SecretXperience
Legal Document

Privacy Policy

Your privacy matters. This policy explains what personal data we collect, how we use it, and the rights you have under GDPR.

Last updated: 21 May 2025  ·  GDPR compliant  ·  Data controller: 3S.lifestyle bv
01

Data Controller

The data controller responsible for the processing of personal data through SecretXperience.eu is:

3S.lifestyle bv
Tangendallaan 23, 1850 Grimbergen, Belgium
VAT: BE 0749.661.728
support@secretxperience.eu

We do not collect any personal data from persons under the age of 18. The Platform is strictly for adults only. If we become aware that data has been collected from a minor, we will delete it immediately.

02

Data We Collect

We collect personal data only to the extent necessary to operate the Platform and fulfil our legal obligations. Categories of data include:

Account & Identity DataEmail address, chosen username, and — for providers undergoing verification — government-issued ID documents and a selfie for age and identity confirmation. Verification documents are processed by a trusted third-party partner.
Profile DataInformation you voluntarily add to your profile: gender, age, biography, service descriptions, photos, location (city/region level), spoken languages, and physical characteristics if provided.
Payment DataPayment processing is handled by third-party processors. We do not store full card numbers or CVV codes. We may retain transaction identifiers, amounts, and timestamps for accounting and fraud prevention.
Usage & Technical DataIP address, browser type, device identifiers, pages visited, session duration, referral URLs, and interaction logs collected automatically as part of normal web server operation and analytics.
Communications DataMessages sent via the Platform's internal system, support tickets, and correspondence with our team.
03

Legal Bases & Purposes

We process personal data under the following GDPR legal bases:

  • Contract performance (Art. 6(1)(b)) — account management, service delivery, payment processing
  • Legal obligation (Art. 6(1)(c)) — compliance with Belgian and EU law, financial record-keeping
  • Legitimate interest (Art. 6(1)(f)) — fraud prevention, platform security, analytics, dispute resolution
  • Consent (Art. 6(1)(a)) — marketing communications and non-essential cookies (withdrawable at any time)

Purposes for which we use your data include:

  • Creating and managing your account and profile
  • Processing payments and token purchases
  • Providing customer support and responding to enquiries
  • Identity verification and age confirmation
  • Detecting and preventing fraud and abuse
  • Complying with legal obligations and responding to lawful authority requests
  • Analysing platform usage to improve our services (aggregated / anonymised where possible)
  • Sending marketing communications where you have given explicit consent
04

Data Sharing

We do not sell, rent, or trade your personal data to third parties for their own commercial purposes.

We share data only with the following categories of trusted service providers, subject to binding data processing agreements:

Hosting & InfrastructureOur database and backend infrastructure provider stores your account and profile data on secure, EU-hosted infrastructure. They act as a data processor and may not use your data for any independent purpose.
Payment ProcessorsPayment data is handled by certified third-party processors who receive only the information necessary to process your transaction securely.
Identity Verification PartnersThird-party providers engaged solely to verify user ages and identities. Data shared is limited to what is strictly necessary for verification.
AnalyticsPrivacy-conscious analytics tools configured to anonymise or pseudonymise data wherever possible.
Legal & Law EnforcementWe may disclose personal data to competent authorities when required by law or court order, or in connection with investigations of illegal activity including child exploitation material, human trafficking, or fraud.
05

International Transfers

Your personal data is primarily stored and processed within the European Economic Area (EEA). Where we engage service providers outside the EEA, we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions for countries recognised as providing equivalent data protection
  • Binding corporate rules where applicable

For details about the safeguards applied to any specific transfer, contact us at support@secretxperience.eu.

06

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law:

Active Account DataRetained for the duration of your account and for up to 12 months following account deletion, to allow for dispute resolution and fraud investigation.
Financial RecordsTransaction records are retained for 7 years from the date of the transaction to comply with Belgian and EU accounting and tax law obligations.
Verification DocumentsRetained for the minimum period required by law and then securely deleted.
Support & CommunicationsRetained for up to 3 years from the last interaction, unless subject to an ongoing legal matter.

Upon expiry of the applicable retention period, data is securely deleted or anonymised so that it cannot be reconstructed.

07

Your Rights Under GDPR

If you are located in the European Economic Area, you have the following rights under GDPR (EU) 2016/679. To exercise any of these rights, contact us at support@secretxperience.eu. We will respond within 30 days.

Right of Access (Art. 15)Obtain a copy of the personal data we hold about you and information about how it is processed.
Right to Rectification (Art. 16)Have inaccurate or incomplete personal data corrected.
Right to Erasure (Art. 17)Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where processing is unlawful. Note that we may retain certain data for legal compliance.
Right to Restriction of Processing (Art. 18)Request that we restrict the processing of your data in certain circumstances.
Right to Object (Art. 21)Object to processing based on our legitimate interests, including for direct marketing purposes.
Right to Data Portability (Art. 20)Receive a copy of your personal data in a structured, machine-readable format and transmit it to another controller.
Right to Withdraw ConsentWhere processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
08

Complaints & Contact

For any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact our data protection team:

3S.lifestyle bv — Data Protection
Tangendallaan 23, 1850 Grimbergen, Belgium
Email: support@secretxperience.eu

We aim to respond to all privacy-related correspondence within 30 calendar days. For complex requests we may extend this by a further 60 days, in which case we will notify you.

You also have the right to lodge a complaint at any time with the Belgian supervisory authority:

Gegevensbeschermingsautoriteit (GBA) / Autorité de protection des données (APD)
Rue de la Presse 35, 1000 Brussels, Belgium
www.dataprotectionauthority.be
Questions about your data? Contact support@secretxperience.eu
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