This Privacy Statement explains how CLUB LV handles personal data of its clients and the users of its services. CLUB LV considers it important that the collection and processing of personal data takes place in a careful and secure manner.
Controller: CLUB LV
The private limited company organized under the laws of the Netherlands Graanberg B.V., also trading under the name ‘Club LV’, with its registered office and principal place of business at Middenweg 144 in (1097 BV) Amsterdam (Chamber of Commerce number: 34217142), hereinafter “CLUB LV”, is responsible for collecting and processing your personal data and to determine the purpose and means of processing personal data on the basis of a special legal authority. CLUB LV is therefore the controller within the meaning of the General Data Protection Regulation (GDPR) and related implementing acts and regulations.
CLUB LV manages several websites concerning its services linked to the deployment of possible apps and social media or otherwise. These websites (and any apps and social media) are jointly referred to in this Privacy Statement as “the Websites”. More in particular, it concerns the following websites:
Generally speaking, CLUB LV can collect your data inter alia at the moment a client or user sends us an information request or booking request, made by email, website form and/or telephone, when a client or user uses or enjoys our services, when a client or user sends us otherwise an e-mail and/or a client or user disclosed his/her data publicly via or through the use of our Websites, social media or another public platform.
The information CLUB LV receives in this connection is used to be able to execute booking agreements with clients, to deliver our services, to improve them, for marketing purposes and in order to be able to offer our users sound and personalized services.
The manner in which CLUB LV collects data
CLUB LV can receive information from clients and/or users as a client or user in the following ways:
Directly from you as the client or user – for example when you send an e-mail containing a question, information or booking request and/or when you use our customer service otherwise.
Via our escorts – for example by providing us with a report of the agreed booking an/or upon our special request.
From public sources – for example by searching for additional information via online search engines.
In addition, CLUB LV collects various data via our Websites – inter alia for the performance, improvement or registration of our services – inter alia by the use and deployment of cookies. If you consent thereto, CLUB LV may also provide your personal location details separately (we can and are allowed to process anonymized location data without consent as well).
At our venues – CLUB LV can also process the data of its clients, such as registering (by camera) your visit for security purposes. Clients are always informed of such recording and processing when entering our venues and such data are not shared with third parties without consent insofar as it can be obtained within reason, unless CLUB LV is required by law or governmental authorities to do so.
Data collected by CLUB LV
CLUB LV may process data of clients and users, including personal data. The data CLUB LV may collect in respect of you as a client or user are:
contract and account details – this includes the name, address, telephone number, e-mail address, customer number, gender, age, occupation, your preferences and information about you as a person;
payment and invoicing details – when you place a booking request for the purpose of financial handling and administration;
data you have placed publicly – this includes personal responses on our Websites, including forms, or messages you have placed on social media managed by us or on our behalf;
information about your personal preferences – this includes information pertaining to your booking request;
special data – in case of you are disabled, we want to make sure that you are able to have the best possible experience by visiting our venues. We collect data concerning your needs in order to be able to meet your accessibility needs. This may include data regarding your mental and physical health, including use of special medication, which you provide to us when applying for a e.g. disabled parking space.
Please note that if a booking request has been cancelled by you or CLUB LV, for whatever reason, the aforesaid data will be processed by us in the same way as if the booking agreement had been executed, with the exception of the information provided by the escort(s).
Please note that, except for fake booking requests, in cases where an information request or booking request does not result in a booking, only the (email) correspondence and our personal notes will be saved by us.
Reasons why CLUB LV uses data
CLUB LV may use the aforesaid data for the following purposes:
For the purpose of making a successful match between you as a client or user and one or more of our escorts.
For the purpose of making a booking and to optimize future bookings, as well as the execution of our booking agreement with you as a client or user – CLUB LV uses your data when you conclude a booking agreement with us after you have placed an information request and/or booking request, for example to book a certain escort or purchase a service, so that we:
- are able to process the order and execute the booking agreement;
- are able to accept payment;
- are able to provide you with customer service and after sales.
For the purpose of safeguarding the safety and welfare of our escorts.
For the purpose of preventing fake clients or fake users from causing further damage to us and third parties, including the escorts.
For our legitimate business interests – which includes:
conducting market research and analysis, in order to be able to improve our services;
for our marketing purposes, to provide you as a client or user, if that is the case, with information regarding special offers, products, services and our special events;
in order to send e-mails or text messages from customer service, such as booking confirmations and reminders for the booking made;
in order to prevent or investigate unlawful behaviour, to protect or enforce our legal rights and the rights of our escorts or in other cases permitted by law or stipulated by local authorities. As such, we may also use your data to help prevent abuse of identity, age, infringement of intellectual property rights and/or portrait/image rights, fraud or other crimes.
For the purpose of being compliant with legal duties or obligations, including those stipulated by tax authorities and governmental authorities (e.g. licenses or permits).
Unless otherwise agreed or upon your express request we will not initiate contact with you as a client or user except for an urgent reason. This means that we only contact you by telephone or text message in the event of a missed call during our opening hours which we can return within 30 minutes and for urgent matters on the day of the execution of your booking. We will contact you by email or text message in the event of a change of your booking and to optimize future bookings. For the latter purpose it is possible that we may ask you for feedback via email within a reasonable time after the execution of your booking.
Your data as a client or user will not be used for any purpose other than the purposes referred to above. You can simply unsubscribe if you no longer wish to receive messages from CLUB LV. More information in this regard can be found under the heading “Your choices and rights as a client or user” in this Privacy Statement.
What you consented to
By accepting the content of this Privacy Statement when using our services or making an information request and/or booking request, you grant us consent to:
to contact you as a client or user in order to execute your booking agreement. This may take place by email, via text message or telephone. You can change these personal communication preferences at any time, see the paragraph entitled “Your choices and rights as a client or user” below in this Privacy Statement;
if that is the case, in order to process your health data in order to comply with your accessibility requirements – if you are disabled and/or use special medication and choose to share these data with us.
CLUB LV also shares data with third parties
within the group of CLUB LV and possible affiliate companies that provide services on our behalf such as marketing, reporting and technical support;
our external service providers (also referred to as data processors), such as computing providers, who supply the IT infrastructure on which our services and systems are built (including Bravoure, Natwerk);
in case of fake booking requests or invoices due, to legal advisors for obtaining legal advice and to debt collection agencies in case of default in order to start collecting the amounts due;
governmental authorities or other competent authorities if such is permitted or required by law.
Your choices and rights as a client or user
As a client or user you can always request, adjust and alter or remove your data if necessary or have this done. This can be done in different ways:
if that is the case, you can switch on or off whether you wish to share location settings or receive push notifications from or on behalf of CLUB LV via the settings of your device (such as your mobile phone);
You have the right to object to the processing of your personal data by CLUB LV and to adjust the data you have provided. You also have the right to request a copy of the information we hold in respect of you. You can contact us at email@example.com if you have further questions or if you wish to submit a request for inspection of your data.
Maintenance of your information
CLUB LV makes every effort to ensure that your data is secured properly. Only those persons who require access to user data pursuant to his or her position have access to such data. CLUB LV has implemented suitable technical measures that are updated regularly in order to ensure that the data are secured properly. But: please note that the internet is never 100% secure. You should therefore ensure that you as a client or user also implement the necessary security measures yourself and never provide your data (e.g. password) to another person and certainly not to unknown persons.
CLUB LV does not retain data longer than necessary in order to be able to execute your booking agreement and to provide the services you have requested. We will remove your data securely if they are no longer necessary for these purposes in accordance with our company policy, except for reasons and obligations (e.g. retention periods, licenses or permits) stipulated by law and/or the relevant authorities. In addition, CLUB LV will be able to retain your data in order to defend itself and/or our escorts against a possible legal claim and/or to avoid further damage (e.g. in case of fake booking requests).
In the event data are transferred outside Europe, there are strict rules to ensure that your data are still protected by a high level of security. If CLUB LV were to do so, we will ensure that the necessary security measures are implemented. We will use one of the mechanisms set out below if we transfer your data outside the European Economic Area. The standard contract provisions approved by the European Commission are:
EU-US Privacy shield
Binding company rules
Binding rules for company processors
CLUB LV uses functional cookies that are essential to the functionality of the Websites, such as cookies for registering whether consent for cookies was granted and to remember your preferred language.
CLUB LV uses analytical cookies, such as the cookies from Google Analytics, in order to be able to understand how the Websites are used, for the purpose of acquiring knowledge of the interests of clients and users and to improve the Websites on a continuous basis and to make them user-friendlier. It is registered for example how long clients or users remain on a certain page, how many clicks a page or escort receives, but also whether a certain link does not function properly.
CLUB LV has concluded a processing agreement with Google for the use of Google Analytics, if that is the case, through the intervention of a third party or otherwise. This agreement ensures that the Google Analytics cookies are set in most privacy-friendly way possible.
Cookies may also be used by or on behalf of CLUB LV to test the effectiveness of escort profiles and, if that is the case, advertisements, so that we can show the best and most relevant offers.
All information collected on our Websites by means of cookies is anonymized as much as possible.
As a user you can contact us at firstname.lastname@example.org if you require further information, if you have questions or if you wish to obtain a copy of the relevant information.
Changes to the Privacy Statement
CLUB LV expressly reserves the right to make changes to this Privacy Statement. Users are recommended to read this Privacy Statement on a regular basis to find out about any changes. In the event CLUB LV makes important changes to its Privacy Statement, please note that due to reasons of discretion, we will not send you updated versions of our Privacy Statement.
CLUB LV makes every effort to ensure the reliability and timeliness of published data, yet errors or omissions are not always avoidable. Therefore, except for this Privacy Statement, the content of its Websites is not legally binding. In no event will CLUB LV be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of its Websites.
Most recently amended on 25 May 2018.