Privacy Policy

EliteTreat ApS is the data controller for the processing of the personal data processed in connection with the operation of EliteDulce, unless otherwise expressly stated.

As data controller, we are responsible for ensuring that your personal data is processed in accordance with the General Data Protection Regulation, the Data Protection Act and other relevant legislation.

If you have questions about our processing of personal data, you can contact us by email: info@elitedulce.com.

When you visit, create a profile on or use EliteDulce, we process information about you. The information is used, among other things, to provide the platform, create and manage profiles, enable communication between users, handle payments, send necessary emails, prevent misuse, improve the user experience, comply with legislation and ensure the operation of the platform.

We process personal data only where there is a valid legal basis for processing, and we do not process more data than is necessary for the purposes described in this privacy policy.

If you do not wish us to process the information necessary to provide EliteDulce, you will not be able to create or use a profile on the platform.

We may process the following categories of personal data about you:

3.1 Account and profile information

When you create a profile, we may process information such as:

• email address,
• username,
• age or date of birth,
• gender,
• role on the platform,
• profile text,
• preferences,
• images,
• profile status,
• verification status,
• payment status,
• account settings,
• information you yourself choose to provide on your profile.

You yourself are responsible for ensuring that the information you provide is accurate, lawful and does not infringe the rights of others.

3.2 Information from your use of the platform

When you use EliteDulce, we may process information about your activity on the platform, including:

• login history,
• IP address,
• device information,
• browser type,
• operating system,
• technical identifiers,
• time of visit,
• pages and functions you use,
• interactions with profiles,
• message activity,
• profile views,
• notification history,
• security logging,
• error and operational logs.

This information is used, among other things, for operation, security, troubleshooting, improvement of the platform, prevention of misuse and enforcement of our terms.

3.3 Messages and communication

If you use EliteDulce's messaging features, we may process message content, metadata and technical information necessary to provide the messaging feature.

As a general rule, we do not review private messages manually. However, we may review messages and other communication if it is necessary to enforce our terms, process reports, investigate suspected misuse, prevent illegal activity, protect users or comply with legal obligations.

3.4 Images and verification material

If you upload profile pictures, gallery images or verification images, we process this information for the purpose of displaying your profile, administering the platform, carrying out moderation, preventing fake profiles and verifying users.

If we use manual verification, you may be asked to upload an image in which you hold a physical sign with “EliteDulce” and the current date. Such verification images are used for security and verification purposes and are not displayed publicly unless expressly stated.

3.5 Payment information

When you purchase subscriptions, credits, access to features or other digital services, payment information is processed through our payment provider Stripe.

We process information such as:

• payment status,
• transaction ID,
• order number,
• time of purchase,
• purchased services,
• amount,
• subscription status,
• billing information, if relevant,
• limited payment information, for example card type and the last four digits, if these are made available by the payment provider.

We do not store your full payment card details on our own systems. Payment card details are processed by Stripe and relevant acquirers/payment partners.

3.6 Support and enquiry information

When you contact us, we may process:

• name or username,
• email address,
• subject of the enquiry,
• the content of your message,
• history of previous enquiries,
• technical information relevant to support,
• documentation that you send to us yourself.

This information is used to answer your enquiry, provide support, document communication and improve our service.

3.7 Marketing and analytics information

If you consent to cookies or marketing, we may process information about:

• visits to the website,
• traffic channels,
• campaign sources,
• advertisements you have interacted with,
• conversions,
• user behaviour on the website,
• aggregated statistics,
• cookie IDs and similar online identifiers.

This information is used for analytics, statistics, marketing, conversion measurement, optimisation of advertisements and improvement of the website.

EliteDulce is a dating and social platform. Users may therefore choose to provide information on their profile or in messages that may be sensitive or private, including information about relational preferences, lifestyle, sexuality or similar.

We encourage you not to share more sensitive or private information than necessary.

If you yourself choose to publish or share information that may constitute special categories of personal data, the processing is in principle based on your explicit consent and/or because you yourself have manifestly made the information public.

You may at any time delete or change information on your profile to the extent the platform's functions allow. If you wish for further deletion or restriction, you can contact us.

We process personal data for the following purposes:

1. 1. to create and administer user accounts,
2. 2. to deliver EliteDulce's functions and services,
3. 3. to display profiles and enable interaction between users,
4. 4. to enable messages, notifications and platform communication,
5. 5. to administer subscriptions, purchases and payments,
6. 6. to send transactional emails, system emails and necessary service notifications,
7. 7. to provide customer support,
8. 8. to carry out profile and image moderation,
9. 9. to verify profiles and reduce the risk of fake profiles,
10. 10. to prevent fraud, abuse, spam, harassment, prostitution, illegal activities and violation of our terms,
11. 11. to ensure the technical operation and security of the platform,
12. 12. to analyse the use of the website and improve the user experience,
13. 13. to measure the effect of marketing and advertising,
14. 14. to send marketing if you have given consent,
15. 15. to comply with accounting, tax, consumer, payment and data protection law obligations,
16. 16. to document, establish, exercise or defend legal claims.

We do not use your personal data for other incompatible purposes without a valid legal basis for processing.

We process your personal data on the following legal bases:

6.1 Performance of a contract

We process information when it is necessary to perform the agreement with you, including in order to:

• create and administer your profile,
• provide access to the platform,
• provide free and paid functions,
• process purchases and subscriptions,
• send necessary service emails,
• handle support concerning your account.

6.2 Legitimate interests

We process information when it is necessary for our legitimate interests, unless your interests or fundamental rights override them.

Our legitimate interests include, among other things:

• operation and improvement of the platform,
• technical security,
• prevention of fraud and abuse,
• enforcement of terms,
• moderation of content,
• handling of reports,
• customer support,
• documentation of communication,
• analysis of the platform's functions,
• protection of users and the platform's integrity.

6.3 Consent

We process information on the basis of consent where required, including for:

• non-essential cookies,
• Google Analytics, where consent is required,
• Google Ads cookies and conversion tracking, where consent is required,
• newsletters and marketing,
• the processing of certain sensitive information that you voluntarily choose to provide or make public.

You may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out prior to the withdrawal.

6.4 Legal obligation

We process information where it is necessary to comply with legal obligations, including:

• accounting rules,
• tax rules,
• payment documentation,
• consumer-law requirements,
• requirements from public authorities,
• obligations under data protection legislation.

6.5 Legal claims

We may process information where it is necessary to establish, exercise or defend legal claims.

EliteDulce uses cookies and similar technologies on the website.

Cookies are small text files that are stored on your device via your browser. Cookies may, among other things, be used to make the website function, remember your choices, measure traffic, improve the user experience, analyse usage patterns and target or measure advertising.

Cookies can be divided into the following categories:

7.1 Essential cookies

Essential cookies are necessary for the website and the platform to function correctly. They may, among other things, be used for login, security, payment, session management and basic functionality.

These cookies may, as a general rule, be used without consent because they are necessary to provide the service you have requested.

7.2 Statistics cookies

Statistics cookies are used to understand how visitors use the website, so that we can improve content, features and the user experience.

We use Google Analytics for analytics and statistics if you give your consent thereto.

7.3 Marketing cookies

Marketing cookies are used to measure the effect of advertisements, optimise campaigns and display more relevant advertisements.

We use Google Ads, formerly known as Google AdWords, for advertising and conversion tracking if you give your consent thereto.

Google Ads may use cookies or similar technologies to register whether a user who has clicked on an advertisement subsequently performs an action on the website, for example creates a profile or completes a purchase.

7.4 Opting out of and deleting cookies

You may at any time change or withdraw your cookie consent via the website's cookie settings, if the function is available.

You may also delete or block cookies in your browser. If you block essential cookies, parts of the website or platform may cease to function correctly.

We use Google Analytics to collect statistics on the use of our website and platform, including information on traffic, visits, usage patterns, devices, pages and general interaction.

The purpose is to understand how the website is used, improve the user experience, optimise technical operation and develop better features.

Google Analytics is used only to the extent that it is lawful and, where necessary, on the basis of your consent.

Information collected via Google Analytics may be processed by Google in accordance with Google's own terms and data processing conditions.

We use Google Ads for marketing, campaign management and conversion tracking.

Google Ads may be used to measure whether advertisements lead to actions on the website, for example profile creation, purchase, subscription start or other relevant activity.

Processing for Google Ads, including the use of marketing cookies, takes place only to the extent that it is lawful and, where necessary, on the basis of your consent.

If we use enhanced conversion tracking or similar functions, certain information, for example an email address, may be processed in hashed form for the purpose of conversion tracking. This only takes place if the function is enabled, and the processing is carried out in accordance with applicable data protection rules.

We use Resend to send emails.

Resend may be used, among other things, for:

• account activation,
• login and security emails,
• verification emails,
• payment confirmations,
• subscription emails,
• notifications,
• support-related emails,
• operational messages,
• marketing, if you have given your consent.

When we send emails via Resend, Resend may process information such as email address, name or username, the content of the email, time of delivery, delivery status, technical information and any error messages.

Resend acts as a data processor for us to the extent that Resend processes information on our behalf.

We use Stripe as a payment gateway to process payments.

Stripe may process information necessary to complete payments, including payment card details, transaction information, amount, time, payment status and technical payment data.

As a rule, we do not receive your full payment card details. Card payments and other payment methods are handled by Stripe and the relevant payment partners.

We process only the payment information necessary to administer your purchase, your subscription, your access to paid features, accounting, documentation, support and any handling of objections or chargebacks.

We may share or entrust personal data to third parties where it is necessary to provide EliteDulce, comply with the law or protect our rights.

We use, among others, the following providers:

• Resend – sending of transactional emails, system emails and possibly marketing emails.
• Stripe – payment gateway and payment processing.
• Google Analytics – analytics and statistics.
• Google Ads – advertising, campaign measurement and conversion tracking.
• Hosting, database, security and operations providers – technical operation of the platform.
• Advisers – for example auditors, lawyers or IT security advisers, if necessary.

Data processors may only process personal data in accordance with our instructions and pursuant to data processing agreements, where this is required.

We may also disclose information to public authorities, courts, the police or other relevant parties if we are legally obligated to do so, or if it is necessary to prevent or investigate unlawful conduct.

Some of our providers or their sub-processors may process personal data outside the EU/EEA, including in the USA.

If personal data is transferred to countries outside the EU/EEA, we ensure that a valid basis for transfer exists, for example:

• the European Commission's standard contractual clauses,
• an adequacy decision,
• supplementary safeguards,
• or another lawful basis for transfer under the data protection rules.

You may contact us if you would like further information about the basis for transfer for the relevant providers.

We store personal data only for as long as it is necessary for the purposes for which the data was collected, or for as long as we are obligated to under the law.

As a rule, the following applies:

• Account and profile information is stored for as long as you have an active profile.
• Profile pictures and profile content are stored for as long as the profile is active, unless the information is deleted earlier.
• Messages are stored for as long as it is necessary to provide the messaging function, security, documentation and enforcement of the terms.
• Payment and accounting information is stored to the extent and for the period required by bookkeeping and tax rules.
• Support inquiries are stored for as long as it is necessary to handle the inquiry, document the process and address any subsequent questions.
• Security logs may be retained for a limited period in order to prevent abuse, fraud, attacks and unauthorised access.
• Cookie and analytics data are retained in accordance with our cookie settings and the retention periods of the relevant providers.

When information is no longer necessary, it is deleted or anonymised, unless continued retention is necessary in order to comply with legislation, document a claim or protect EliteDulce or our users.

We have implemented appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure and unauthorised access.

These measures may include, among other things:

• encrypted connection via HTTPS,
• access control,
• restriction of employee access,
• logging and monitoring of security incidents,
• firewall and technical security measures,
• ongoing maintenance and updates,
• internal procedures for handling personal data,
• use of professional data processors and providers.

Only persons with a legitimate need have access to personal data, and such persons are subject to confidentiality.

EliteDulce is not intended for persons under the age of 18.

Persons under the age of 18 are not permitted to create a profile, use the platform or communicate with other users via EliteDulce.

We do not knowingly collect personal data about minors. If we become aware that a person under the age of 18 has created a profile or provided personal data, we will take steps to delete the profile and the relevant information.

In the event of suspicion of unlawful conduct, exploitation, grooming, abuse or other serious content involving minors, we may retain relevant information and report the matter to the police or other relevant authorities.

EliteDulce may use technical systems to suggest profiles, sort content, improve relevance, detect suspicious activity and protect the platform against abuse.

We do not make decisions that produce legal effects concerning you or similarly significantly affect you based solely on automated processing, unless this is lawful and necessary.

If we use automated systems for moderation or security, the results may be reviewed manually where relevant.

Under the data protection rules, you have a number of rights.

Among other things, you have the right to:

1. 1. Access – you can request access to the personal data we process about you.
2. 2. Rectification – you can have inaccurate information corrected.
3. 3. Erasure – in certain cases you can have information deleted.
4. 4. Restriction – in certain cases you can have the processing restricted.
5. 5. Data portability – in certain cases you can receive your information in a structured, commonly used and machine-readable format.
6. 6. Objection – in certain cases you can object to our processing.
7. 7. Withdrawal of consent – if the processing is based on consent, you can withdraw your consent at any time.

If you wish to exercise your rights, you can contact us by email: info@elitedulce.com.

We may ask you to verify your identity, where necessary to ensure that information is not disclosed to unauthorised parties.

If you are dissatisfied with our processing of your personal data, you can contact us.

You also have the right to lodge a complaint with Datatilsynet:

Datatilsynet

Carl Jacobsens Vej 35

2500 Valby, Danmark

www.datatilsynet.dk

We may amend this privacy policy if necessary as a result of changes in legislation, case law, our processing of personal data, the platform's features, the use of providers or for other legitimate reasons.

The privacy policy in force at any given time is available on EliteDulce. In the event of significant changes, we may notify you, for example by email, notification or clear information on the platform.

We encourage you to keep yourself informed on an ongoing basis about the privacy policy in force.

Questions regarding this privacy policy or our processing of personal data may be directed to:

EliteTreat ApS

E-mail: info@elitedulce.com

Adresse: Enghavevej 182, 3. tv., 2450 København SV

CVR-nr.: 46250559