Privacy Policy

Last updated: 9 July 2026

This Privacy Policy (the “Policy”) applies to the Ashoo platform (the “Platform”), available at ashoo.cz, and sets out how the personal data of Platform users is processed and protected. In this Policy, the terms “we”, “us” and “our” refer to the operator of the Platform.

This Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have in relation to it. It applies together with our Cookie Policy and User Agreement.

If you do not want us to process your personal data as described in this Policy, you should not use the Platform or should stop using the relevant features.

1. Definitions

For the purposes of this Policy, the following terms have the meanings set out below:

• User means any natural or legal person who accesses or uses the Platform, including Guests and registered account holders.
• Guest means a User who browses the Platform without registering an account.
• Listing means any advertisement, offer, or notice published on the Platform by a User.
• Credits means prepaid units of internal balance purchased by a User and stored in the Wallet to pay for publication, promotion, and other features related to Listings.
• Wallet means the section of a User’s account where the Credit balance is displayed and recorded.
• KYC / Identity Verification means the process by which we verify a User’s identity and age before allowing them to publish Listings, carried out by our third-party provider Yoti.
• GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data.
• Personal Data means any information relating to an identified or identifiable natural person.
• Services means the technical functions of the Platform that enable Users to create, publish, promote, and manage Listings.

2. About this Policy

This Policy describes how the Company collects, uses, stores, and protects personal data in connection with the operation of the Platform.

If you browse the Platform as a Guest, we do not collect account registration data about you. However, we may collect technical data, cookie data, and security logs as described in Sections 3.4 and 3.6 below.

This Policy has been developed in accordance with the GDPR and other applicable laws, including Czech Act No. 110/2019 Coll. on Personal Data Processing.

3. What Information Do We Collect?

We collect the following categories of personal data:

3.1. Registration Data

When you create an account, we collect:

• Username;
• Email address;
• Password (stored in hashed form);
• Confirmation that you are 18 years of age or older;
• The following data connected with your Listing or profile:
• Social network account (optional);
• Country of residence, city, district, metro station or location coordinates (optional);
• physical data that the User voluntarily provides in the Listing, including age, height, and other profile data;
• photographs and videos.

We use this data to create and authenticate your account and to provide you with the Services in accordance with our User Agreement.

3.2. Identity Verification Data (KYC)

Before publishing a Listing, Users are required to complete an identity verification process. This process is carried out by our third-party provider, Yoti (www.yoti.com).

As part of the KYC process, you will be asked to submit directly to Yoti:

• A photograph of yourself holding a valid government-issued identity document (national ID card or passport).
• A short video in which you hold a sheet of paper displaying a verification code sent to you by the Company.

You do not submit this data directly to us. It is securely processed by Yoti, which then shares with us only the outcome of the verification:

• Whether the verification was passed or failed.
• The reason for failure, if applicable (e.g., invalid document, underage, insufficient quality).

Yoti processes your verification data as an independent data controller. Please refer to Yoti’s Privacy Policy at https://www.yoti.com/privacy/ for more information on how Yoti handles your data.

3.3. Account and Activity Data

When you use the Platform, we collect:

• Listing content and publication history.
• Wallet balance and credit transaction history (top-ups and redemptions).
• Customer support queries submitted to us.
• Communications between you and the Platform.

Certain information included in or associated with a Listing may be publicly visible on the Platform, including the User’s display name, Listing content, location or approximate location, age, and any other information the User chooses to include in the Listing.

3.4. Technical Data

When you access the Platform, we automatically collect certain technical identifiers, including:

• IP address and associated approximate location data.
• Device type (mobile, desktop, tablet).
• Browser name, version, and language settings.
• Operating system.

This technical data is used collectively as a device fingerprint for security purposes, including the detection and prevention of duplicate or fake accounts and fraudulent activity. Processing is carried out on the basis of our legitimate interests (Article 6(1)(f) GDPR) in maintaining the security and integrity of the Platform. We do not use this data for advertising or profiling purposes.

3.5. Sensitive Listing Content

Because the Platform may include Listings relating to services intended for adults or age-restricted services, Content submitted by Users may reveal information relating to a User’s sex life, sexual orientation, or other sensitive matters. Users should not submit sensitive personal data about themselves or any other person unless it is necessary for their Listing and they have the right to share it. We process Listing Content only for the purpose of operating, displaying, moderating, and securing the Platform.

Where you voluntarily submit Listing Content that reveals special categories of personal data about you, including information relating to your sex life or sexual orientation, you must provide explicit consent to our processing and public display of that content for the purposes of publishing, operating, displaying, moderating, and securing your Listing.

Users must not submit special categories of personal data about any other person unless they have that person’s explicit consent or another lawful basis to do so.

3.6. Cookie Data

We use cookies and similar technologies as described in our Cookie Policy. Please refer to the Cookie Policy for full details on the types of cookies used, their purposes, and how you can manage them.

4. Payment Data

We do not process payments directly and do not have access to your credit or debit card or crypto wallet details. All payment transactions are processed by our third-party payment providers, who are independent data controllers. Your payment details are submitted directly to the payment provider and never reach our servers.

When you save a payment method, it is stored by the payment provider, which issues us with a payment token for future use. We cannot recover card details from this token.

However, we may receive and store information necessary to record Credits and payments, including payment status, amount, currency, payment date, transaction ID, and payment token.

Please, review the Privacy Policy of the relevant payment provider before submitting your payment information.

5. How Do We Use Your Personal Data?

We use the personal data we collect for the following purposes:

• Account creation and authentication – to allow you to register, log in, and maintain a secure session on the Platform.
• Public display of Listings – to display Listing content and related public information, such as display name, age, location or approximate location, and other information provided by the User.
• Provision of Services – to allow you to publish Listings, manage your Wallet, and use the Platform’s features in accordance with our User Agreement.
• Identity verification – to verify that you are 18 years of age or older before allowing you to publish Listings, enforce our age-restriction requirements, prevent misuse of the Platform, comply with applicable laws where required, and and comply with our User Agreement.
• Fraud prevention and security – to detect and prevent duplicate or fake accounts, fraudulent activity, and other misuse of the Platform.
• Customer support – to respond to your queries, resolve disputes, and improve our support services.
• Platform improvement – to analyse usage patterns, fix errors, and improve the functionality and user experience of the Platform.
• Legal compliance – to comply with applicable laws, regulations, and orders from competent authorities.

We do not make decisions affecting your rights and legitimate interests solely on the basis of automated processing of your personal data.

6. Legal Basis for Processing

We process your personal data on the following legal bases under the GDPR:

• Performance of a contract: processing necessary to provide the Services and fulfil our obligations under the User Agreement.
• Legal obligation: processing required by applicable law, including tax, accounting, regulatory, and record-keeping obligations.
• Legitimate interests: processing for fraud prevention, security, and Platform integrity, where our interests are not overridden by your rights and freedoms.
• Consent: where we rely on your consent (e.g., for analytics cookies), you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
• Explicit consent: where Listing Content submitted by a User reveals special categories of personal data within the meaning of Article 9 GDPR, such as data relating to sex life or sexual orientation, we process such data on the basis of the User’s explicit consent given at the time of submitting the relevant Listing Content.

7. Do We Share Your Personal Data?

We do not sell your personal data. We may share your data in the following circumstances:

• Service providers – we share data with providers such as hosting providers, analytics providers, customer support providers, and infrastructure service providers.
• Identity verification provider – identity verification is carried out by Yoti. As described in Section 3.2, Yoti may act as an independent data controller for the verification data submitted directly to it.
• Analytics – we may share aggregated or anonymised data with analytics providers to understand Platform usage, improve functionality, and detect technical issues. Where analytics involve cookies or similar technologies, they are used in accordance with our Cookie Policy and applicable consent requirements.
• Legal obligations – we may disclose your data to competent authorities, courts, or law enforcement agencies where required by law, court order, or legal process.
• Business transfers – in the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction.

Where personal data is transferred to third parties outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Data Storage

Your personal data is stored on servers located in Poland, within the European Economic Area. We use Host4.biz as our infrastructure provider. Data is stored and processed in accordance with applicable EU data protection law.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Policy:

• Account data – retained for the duration of your account and for a period of 5 years after account closure, as required by applicable law or our legitimate interests.
• KYC verification records – retained by us for the period required by applicable law or as necessary to prevent fraud and comply with legal requirements.
• Documents, photographs, and videos submitted for KYC are retained by Yoti in accordance with Yoti’s Privacy Policy.
• Transaction data – retained for a minimum of 5 years in accordance with Czech accounting and tax law.
• Technical and security data – retained for 12 months for fraud prevention and security purposes.
• Legal claims – data may be retained for the duration of applicable limitation periods or active legal proceedings.

When data is no longer required, we delete or anonymise it in a secure manner.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include encryption of data in transit and at rest, access controls, and regular security reviews.

No security measure is entirely impenetrable. In the event of a personal data breach, we will notify the relevant supervisory authority and, where required, affected Users in accordance with the GDPR.

You are responsible for keeping your account credentials confidential. Please do not share your login details with third parties.

11. Your Rights

Under the GDPR, you have the following rights in relation to your personal data:

• Right of access – to request a copy of the personal data we hold about you.
• Right of rectification – to request correction of inaccurate or incomplete data.
• Right to erasure – to request deletion of your data in certain circumstances.
• Right to restrict processing – to request that we limit the processing of your data in certain circumstances.
• Right to data portability – to receive your data in a structured, commonly used format.
• Right to object – to object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent – where processing is based on consent, to withdraw it at any time without affecting prior processing.
• Right to lodge a complaint – to lodge a complaint with a supervisory authority. In the Czech Republic, this is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů, www.uoou.cz).

To exercise any of the above rights, please contact us at [email protected].

12. Contact

For questions relating to the processing of personal data or the exercise of your rights, please contact us at [email protected]. For general questions relating to the Platform, please contact us at [email protected].

13. Updates to This Policy

We may update this Policy at any time. Where changes are material, we will notify you by email or through a notice on the Platform. The date of the most recent update is shown at the top of this page.

Your continued use of the Platform following publication of an updated Policy means that you have been informed of the updated version, unless otherwise required by applicable law.