, promotional event, or request user support, I may maintain records of your communication and the accompanying details you provide.
  5. User-Generated Content: You may upload, post, or share content on the Websites. This can include text, images, videos, audio, or comments in forums or discussion areas. The nature of this content might reveal additional information about you, such as your preferences, opinions, or other personal details, depending on what you choose to share.

5.2 Data Collected Automatically

  1. Device Data: When you visit the Websites, I automatically collect your IP address, browser type/version, operating system, language settings, and other similar device identifiers.
  2. Usage Data: Information about your interactions with the Websites, including pages viewed, the path you take within the Websites, time spent on each page, referral URLs, the date/time stamps of your visit, and any links you click.
  3. Cookies and Similar Technologies: I use cookies (both first-party and third-party), web beacons, pixel tags, and similar tracking technologies to store and retrieve small pieces of data on your device. These tools help me recognize you across different pages of the Websites or different visits, track your usage patterns, and personalize or optimize your experience. See the Cookies & Tracking Technologies section for more details.

5.3 Data From Third Parties

  1. Advertising Partners: I partner with third-party ad networks (e.g., Traffic Stars Limited) to serve advertisements on the Websites. These partners may use their own tracking technologies to collect data about your online activities across different websites to provide you with targeted ads.
  2. Social Media Platforms: If you choose to log in or interact with the Websites using social media login features (e.g., “Login with Facebook” or “Sign in with Google”), I may receive information from those platforms such as your name, profile photo, or other account details, depending on your privacy settings on that platform.

5.4 Special Categories of Data (GDPR)

Under the GDPR, certain categories of data are considered “special” (e.g., health data, biometric data, sexual orientation, political opinions). Generally, I do not intentionally collect or request these categories of data. However, due to the nature of user-generated content—particularly if the Platform has adult-oriented sections—users may voluntarily provide or reveal information that could be considered “special category” data. If you do provide such information, you are consenting to my processing of that data in accordance with this Privacy Policy.

6. Lawful Basis for Processing (For GDPR/EEA/UK Users)

Where the GDPR or similar legislation applies, I must have a lawful basis to process your Personal Data. Depending on the context of collection and the nature of the Personal Data, these lawful bases may include:

  1. Consent (Article 6(1)(a) GDPR): You have given clear consent for me to process your Personal Data for a specific purpose. For example, when you opt in to receive marketing communications, you are consenting to receive emails from me.
  2. Performance of a Contract (Article 6(1)(b) GDPR): Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract (e.g., if you purchase a subscription or other product).
  3. Legal Obligation (Article 6(1)(c) GDPR): Processing is necessary to comply with a legal obligation (e.g., tax obligations, or responding to lawful requests from authorities).
  4. Legitimate Interests (Article 6(1)(f) GDPR): Processing is necessary for my legitimate interests (or those of a third party), except where overridden by your fundamental rights and freedoms. This might include security monitoring, analytics, or direct marketing in certain circumstances.

Where I rely on your consent, you have the right to withdraw that consent at any time by contacting me at info@adamszokol.com or by following unsubscribe instructions in the relevant communication. Withdrawal of consent does not retroactively affect the lawfulness of processing done before your withdrawal.

7. Purposes for Processing Personal Data

7.1 Provision of Services and Functionality

I primarily collect and process your data to:

  1. Provide and Optimize Website Functionality: Ensure the Websites function correctly, load quickly, and present content in an optimal format for your device.
  2. Account Management: Create and administer user accounts, authenticate your logins, manage subscriptions or access entitlements, and provide user support.
  3. Personalization: Tailor the content, recommendations, or advertisements you see based on your previous browsing or indicated interests, which can enhance your experience.

7.2 Communications and Customer Service

I may use your contact details (like email address or phone number) to:

  1. Send Notifications and Updates: For example, transactional emails related to subscription renewals, account changes, or technical or security notices.
  2. Respond to Queries or Support Requests: If you reach out for help or report a technical issue, I will use your information to troubleshoot and resolve the matter.
  3. Promotional Communications: If you have opted in, I may send marketing materials, newsletters, or other promotional messages about new features or content, subject to your preferences and the legal requirements in your jurisdiction.

7.3 Transactions and Financial Operations

When you make a payment, I need to:

  1. Process Your Transaction: This includes verifying your payment method, billing you, and confirming your purchase or subscription.
  2. Prevent Fraud: Monitoring transactions for suspicious activity or potential fraud.
  3. Comply With Financial or Tax Regulations: Retain financial records for audits, tax compliance, or other legal reporting obligations.

7.4 Analytics and Performance

I use analytics services to:

  1. Measure Website Performance: Track metrics like page load times, server uptime, traffic volume, user engagement, and demographic data.
  2. Identify Trends and Preferences: Understand how Users interact with different sections of the Websites to enhance usability, fix bugs, or develop new features.

7.5 Compliance with Legal Obligations

I may process or disclose your data if required to:

  1. Comply with Court Orders, Subpoenas, or Other Legal Processes: Provide data to law enforcement or regulatory bodies when legally mandated.
  2. Enforce My Terms of Service or Other Agreements: Investigate or address possible breaches, respond to claims, or protect my rights, property, or safety, or that of others.
  3. Prevent Harm or Illegality: If I believe it’s necessary to detect, prevent, or address illegal or harmful activities, such as suspected fraud or potential threats to personal or public safety.

7.6 Other Legitimate Interests (Where Lawful)

I may also process your Personal Data for other legitimate interests not specifically described above, but only if they do not override your fundamental rights and freedoms, and if I inform you or obtain your consent where required by law.

8. Disclosure and Sharing of Personal Data

8.1 Service Providers and Processors

I engage third-party companies and individuals to facilitate my services and Websites. These “Service Providers” or “Processors” carry out tasks on my behalf, such as:

  • Hosting Services: (e.g., Oracle Corporation, located at 2300 Oracle Way, Austin, TX 78741, USA) to store and manage data.
  • Payment Processing: (e.g., Bank of America, N.A. and HSBC Bank Australia Limited) for secure handling of credit/debit card information, bank transfers, and other payment methods.
  • Marketing and Email Services: Tools for sending out email campaigns or newsletters.

These Service Providers only access your Personal Data to perform tasks on my behalf and are contractually obligated not to disclose or use it for other purposes. I take steps to ensure these parties implement reasonable security measures to protect your Personal Data in accordance with applicable law.

8.2 Advertising Partners

  1. Traffic Stars Limited: This partner may serve advertisements on my Websites, collecting data about your activities to deliver targeted ads. For certain Websites (e.g., adamszokol.me), it provides adult-oriented ad content and may use cookies or similar technologies to track user activity.

Because these advertising partners have their own privacy policies, I recommend you review them:

TRAFFIC STARS LTD is a company duly registered in the Republic of Cyprus under registration number HE 335138 having its registered office and head office at Arch. Makariou III, 124, AGROTIS COURT, Floor 1, 3021, Limassol, Cyprus.

8.3 Legal and Regulatory Disclosures

I may disclose your Personal Data if:

  • Legally Required: I receive a lawful request (e.g., a subpoena or court order) or need to comply with applicable law or regulations.
  • Protective Measures: I believe disclosure is necessary to enforce or protect my rights, property, or safety; to investigate fraud or violations of this Policy; or to respond to an emergency that could threaten someone’s physical safety.

8.4 Business Transfers

If I engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction, your Personal Data may be transferred as part of that transaction. In such an event, I will endeavor to ensure the recipient of your Personal Data is bound by terms substantially similar to those in this Privacy Policy. If the new entity intends to use your Personal Data in a manner different from that stated in this Policy, I will notify you and/or provide you with a choice before your data is used in such a manner, as required by law.

8.5 Aggregated or De-Identified Data

I may also share aggregated or de-identified data (i.e., data that cannot reasonably be used to identify you) with my affiliates, partners, or research institutions for business, research, or statistical purposes. This type of data does not fall under “Personal Data” as per most privacy regulations, and thus I may use it for lawful business purposes.

9. Cookies & Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They can be “session cookies” (which expire as soon as you close your browser) or “persistent cookies” (which remain on your device until a set expiration date or until you delete them). Cookies can serve various purposes: ensuring site functionality, providing personalized content or settings, and enabling analytics or advertising tracking.

9.2 Types of Cookies I Use

  1. Strictly Necessary Cookies: Essential for the Websites to function properly (e.g., enabling you to log in, navigate between pages, and access secure areas). Disabling these may prevent core site features from working.
  2. Functional Cookies: Allow me to remember preferences and settings to improve your experience (e.g., language selection, saved items in a cart).
  3. Performance/Analytics Cookies: Collect information about how Users interact with the Websites, which helps me optimize design, functionality, and content. Examples include pages visited or links clicked.
  4. Advertising/Targeting Cookies: Used to deliver relevant advertisements and measure the effectiveness of ad campaigns. They track browsing habits, user interactions, and may tailor ads across multiple websites.

9.3 Third-Party Cookies

I allow certain third parties to place cookies on your device for advertising, or social media functionality. These third parties include:

  • Ad Networks (e.g., TrafficStars)
  • Social Media Platforms (if you interact with their plugins or use social logins)

Each such third party is responsible for their own cookie and data handling practices. I recommend that you review their respective cookie and privacy policies.

9.4 Managing Cookie Preferences

Most web browsers automatically accept cookies but allow you to delete or reject them through the browser settings. Methods for managing cookies vary from browser to browser, so refer to your browser’s “Help” section for detailed instructions. You may also generally opt out of data collection by certain third-party ad networks by visiting:

Be aware that blocking or disabling cookies can affect site functionality. Some features (such as maintaining a logged-in session, remembering preferences, or personalizing content) might not work if you disable or remove cookies.

9.5 Do Not Track Signals

“Do Not Track” (DNT) is a preference you can set in some web browsers to inform websites that you do not want to be tracked. Currently, there is no universal standard for recognizing or honoring DNT signals, and I do not respond to these signals in a standardized way. I continue to review new technologies and may adopt a standardized protocol if one is established.

10. Data Retention

I retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, unless I am required by law or regulation to retain it longer. Specific retention periods vary depending on:

  • The nature of the data (e.g., transaction data vs. email correspondence).
  • The reason for collection (e.g., contractual obligations, compliance with legal obligations, legitimate business interests).
  • Ongoing business relationships (e.g., whether you maintain an active account).
  • Applicable statutes of limitations (e.g., I may retain certain data to comply with law enforcement or to defend legal claims).

Generally:

  • Account Data: Retained as long as you maintain an account. If your account is closed or inactive, I typically remove or anonymize your data within 30 days, unless legal obligations require a longer retention.
  • Financial/Transaction Data: Retained to comply with tax, audit, and financial record-keeping obligations, typically 7 years in many jurisdictions, or longer if required.
  • Communications and Support: Retained until the query or issue is resolved, plus a reasonable period for follow-up, unless further retention is necessary for audit or legal purposes.
  • Marketing Data: Retained until you opt out of marketing communications or otherwise withdraw your consent (if consent is required).

When I no longer have a legitimate need to process your Personal Data, I will either securely delete, destroy, anonymize, or aggregate it to ensure it no longer identifies you.

11. Children’s Privacy

11.1 General Note

The Websites are not generally directed to children under the age of 13, and I do not knowingly collect or solicit Personal Data from children in this age group. If you are under 13 (or under 16 if you are in the European Economic Area, unless otherwise specified by your jurisdiction’s laws), do not use or provide any information on the Websites.

11.2 Adult-Oriented Content

Portions of my Websites may contain or display adult-oriented content (nudity or sexually explicit material). Access to such content is restricted to individuals 18 years of age or older (or the age of majority in their respective jurisdictions), unless you see a specific banner indicating “Are you 18 or older?” In that case, the minimum age is 18. Where the Website does not display the adult restriction banner, a minimum age of 13 applies. This policy overwrites any other restriction indicated elsewhere or in other policies for those specific Websites that do not display the banner.

11.3 COPPA Compliance (U.S. Users)

I comply with the U.S. Children’s Online Privacy Protection Act (COPPA). If it comes to my attention that I have collected Personal Data from a child under 13 without parental consent, I will delete it promptly. If you believe I might have any data from or about a child under 13, please contact me at info@adamszokol.com.

12. Security Measures

I implement a variety of reasonable security measures to help protect against the loss, misuse, and alteration of the Personal Data under my control, including:

  • Encryption: Sensitive data (such as payment details) is transmitted over secure socket layer (SSL/TLS) encryption.
  • Access Controls: Only authorized personnel with a legitimate business need can access systems and data.
  • Firewalls and Intrusion Detection Systems: To prevent unauthorized external access.
  • Regular Audits and Testing: Periodic security assessments, vulnerability scans, and patching of known security issues.

Despite these precautions, no system is completely secure. Therefore, while I strive to protect your Personal Data, I cannot guarantee absolute security. If you have reason to believe your interaction with the Websites is no longer secure (e.g., if you believe your account has been compromised), please contact me immediately.

13. International Data Transfers

13.1 Location of Servers

My primary data centers are located in the United States (e.g., Oracle Corporation facilities). If you are accessing the Websites from outside the U.S., be aware that your data may be transferred to, stored, and processed in a country that may have different data protection standards than those in your country of residence.

13.2 EU-U.S. and Swiss-U.S. Transfers

To comply with the GDPR’s cross-border data transfer requirements, I may rely on:

  • Adequacy Decisions: In limited cases, if the receiving country is deemed by the European Commission to have an adequate level of data protection.
  • Standard Contractual Clauses (SCCs): I may incorporate the most recently approved sets of standard contractual clauses for transferring data from the EEA/UK/Switzerland to third countries.
  • Consent: In certain instances, with your explicit consent, I may transfer Personal Data outside of the EEA/UK.
  • Legitimate Interests: If necessary for the performance of a contract or legal claims.

13.3 Additional Safeguards

Wherever your Personal Data is transferred, I will implement appropriate safeguards (such as contractual obligations) to ensure the recipient of your Personal Data provides a level of protection equivalent to that under your jurisdiction’s data protection laws. If you wish to inquire more about these safeguards, contact me at info@adamszokol.com.

14. Your Rights and Choices

Depending on the laws of your jurisdiction, you may have some or all of the following rights regarding your Personal Data. These rights may include (but are not limited to):

  1. Right of Access/Portability: Obtain confirmation as to whether your Personal Data is being processed, and request a copy of that data in a portable format (where feasible).
  2. Right of Rectification: Request corrections of inaccurate or incomplete Personal Data.
  3. Right of Erasure (“Right to be Forgotten”): Ask me to delete or remove Personal Data when there is no compelling reason for continued processing, subject to exceptions set by law (e.g., compliance with a legal obligation).
  4. Right to Object: Object to certain forms of data processing, such as direct marketing or when the legal basis is a legitimate interest.
  5. Right to Restrict Processing: In certain circumstances, request that I temporarily or permanently stop processing all or some of your Personal Data.
  6. Right to Withdraw Consent: If I rely on your consent to process your data, you can withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  7. Right to Non-Discrimination (CCPA-specific): If you are a California resident, you have the right not to be discriminated against for exercising your privacy rights under the CCPA.

To exercise any of these rights, please email info@adamszokol.com. I may ask you to verify your identity and provide additional information to fulfill your request. If I am unable to comply with your request (e.g., due to conflicting legal obligations), I will inform you of the reasons.

14.1 Additional Rights Under the CCPA (California Residents)

If you are a California resident, you may have additional rights, including:

  • Right to Know About Personal Information Collected, Disclosed, or Sold: You can request that I disclose which categories of Personal Information I have collected, the sources from which it was collected, the business purpose for collecting or selling, categories of third parties with whom it was shared, and the specific pieces of Personal Information I have collected about you.
  • Right to Delete: Subject to certain exceptions, you can request deletion of your Personal Information.
  • Right to Opt Out of Sales: If I “sell” Personal Information (as defined by CCPA), you may have the right to opt out of such sales. I do not believe I “sell” Personal Information under the CCPA’s definitions, but to the extent any data transfers or ad tracking might be considered a “sale,” I will honor your opt-out request.
  • Shine the Light Law (Cal. Civ. Code § 1798.83): If you have an established business relationship with me, you can request information regarding the disclosure of certain categories of Personal Data to third parties for their direct marketing purposes.

14.2 Additional Rights for Nevada Residents

Under Nevada law, residents can opt out of the sale of their covered information to third parties. As a Nevada resident, you can submit a request to opt out of such sales at any time by contacting me at info@adamszokol.com.

While I do not currently sell Personal Data as defined under Nevada law, I will maintain your request in the event that practices change.

15. Third-Party Websites and Services

The Websites may contain links to third-party websites, plug-ins, or applications that are not controlled or operated by me. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party sites, nor am I responsible for their privacy statements or practices. When you leave my Websites, I encourage you to read the privacy policy of every site or service you visit.

16. Model-Specific Sites and User-Generated Content

16.1 Model-Specific Sites

Some parts of the Websites or affiliated subdomains may be created or maintained on behalf of Models (adult content creators, for example) or other content creators. In these cases, the Model or creator may have partial control or oversight of the content on that sub-site, but I remain responsible for ensuring overall compliance with data protection laws. Models are instructed to follow this Privacy Policy and may not have direct access to all Personal Data about Users (beyond aggregated analytics or limited contact information, if shared).

16.2 User-Generated Content

Please be aware that any content (including Personal Data) you voluntarily share or submit for public posting on the Websites—such as in forums, chat rooms, or comment sections—may be visible to other Users. I cannot prevent the public disclosure or misuse of any information you post publicly. Therefore, exercise caution when deciding to disclose your Personal Data in these environments.

If you request removal of posted content that contains Personal Data from a publicly accessible area of the Websites, I will make reasonable efforts to remove it, but complete or comprehensive removal of the content (e.g., from caches or archives) may not be possible.

17. Business or Corporate Transactions

In the event that I enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or asset sale, or in the unlikely event I cease operations or enter bankruptcy, user data (including Personal Data) may be transferred or acquired by a third party. Under such circumstances, this Privacy Policy will continue to apply to your Personal Data, and the party receiving your data may continue to use it, but only as set forth in this Policy (unless you are notified otherwise and provided a choice when required by law).

18. Additional Information for Certain Jurisdictions

18.1 European Economic Area (EEA) and United Kingdom

  • Data Controller: For GDPR purposes, I, Adam Szokol, am typically the controller of your Personal Data.
  • Legal Bases: As described above.
  • Complaints: You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe your rights under GDPR have been violated.

18.2 California, USA

  • CCPA/CPRA: Residents are entitled to request additional disclosures about collection and sharing of Personal Data, as well as request access to or deletion of their Personal Data in certain cases. For more details, see Section 14.1.
  • Shine the Light: California Civil Code § 1798.83 gives you the right to request information regarding the disclosure of your Personal Data by me to third parties for their direct marketing purposes within the immediately preceding calendar year. To make such a request, please contact me at info@adamszokol.com.

18.3 Nevada, USA

  • SB 220: Residents have the right to request that operators refrain from selling their Personal Data. I do not currently sell Personal Data, as explained in this Policy. If that changes, you will be able to opt out. See Section 14.2.

19. Changes to this Privacy Policy

I reserve the right to update or modify this Privacy Policy at any time to reflect changes in law, privacy practices, the scope of services, or for any other reason I deem necessary. If I make material changes, I will notify you by posting the updated Policy on the Websites with a new “Last Modified” date and/or via email if you have provided one. All changes take effect immediately upon posting unless otherwise stated. By continuing to use the Websites after these changes become effective, you accept and agree to the revised Policy. If you do not agree with the changes, your sole remedy is to cease use of the Websites.

20. Your Choices and Opt-Out Options

  1. Account Deletion: If you have registered for an account and wish to delete it, please contact me at info@adamszokol.com. Once deleted, your account data will be removed or anonymized, except to the extent retention is required by law (e.g., transaction records for tax purposes).
  2. Email Marketing: You can unsubscribe from marketing emails at any time by clicking the “unsubscribe” link at the bottom of such emails or by emailing me at info@adamszokol.com.
  3. Advertising Preferences: Refer to your browser settings or the relevant third-party ad networks to manage your advertising preferences.
  4. Cookie Management: Use your browser settings to control or block cookies. See the Cookies & Tracking Technologies section for more details.

21. Payment Services and Financial Data

21.1 Payment Processing Partners

Transactions on the Websites (e.g., purchases, subscriptions, or content unlocks) may be processed by third-party payment processors, including but not limited to Bank of America, N.A. / Bank of America Corporation (100 North Tryon Street, Charlotte, NC 28255, USA) and HSBC Bank Australia Limited (Level 36, Tower 1, International Towers Sydney 100 Barangaroo Ave, Sydney NSW 2000 Australia). This arrangement means:

  1. Secure Processing: Your payment information (credit/debit card data, bank account numbers, etc.) is transmitted directly through secure, encrypted channels to the payment processor. I do not store full card numbers on my servers.
  2. Compliance: My payment processors are PCI-DSS (Payment Card Industry Data Security Standard) compliant or follow equivalent standards to ensure the safety of financial data.
  3. Limited Access: I may receive only limited payment details (e.g., last four digits of your card, expiration date) and transaction confirmations (success/failure).

21.2 Models’ Earnings and Payouts

If you are a content creator or Model earning revenue via the Websites:

  1. Payout Information: You must provide accurate financial details (e.g., bank account, PayPal details, or other payment methods) to receive your payouts.
  2. Taxes: You are solely responsible for reporting and paying any income or sales tax relevant to your earnings. I may require tax-related documentation, such as W-9 forms (for U.S. residents) or W-8 forms (for non-U.S. residents), and I may withhold a portion of your earnings where required by law.
  3. Withholding and Compliance: If required by law, I will comply with any financial regulations that necessitate withholding or reporting of your earnings. This may include providing your information to tax authorities upon lawful request.

22. Data Protection Officer

While I may not be legally obligated to appoint a Data Protection Officer (DPO) under the GDPR or other regulations (depending on the volume and scope of data processing), I am committed to upholding data protection standards. For inquiries about GDPR compliance, you can reach me directly at info@adamszokol.com.

If the scale or nature of my data processing activities changes significantly and a formal DPO becomes necessary, I will publicly post that information and update this Privacy Policy accordingly.

23. Exercising Your Legal Rights

23.1 Making a Request

To exercise any of your legal rights, email me at info@adamszokol.com with a clear description of your request. Include:

  • Your full name and contact information.
  • Details of the specific right you wish to exercise (e.g., “I want to access my data,” “I want my data deleted,” “I object to processing for marketing,” etc.).
  • If relevant, information about your interactions with the Websites (e.g., your username, the nature of your subscription).

23.2 Response Timeframe

I aim to respond to legitimate requests within 30 days or the timeline required by your local law (e.g., GDPR typically requires a response within one month, extendable for complex requests). If I need more time, I will inform you of the reason for the delay and how long I expect it to take (up to a further two months if permissible by law).

23.3 Verification

To protect your privacy and security, I may request that you verify your identity before providing or deleting Personal Data. This may involve verifying account details, providing ID documentation, or any other verification procedure I deem appropriate under the circumstances. If I cannot verify your identity, I reserve the right to refuse to fulfill your request.

23.4 Possible Limitations

Your rights are not absolute. There may be instances where I cannot comply with your request for legal or other valid reasons, such as:

  • Compliance with Legal Obligations: Certain laws require me to retain data (e.g., for tax filings).
  • Public Interest: Data that might be needed for official statistics or scientific/historical research.
  • Legal Claims: Where retention of certain data is necessary to establish, exercise, or defend legal claims.
  • Overly Broad Requests: If your request is manifestly unfounded, repetitive, or excessive, I may charge a fee or refuse it.

24. Your California Privacy Rights (Detailed)

In addition to the rights outlined in Section 14.1, California law also provides:

  1. Right to Access Information About Data Collected and Disclosed: You may request that I disclose to you the specific pieces of Personal Data I have collected, the categories of Personal Data, the categories of sources from which Personal Data is collected, the business or commercial purposes for collecting Personal Data, and the categories of third parties to whom Personal Data was shared or disclosed for a business purpose in the preceding 12 months.
  2. Right to Delete: You may request I delete certain Personal Data, subject to exemptions.
  3. Authorized Agent: You can designate an authorized agent to exercise your rights under CCPA on your behalf. I require proof that the agent is acting on your behalf and may require you to verify your identity with me directly.
  4. Non-Discrimination: I will not discriminate against you for exercising your rights under the CCPA. This means I will not deny you goods or services, charge you different prices, or provide a different level or quality of services just because you exercised your CCPA rights (unless that difference is reasonably related to the value provided by your data).

25. Cross-Border Communication and Marketing

25.1 Marketing Consent

When you sign up for an account or opt-in to marketing communications, you give me permission to contact you via email or other electronic means about updates, promotions, or informational content. You can revoke this consent at any time by clicking the “unsubscribe” link in such emails or by emailing info@adamszokol.com.

25.2 International Communication

If you reside in a country outside the United States, your Personal Data might be transferred to and processed on servers located in the U.S. and potentially other countries. This includes any personal information you provide when signing up for a newsletter or creating an account. By providing your Personal Data, you explicitly consent to the cross-border transfer of your data in accordance with this Privacy Policy.

26. Record-Keeping and Audit

I maintain records of data processing activities as required by various data protection laws, including the GDPR (Article 30), where applicable. These records may include:

  • Name and contact details of the Controller (me).
  • Categories of data subjects and Personal Data processed.
  • Purposes of processing.
  • Categories of recipients.
  • Transfers of Personal Data to third countries or international organizations.
  • Retention schedules.
  • Security measures.

I periodically conduct audits to ensure compliance with this Privacy Policy and with relevant privacy regulations. I monitor and update these measures and records to reflect changes in technology, law, or my business operations.

27. User Testimonials

If you provide me with testimonials or feedback, I may post them on the Websites (along with your name and possibly profile photo) for promotional purposes. You consent to the posting of such testimonials. If you wish to update or remove your testimonial, you can contact me at info@adamszokol.com and I will endeavor to remove it. However, please note that caching or references to the testimonial may still appear in external media or search engines.

28. Breach Notification

In the event of a data breach that affects your Personal Data, and where required by law, I will notify you and relevant regulatory authorities within the required time frames. The notification will include details about the nature of the breach, the likely consequences, and any measures taken or proposed to address the breach. If direct notification is not possible (e.g., if your contact details are not available), I may post a public notice on the Websites.

29. Employee and Contractor Confidentiality

All employees, contractors, or other individuals who might have access to your Personal Data for legitimate business purposes are required to keep such information confidential and to use it only for the purposes for which it was collected. They are trained on the importance of maintaining data privacy and are bound by contractual or legal confidentiality obligations.

30. Liability and Indemnification

This Privacy Policy forms part of the broader legal agreement that you, the User, have with me regarding use of the Websites. By using the Websites, you agree to the Disclaimer of Warranties & Limitation of Liability and Indemnification provisions contained in the Terms of Service. This means, among other things, that you agree I shall not be held liable for certain losses or damages (to the extent permitted by law) and that you will defend and indemnify me against certain claims that might arise from your use of the Websites, including privacy or data protection violations that result from your own actions.

31. Contact Information and Complaints

31.1 Contacting Me

If you have questions about this Privacy Policy, want to exercise your rights, or need further clarification, you may contact me using the following details:

  • Name: Adam Szokol
  • Email: info@adamszokol.com
  • Phone: +1 (845) 793-0554
  • Address: 2300 Rock Springs Drive, Apt 1145, Las Vegas, NV, USA

31.2 Complaint Resolution

I endeavor to resolve any complaints regarding the use or disclosure of Personal Data in a fair and timely manner. If you have a complaint regarding this Privacy Policy or my data handling practices, please contact me first. I will do my best to investigate and resolve your complaint promptly.

If you are located in certain jurisdictions (e.g., the EEA or the UK), you may also file a complaint with the local data protection authority if you believe I have not addressed your concerns adequately. However, I would appreciate the opportunity to address your concerns first, so please contact me directly.

32. Final Remarks

Thank you for taking the time to read this Privacy Policy. Transparency is a core value, and I want you to feel confident about how your Personal Data is collected, used, and protected when you use the Websites.

If you have read this entire document, you now have a comprehensive understanding of my privacy practices, your rights, and my obligations. Your trust is paramount, and I will continue to review and refine my privacy and data protection measures to align with evolving laws, regulations, and best practices.

By continuing to use the Websites, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree, please refrain from using the Websites and, if applicable, delete your account as outlined above.

Effective Date: March 8th, 2025
Last Modified: March 8th, 2025

Adam Szokol
Welcome to my main website! Yes, I'm on that picture. It's a digitally drawn photo. I'm an entrepreneur, creative strategist and the owner of a few websites. Let's get in touch, contact me and you'll never forget the experience. I'm always here to help :)

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