Privacy Policy

1. Controller

KL Digital LLC — 30 N Gould St Ste N, Sheridan, WY 82801, USA (EIN 32-0850848).

Privacy contact / Data Protection Officer: contact@kinklabyrinth.com.

EU representative under Article 27 GDPR: KL Digital LLC is established outside the EU and currently does not meet the Article 27(2) thresholds requiring a designated EU representative. Should the obligation become applicable, an EU representative will be designated and listed here. EU/EEA data subjects can reach our DPO directly at contact@kinklabyrinth.com.

2. Data We Collect

• Account data: email, username, hashed password, declared age (18+ self-attestation at registration).
• Profile data: pseudonym, bio, role, orientation, country/region, photos you upload.
• Communications: messages you send, signals (flashes, favorites, reports).
• Billing data: processed by our payment processor — we receive only tokenized transaction data, never your full card number.
• Technical data: IP address, device, browser, pages visited, session duration.
• Consent records: age gate confirmation, cookie choices, withdrawal waivers.

3. Purposes

• Provide the service and your account.
• Process subscriptions and billing (via our payment processor).
• Moderate content, prevent fraud, abuse and illegal activity.
• Comply with legal obligations (2257, DMCA, tax, law enforcement requests).
• Improve and secure the Platform.
• With your consent: analytics, non-essential cookies.

4. Legal Bases (GDPR / UK GDPR)

• Performance of contract (Art. 6(1)(b)): account, subscription, messaging.
• Legitimate interests (Art. 6(1)(f)): security, fraud prevention, service improvement.
• Legal obligation (Art. 6(1)(c)): tax, 2257, court orders.
• Consent (Art. 6(1)(a)): non-essential cookies, marketing.
• Explicit consent for special-category data (Art. 9(2)(a)): sexual orientation / preferences you voluntarily disclose.

5. Retention

• Account data: deleted within 30 days after account closure.
• Billing records: 10 years (legal accounting obligation).
• Connection logs: 12 months.
• Messages: deleted with the account (subject to legal hold).
• 2257 records: as required by 18 U.S.C. § 2257 and 28 C.F.R. Part 75.
• Moderation/ban records: up to 5 years to prevent circumvention.

6. Your Rights

You may exercise the following rights by emailing contact@kinklabyrinth.com. We respond within 30 days.

• GDPR / UK GDPR: access, rectification, erasure, restriction, portability, objection, withdraw consent, complaint to your local supervisory authority (e.g. CNIL in France, ICO in UK, AEPD in Spain, Garante in Italy).
• CCPA / CPRA (California residents): right to know, delete, correct, opt out of sale/share (we do not sell personal data), limit use of sensitive data, non-discrimination.
• PIPEDA (Canadian residents): right to access and challenge accuracy; complaint to the Office of the Privacy Commissioner of Canada.

7. Recipients and International Transfers

We do not sell personal data. We share with processors acting on our behalf: Supabase (database and auth), Vercel (hosting), our payment processor (payments), Fal.ai (content generation), NCMEC / law enforcement (when legally required).

For transfers of EU/UK/Swiss data to the USA, we rely on the EU-US Data Privacy Framework where available, and on Standard Contractual Clauses (SCC) supplemented with transfer impact assessments. Copies of SCC available on request.

8. Security

Data is encrypted in transit (TLS 1.2+) and at rest. Access is restricted via role-based access control. We maintain an incident response plan and will notify affected users and regulators in case of a breach, in accordance with applicable law.

9. Cookies

See our Cookie Policy for the full list, durations and how to withdraw consent.

10. Children

The Platform is strictly reserved for adults (18+). We do not knowingly collect data from anyone under 18 (or 13 under COPPA in the US). If we discover such data, it is deleted immediately.

11. Changes

We will notify you of material changes at least 14 days in advance via email or in-app notice.

12. Complaints

You can always contact us first at contact@kinklabyrinth.com. You also have the right to complain to your supervisory authority:

• France: CNIL — www.cnil.fr
• United Kingdom: ICO — www.ico.org.uk
• Germany: your state BfDI — www.bfdi.bund.de
• Spain: AEPD — www.aepd.es
• Italy: Garante — www.garanteprivacy.it
• California: California AG — oag.ca.gov/privacy
• Canada: OPC — www.priv.gc.ca