Privacy Policy

Last Updated: February 13, 2026
Effective Date: February 13, 2026

INTRODUCTION

Welcome to Cinaed Dane Photography ("we," "us," "our"). We are committed to protecting your personal data and your privacy.

This Privacy Policy explains:

• What personal data we collect and why
• How we use, store, and protect your information
• Your rights under GDPR and Spanish data protection law
• How to contact us with questions or requests

Important: This website contains explicit nude and erotic art photography intended for adults 18+. By using this site, you confirm you meet age requirements and consent to our data practices as described below.

1. WHO WE ARE

Data Controller:
Cinaed Dane Photography

Contact Information:
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Website: https://cinaeddane.com

Jurisdiction:
We operate under Spanish and European Union data protection laws, including:

• General Data Protection Regulation (GDPR)
• Ley Orgánica de Protección de Datos (LOPDGDD) - Spanish Data Protection Law

Supervisory Authority:
Agencia Española de Protección de Datos (AEPD)
Website: https://www.aepd.es

2. WHAT DATA WE COLLECT

2.1 Personal Information You Provide

When you register, subscribe, or contact us, we collect:

Account Information:

• Name (or username)
• Email address
• Country of residence
• PayPal email address (for payment processing)
• Password (encrypted)

Age Verification Data:

• Confirmation that you are 18+ (via age gate acceptance)
• PayPal account verification (PayPal confirms you are 18+ through their payment method validation)

Communication Data:

• Messages you send us
• Support requests
• Feedback or survey responses

Payment Information:

• Transaction details (amount, date, subscription status)
• Note: We do NOT store credit card details - PayPal processes all payments

2.2 Data Collected Automatically

Technical Data:

• IP address
• Browser type and version
• Device type (desktop, mobile, tablet)
• Operating system
• Referring website
• Pages visited on our site
• Time spent on pages
• Links clicked

Usage Data:

• Content accessed (which series, models viewed)
• Download activity
• Login frequency
• Subscription activity

Cookies and Tracking:

• Session cookies (keep you logged in)
• Preference cookies (remember your settings)
• Analytics cookies (understand site usage)
• See Section 8 for detailed cookie information

Analytics Data (PostHog):

• Anonymized page views
• Session duration
• Navigation paths
• Device type (mobile/desktop)
• Geographic region (country-level only)
• **Important:** PostHog is cookie-free and does NOT track personal data

2.3 Special Category Data

Adult Content Access:

Because our website contains explicit adult content, we process data related to:

• Your access to adult materials (implicit in your subscription)
• Age verification through PayPal

Legal Basis: Your explicit consent (by purchasing membership and using the site) + contractual necessity (to provide adult content services)

3. HOW WE COLLECT YOUR DATA

You provide data directly when you:

• Register for an account
• Subscribe to membership via PayPal
• Opt in to our newsletter
• Contact us via email or forms
• Provide feedback or complete surveys

We collect data automatically when you:

• Visit our website (via cookies and server logs)
• Browse content (via analytics)
• Use your browser (technical data collected)

We receive data from third parties:

• PayPal: Payment confirmation, transaction details, age verification (18+ account requirement)
• Analytics services: Aggregated usage statistics

4. LEGAL BASIS FOR PROCESSING

Under GDPR, we process your personal data based on the following legal grounds:

Consent (Article 6(1)(a) GDPR):

• Marketing emails (you opt in)
• Cookies (you accept via cookie banner)
• Age verification (you confirm 18+ at age gate)
• Access to adult content (you knowingly subscribe)

Contractual Necessity (Article 6(1)(b) GDPR):

• Processing payments
• Providing membership access
• Delivering content you purchased
• Managing your account

Legal Obligation (Article 6(1)(c) GDPR):

• Tax compliance (VAT records)
• Legal age verification requirements
• Responding to law enforcement requests

Legitimate Interests (Article 6(1)(f) GDPR):

• Fraud prevention
• Website security
• Analytics to improve services
• Protecting intellectual property

5. HOW WE USE YOUR DATA

We use your personal data to:

5.1 Provide Services

• Process your subscription and payments
• Grant access to member-only content
• Manage your account
• Authenticate your identity (login)
• Verify you meet age requirements (18+)

5.2 Communicate With You

• Send subscription confirmations and receipts
• Notify you of subscription renewals
• Send security alerts about your account
• Respond to your support requests
• Send newsletters (only if you opted in)

5.3 Improve Our Services

• Analyze site usage to improve user experience
• Understand which content is popular
• Optimize website performance
• Test new features

5.4 Protect Our Business

• Prevent fraud and abuse
• Enforce our Terms & Conditions
• Protect copyright (detect content theft)
• Comply with legal obligations
• Defend against legal claims

5.5 Marketing (With Your Consent)

• Send newsletters about new series
• Notify you of special offers
• Share updates about Cinaed Dane
• You can opt out anytime via unsubscribe link

6. HOW WE STORE AND PROTECT YOUR DATA

6.1 Data Storage Location

Primary Storage:

• Data center: Paris, France (EU)
• Backup storage: Within European Union
• All data remains within EU jurisdiction

Payment Processing:

• PayPal (USA) - See Section 6.4 for international transfers

6.2 Security Measures

We implement industry-standard security measures:

• Encryption: SSL/TLS for data transmission
• Password protection: Encrypted password storage
• Access controls: Limited employee access to personal data
• Regular security audits: Vulnerability assessments
• Secure servers: Protected against unauthorized access
• Backup systems: Regular encrypted backups

However: No system is 100% secure. You acknowledge inherent risks in transmitting data over the internet.

6.3 Data Retention Periods

We retain your data as follows:

After retention periods expire:

• Personal data is permanently deleted
• Backups are purged on schedule
• Anonymized data may be retained for statistics

6.4 International Data Transfers

PayPal (USA):

Payment processing involves transferring data to PayPal (headquartered in USA):

• Safeguards: PayPal uses Standard Contractual Clauses (SCCs) approved by EU
• Why necessary: PayPal processes payments and verifies your 18+ age requirement
• Your consent: By using PayPal, you consent to this transfer
• PayPal's privacy policy: https://www.paypal.com/privacy

Other Services:

We may use analytics or hosting services that process data outside EU:

• All use EU-approved transfer mechanisms (SCCs, adequacy decisions)
• We conduct due diligence on data protection practices
• You consent to these transfers by using our website

7. SHARING YOUR DATA

7.1 We DO NOT Sell Your Data

We will never sell, rent, or trade your personal information to third parties.

7.2 We Share Data With:

PayPal (Payment Processor):

• Purpose: Process subscriptions, verify age (18+)
• Data shared: Name, email, payment details
• Legal basis: Contractual necessity

Analytics Providers (if used):

• Purpose: Understand website usage
• Data shared: Anonymized usage statistics, IP addresses
• Examples: Google Analytics (if implemented)
• Legal basis: Legitimate interests

Hosting Provider:

• Purpose: Store website and data
• Data shared: All data necessary to operate site
• Location: EU-based servers
• Legal basis: Contractual necessity

Legal Authorities:

• Purpose: Comply with legal obligations
• Data shared: Only what legally required
• Examples: Tax authorities, law enforcement (with valid warrant)
• Legal basis: Legal obligation

7.3 We Do NOT Share With:

• Advertisers or marketing companies
• Data brokers
• Social media platforms (without your action)
• Other members or public

8. COOKIES AND TRACKING

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us provide better service and understand site usage.

For more information: https://www.allaboutcookies.org

8.2 Types of Cookies We Use

Essential Cookies (Always Active):

• Purpose: Keep you logged in, remember age verification, maintain site functionality
• Duration: Session (deleted when you close browser) or 24 hours
• Legal basis: Contractual necessity (can't use site without these)

Examples:

• age_verified - Remembers you passed age gate
• session_id - Keeps you logged in
• csrf_token - Security protection

Functionality Cookies (Optional):

• Purpose: Remember your preferences (language, settings)
• Duration: 30 days to 12 months
• Legal basis: Your consent

Analytics (Cookie-Free):

• Purpose: Understand how visitors use the site to improve user experience
• Technology: PostHog (cookie-free analytics)
• Data collected: Anonymized usage patterns, pages visited, time on site
• No cookies: PostHog uses cookie-free tracking - no consent required
• Legal basis: Legitimate interests (improving website performance)
• Third party: PostHog (EU/US servers)
• Privacy: No personal data tracked, fully anonymized
• More info: https://posthog.com/privacy

Advertising Cookies (If Used):

• Purpose: Track visits across websites for advertising
• We may use: Retargeting pixels (if implemented)
• Duration: Varies by provider
• Legal basis: Your consent

8.3 Managing Cookies

You can control cookies through:

Browser Settings:

• Chrome: Settings > Privacy > Cookies
• Firefox: Settings > Privacy > Cookies
• Safari: Preferences > Privacy
• Edge: Settings > Privacy > Cookies

Our Cookie Banner:

• Accept all cookies
• Reject non-essential cookies
• Customize your preferences

Consequences of Disabling Cookies:

• Essential cookies: Site will not function properly (can't log in)
• Optional cookies: Site works, but experience may be limited

Note: Disabling cookies does not delete existing cookies - clear your browser cache to remove them.

8.4 Do Not Track (DNT)

We currently do not respond to browser "Do Not Track" signals as there is no industry standard for compliance.

9. YOUR GDPR RIGHTS

Under the General Data Protection Regulation (GDPR) and Spanish law (LOPDGDD), you have the following rights:

9.1 Right to Access (Article 15)

What it means: Request copies of your personal data

How to exercise:

• Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
• Subject: "Data Access Request"
• Include: Proof of identity (to prevent fraud)

We will provide:

• What data we hold about you
• How we use it
• Who we share it with
• How long we keep it

Timeframe: Within 30 days (free of charge)

9.2 Right to Rectification (Article 16)

What it means: Correct inaccurate or incomplete data

How to exercise:

• Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
• Specify: Which data is incorrect and correct version
• Or: Update directly in your account settings

Timeframe: Within 30 days

9.3 Right to Erasure / "Right to be Forgotten" (Article 17)

What it means: Request deletion of your personal data

How to exercise:

• Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
• Subject: "Account Deletion Request"

We will delete your data if:

• No longer necessary for original purpose
• You withdraw consent (and no other legal basis exists)
• You object and no overriding legitimate grounds exist
• Data processed unlawfully

We may refuse if:

• Legal obligation requires retention (e.g., tax records)
• Legitimate interests outweigh your right (e.g., ongoing legal claim)

Timeframe: Within 30 days

9.4 Right to Restriction of Processing (Article 18)

What it means: Limit how we use your data while we verify its accuracy or your objection

When applicable:

• You contest data accuracy (we restrict while verifying)
• Processing is unlawful but you don't want deletion
• We no longer need data but you need it for legal claims

How to exercise: Email This email address is being protected from spambots. You need JavaScript enabled to view it. with your request and reason

9.5 Right to Data Portability (Article 20)

What it means: Receive your data in machine-readable format or have it transferred to another service

What we provide:

• Your account information (JSON or CSV format)
• Usage history
• Does NOT include copyrighted content (our photos)

How to exercise: Email This email address is being protected from spambots. You need JavaScript enabled to view it.

Timeframe: Within 30 days

9.6 Right to Object (Article 21)

What it means: Object to processing based on legitimate interests or for marketing purposes

Marketing:

• You can ALWAYS object to marketing emails
• Click "unsubscribe" in any email
• Or email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Other processing:

• You can object if processing is based on legitimate interests
• We will stop unless we have compelling legitimate grounds

9.7 Right Not to Be Subject to Automated Decision-Making (Article 22)

Our position:

• We DO NOT use automated decision-making or profiling
• All account decisions are made by humans
• No automated systems impact your membership

9.8 Right to Withdraw Consent

What it means: Withdraw consent for processing that requires consent

How to exercise:

• Marketing emails: Click unsubscribe
• Cookies: Adjust browser settings or cookie preferences
• Account: Cancel subscription and delete account

Effect: We stop processing based on consent (but may continue if another legal basis exists)

9.9 Right to Lodge a Complaint

If unsatisfied with our response:

Spanish Data Protection Authority (AEPD):

• Website: https://www.aepd.es
• Address: Calle de Jorge Juan, 6, 28001 Madrid, Spain
• Phone: +34 901 100 099
• Online form: Available on AEPD website

European Data Protection Board:

• Website: https://edpb.europa.eu
• Find your country's authority: https://edpb.europa.eu/about-edpb/board/members_en

10. NEWSLETTER AND MARKETING

10.1 Opt-In Consent

We only send marketing emails if you explicitly opt in:

• Checkbox during registration (unchecked by default)
• Separate newsletter signup form
• Clear description of what you'll receive

You will receive:

• Announcements of new series and content
• Promotional offers and discounts
• Updates about Cinaed Dane Photography
• Frequency: Sparingly (typically 1-2 emails per month)

10.2 Transactional Emails (Non-Marketing)

You will automatically receive (cannot opt out):

• Purchase confirmations and receipts
• Subscription renewal notices
• Password reset emails
• Account security alerts
• Legal/policy updates

Legal basis: Contractual necessity and legal obligation

10.3 Unsubscribing

To stop marketing emails:

1. Click "unsubscribe" link at bottom of any email
2. Email This email address is being protected from spambots. You need JavaScript enabled to view it. with "Unsubscribe" in subject
3. Manage preferences in account settings (if available)

Effect:

• Immediate removal from marketing list
• You will still receive transactional emails
• Unsubscribe applies to future emails only (emails already sent cannot be recalled)

11. CHILDREN'S PRIVACY

This Website is NOT for Children:

• We do NOT knowingly collect data from anyone under 18
• Our content is exclusively for adults
• Age verification is required (age gate + PayPal 18+ requirement)

If we discover data from a minor:

• We will immediately delete it
• We will terminate the account
• We will notify parents/guardians if identifiable

Parents/Guardians:

If you believe your child has accessed this site or provided personal data:

• Contact us immediately: This email address is being protected from spambots. You need JavaScript enabled to view it.
• We will investigate and take appropriate action
• Use parental control software to prevent future access

12. CHANGES TO THIS PRIVACY POLICY

12.1 Right to Modify

We may update this Privacy Policy to reflect:

• Changes in our data practices
• New legal requirements (GDPR updates, Spanish law changes)
• New features or services
• User feedback

12.2 How We Notify You

For minor changes:

• Updated "Last Updated" date at top of this page
• Posted on website

For material changes:

• Email notification to active subscribers
• Prominent notice on website
• 30-day notice period before changes take effect

12.3 Your Responsibility

• Review this policy periodically
• Check "Last Updated" date
• Contact us with questions: This email address is being protected from spambots. You need JavaScript enabled to view it.

Continued use after changes = acceptance of updated policy

13. THIRD-PARTY WEBSITES

Our website contains links to:

• Social media platforms (Bluesky, Instagram, Twitter, VK, Pinterest, Behance)
• pCloud storage (affiliate link)
• Payment processor (PayPal)
• Other external websites

Important:

• We are NOT responsible for third-party privacy practices
• Each site has its own privacy policy
• Review their policies before providing data
• Our Privacy Policy applies ONLY to cinaeddane.com

Recommended actions:

• Read privacy policies of sites you visit
• Adjust privacy settings on social media
• Understand how PayPal handles your data

14. DATA SECURITY

14.1 How We Protect Your Data

Technical measures:

• SSL/TLS encryption for all data transmission
• Encrypted password storage (bcrypt or similar)
• Firewall protection on servers
• Regular security updates and patches
• Secure hosting infrastructure (EU-based)

Organizational measures:

• Limited employee access (need-to-know basis)
• Confidentiality agreements with staff
• Regular security training
• Incident response procedures
• Data breach notification protocols

14.2 Your Responsibilities

To protect your account:

• Use strong, unique passwords
• Don't share your login credentials
• Log out on shared devices
• Enable two-factor authentication (if available)
• Report suspicious activity immediately

14.3 Data Breach Notification

If a breach occurs:

We will notify you within 72 hours if:

• Personal data is compromised
• Risk to your rights and freedoms exists
• Notification is legally required

We will provide:

• Description of the breach
• Data affected
• Potential consequences
• Measures taken to address breach
• Steps you should take

We will notify:

• Affected users (via email)
• Spanish Data Protection Authority (AEPD)
• Other authorities as required by law

15. LEGAL COMPLIANCE

We comply with:

• GDPR (General Data Protection Regulation - EU Regulation 2016/679)
• LOPDGDD (Ley Orgánica 3/2018 de Protección de Datos - Spanish Law)
• ePrivacy Directive (Cookie Law - Directive 2002/58/EC)
• Spanish laws on adult content and age verification
• EU laws on consumer protection and e-commerce

16. CONTACT US

For all privacy-related questions, requests, or concerns:

Data Controller:
Kenneth Svendlund (Cinaed Dane Photography)

Email:This email address is being protected from spambots. You need JavaScript enabled to view it.
Website: https://cinaeddane.com/contact

Response Time:

• General inquiries: Within 5 business days
• GDPR requests: Within 30 days (as required by law)
• Urgent security matters: Within 24 hours

Include in your message:

• Your name and email associated with account
• Specific request or question
• Proof of identity (for data requests)

17. SUPERVISORY AUTHORITY CONTACT

Spanish Data Protection Authority (AEPD):

Agencia Española de Protección de Datos
Address: Calle de Jorge Juan, 6, 28001 Madrid, Spain
Phone: +34 901 100 099 / +34 912 663 517
Website: https://www.aepd.es
Online complaint form: https://www.aepd.es/es/ciudadanos/reclamaciones

When to contact AEPD:

• If unsatisfied with our response to your request
• If you believe we violated GDPR or Spanish data protection law
• To file a formal complaint

European Data Protection Board (for non-Spanish EU residents):
Website: https://edpb.europa.eu
Find your country's authority: https://edpb.europa.eu/about-edpb/board/members_en

18. SUMMARY OF KEY POINTS

Quick reference:

✅ What we collect: Email, name, payment info via PayPal, usage data, cookies
✅ Why we collect it: Provide membership, verify age (18+), process payments, improve site
✅ How we protect it: Encryption, secure EU servers, limited access
✅ How long we keep it: While account active + 5 years; payments 10 years (tax law)
✅ Who we share with: PayPal (payments), analytics (anonymized), legal authorities (if required)
✅ Your rights: Access, rectify, erase, restrict, object, port data, withdraw consent
✅ How to exercise rights: Email This email address is being protected from spambots. You need JavaScript enabled to view it.
✅ How to complain: Contact Spanish AEPD (https://www.aepd.es)
✅ Marketing: Opt-in only; unsubscribe anytime
✅ Cookies: Essential (required), optional (you can disable)
✅ Age requirement: 18+ only; verified via age gate + PayPal account

© 2014-2026 Cinaed Dane Photography. All Rights Reserved.

Last Updated: February 13, 2026