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Privacy Policy

Privacy Policy

This Privacy Policy explains how personal data is processed when you use modelcouples.network (“Platform”), in accordance with the General Data Protection Regulation (GDPR), the Austrian Data Protection Act (DSG), and § 165 of the Telecommunications Act 2021 (TKG 2021).

1. Controller

Krassmedia.at
Gudrunstraße 1/50, 1110 Vienna, Austria
General contact: [email protected]
Privacy contact: [email protected]

A Data Protection Officer has not been appointed, as the legal requirements under Article 37 GDPR are not met.

2. Scope

This Privacy Policy applies to all data-processing activities related to the use of the Platform, including:

  • Registration and user accounts

  • Profiles and user-generated content

  • Community and group features

  • Events and workshops

  • Paid featured listings and marketing services

  • Newsletters and communication

  • Hosting, infrastructure, and IT security

  • Cookies and embedded third-party content

3. Categories of Data

We process the following types of personal data:

  • Registration (required): name, username, email address, date of birth (18+ age check), password hash

  • Profile (optional): location (city/country), bio, profile image, uploads, visibility settings

  • Communication: private messages, support requests, public posts and comments

  • Technical/log data: IP address, browser/device type, cookies, session data, server logs

  • Usage data: page visits, interactions, activity data

  • Newsletter data: email address, double opt-in timestamp and IP address; tracking data only with separate consent

  • Payment data: transaction confirmation from PayPal (transaction ID, amount, payer name/email – no card details)

  • Marketing-service data: profile visibility preferences, promotion status, social-media handles (if submitted for promotion), and related public content.

Important: Please do not submit special categories of personal data under Article 9 GDPR (e.g. health data, sexual orientation).

4. Age Restriction (18+)

The Platform is intended for adult users (18+). If we become aware of an under-age account, it will be deleted after verification.

5. Registration and Public Profile Visibility

The Platform is based on publicly visible profiles for professional and creative networking. The following profile data may be publicly visible, depending on the user’s individual settings:

Username 
Profile type or category
Location city and country
Language
Bio or profile description
Profile images and other uploaded content
Instagram username or other voluntarily provided social media handles

The publication of this data is based on Article 6(1)(a) GDPR consent. By creating and activating a profile, the user consents to the public display of the selected profile data.

Consent may be withdrawn at any time with future effect, in particular by adjusting profile settings or deleting the account in accordance with Article 7(3) GDPR.

6. Purposes, Legal Bases and Retention

We process personal data for:

  • Account creation and management – Art. 6(1)(b) GDPR

  • Platform features and abuse prevention – Art. 6(1)(b),(f) GDPR

  • Communication and support – Art. 6(1)(b),(f) GDPR

  • Security and logs – Art. 6(1)(f) GDPR

  • Events and workshops – Art. 6(1)(b),(f) GDPR

  • Newsletter – Art. 6(1)(a),(f) GDPR

  • Newsletter tracking – Art. 6(1)(a) GDPR

  • Cookies / embedded content – § 165 TKG 2021, Art. 6(1)(a) GDPR

  • Legal obligations and enforcement – Art. 6(1)(c),(f) GDPR

  • Paid marketing and featured services (e.g. Featured Profiles, Events, Venues, or Social-Media Promotion) – Art. 6(1)(b) GDPR (contract performance) and Art. 6(1)(f) GDPR (verification and record-keeping).
    Transaction data is retained for seven (7) years under § 132 BAO (Austrian Fiscal Code).

7. CAPTCHA at Login (Spam and Abuse Protection)

We use Google reCAPTCHA to protect the Platform against automated access and spam.
Legal basis: Art. 6(1)(f) GDPR (IT security).
Provider: Google Ireland Ltd. Privacy Policy: https://policies.google.com/privacy

8. Embedded Content and Pinterest

Third-party content is only loaded after consent.
Legal basis: Art. 6(1)(a) GDPR and § 165 TKG 2021.
Transfers outside the EU comply with the EU-U.S. Data Privacy Framework or Standard Contractual Clauses.

9. Publication of Model Couple Profiles on Pinterest

Selected profiles may be featured on Pinterest or social media channels with voluntary consent (Art. 6(1)(a) GDPR).
Withdrawal possible at any time via [email protected].

10. Hosting and Data Storage

The Platform is operated using hosting and server infrastructure located within the European Union.

Web hosting services are provided by world4you Internet Services GmbH, Austria.
Server infrastructure VPS is provided by Contabo GmbH, Aschauer Str. 32a, 81541 Munich, Germany.

Both providers process personal data exclusively within the European Union.
Data processing is limited to what is necessary for the technical operation, security and availability of the Platform.
Data processing agreements pursuant to Article 28 GDPR are in place with the respective providers.

To secure administrative access to the server infrastructure, a Virtual Private Network VPN is used.
The VPN is used exclusively for internal administrative access and server management.
In this context, connection data such as IP address and connection time may be processed insofar as required for technical security.
The legal basis is Article 6(1)(f) GDPR legitimate interest in ensuring IT security and preventing unauthorized access.
No processing for other purposes takes place

11. Moderation and Reporting

No proactive monitoring. Reported content is reviewed promptly. Violations may lead to deletion or account suspension.
Legal basis: Art. 6(1)(f) GDPR and Art. 6(1)(c) GDPR.

11a. Profile Reviews (Member Reviews)

What data we process.
If you submit a profile review, we process the information you provide in the review (e.g., a star rating from 0–5, any enabled criteria ratings, and—if enabled—your review text), the date/time of submission, and the reference to the profile being reviewed. The review is linked to your user account (e.g., via user ID and/or display name). To protect the Platform and users against misuse (such as spam, duplicate submissions, or fake reviews), we may also process technical log data (e.g., IP address and device/browser information) as well as moderation notes connected to reports and review decisions, to the extent necessary.

Why we process it.
We use this data to operate the review feature, store and display reviews on profiles (including aggregated ratings/averages), and to maintain the integrity of the system. This includes quality assurance, abuse prevention, handling reports, enforcing our Terms, and meeting legal obligations where applicable.

Legal basis.
The processing is generally based on Art. 6(1)(f) GDPR (our legitimate interests in providing a functional and reliable review feature, ensuring transparency, and preventing abuse). Where the review feature forms part of the user contract and Platform functionality, Art. 6(1)(b) GDPR (performance of a contract) may also apply.

Visibility / recipients.
Reviews and aggregated ratings are publicly visible on the relevant profile. Internally, access is limited to staff who need it for support, moderation, and security purposes. Where service providers (e.g., hosting/IT) are involved, they act as processors under GDPR.

Retention.
Reviews are generally kept until (a) the reviewer deletes them, (b) we remove or disable them due to a breach of our Terms or legal requirements, or (c) the account is deleted (subject to the technical deletion and backup cycles described in Section 14). Moderation records are typically stored until the relevant case is closed; technical logs are retained in line with the periods stated in Section 14.

12. Newsletter and Withdrawal of Consent

Newsletters are sent after double opt-in. Email + IP + timestamp processed for proof.
Legal basis: Art. 6(1)(a),(f) GDPR.
Tracking only with separate consent.
Unsubscribe any time via link or [email protected].

13. Free and Paid Services

The basic use of the Platform remains free of charge.
In addition, users may book optional paid marketing and visibility services, including:

  • Featured Profiles (models, vendors, or venues)

  • Featured Events or Organizers

  • Social-media promotion (e.g. Instagram, Pinterest)

  • Venue or Vendor highlight placements

Payments for these services are made outside the Platform via individual PayPal payment links.
The Platform does not process or store any credit-card or account details.
We only receive transaction confirmation data from PayPal (payment ID, amount, payer name/email) to verify and deliver the service.

Data processing is based on Art. 6(1)(b) GDPR (contract performance).

13a. Payment Processing (PayPal)

Payments for marketing and promotion services are handled exclusively by:
PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg.

We do not collect or store any card data. PayPal provides transaction confirmation (payment ID, amount, payer name/email).

Purpose: Contract performance for the requested paid service (Art. 6(1)(b) GDPR).
Legal basis: Art. 6(1)(b) (business contract), Art. 6(1)(f) (verification), Art. 6(1)(c) (retention obligation).
Retention: 7 years under § 132 BAO (Austria).
Recipient: PayPal (Europe) S.à r.l. et Cie, S.C.A. Privacy Policy: https://www.paypal.com/webapps/mpp/ua/privacy-full
If data is transferred outside the EU/EEA, PayPal uses the EU-U.S. Data Privacy Framework and Standard Contractual Clauses.

14. Retention Periods

Account data – deleted within 30 days after closure
Server logs – kept 60 days
User content – stored until deleted by user
Moderation records – until case closed
Newsletter consent – until unsubscribe + 3 years (for proof)
Payment confirmations – 7 years (§ 132 BAO)
Backups – rolling automatic cycles

15. Security (Article 32 GDPR)

We implement technical and organizational security measures such as TLS/SSL encryption, secure password hashing, access controls, two-factor authentication and regular updates. Absolute security cannot be guaranteed.

16. Your Rights

You have rights under the GDPR: access (Art 15), rectification (Art 16), erasure (Art 17), restriction (Art 18), portability (Art 20), objection (Art 21), withdraw consent (Art 7(3)).
Under Austrian law: right to confidentiality (§ 1 DSG).
Contact for requests: [email protected]. Proof of identity may be required.

17. Supervisory Authority

Austrian Data Protection Authority (DSB)
Barichgasse 40–42, 1030 Vienna, Austria
Website: https://www.dsb.gv.at

18. No Automated Decision-Making

We do not conduct automated decision-making or profiling within the meaning of Article 22 GDPR.

19. Changes to this Policy

We may update this Privacy Policy to reflect legal, technical or operational changes. The latest published version applies.

20. Contact

For questions about this Privacy Policy or data processing related to payments, marketing or featured services, please contact:
[email protected]

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