What we know about you, why we need it, who sees it and how long we keep it. Some of it is very sensitive, and this page says exactly how we treat it.
01Who is responsible
The controller of your data is [company name to be completed], [registered office to be completed]. For anything about your data write to [privacy e-mail address to be completed]. Data protection officer: [data protection officer to be completed].
02If you hold an account
We collect and keep:
- who you are: legal name, date of birth, nationality, a copy of your passport or ID card, and a selfie;
- how to reach you: e-mail address and the address you tell us;
- your working name, which is the only name your clients see;
- your registration and tax details: certificates, permits, tax and VAT numbers;
- your bank account for payouts;
- the record of the agreements you accepted, with date, time and IP address;
- your payment links, payments, invoices and payouts;
- technical data: IP address, device and browser, and a log of logins.
03If you pay through a link
We collect your e-mail address, the amount and reference of the payment, your IP address and device data, the first six and last four digits of your card and the result of the 3-D Secure check. We do not receive or keep your full card number. We do not ask what the booking was for, and we do not keep the note longer than the payment record requires.
04If someone invites you
An account holder or our team can enter your e-mail address to send you an invitation. We use the address for that one e-mail, which names the person who invited you. If you do nothing, the invitation expires after 30 days and we do not write again.
If you open an account from an invitation, the person who invited you can see your working name and whether you took at least one payment in a month, during your first three months. They never see amounts, clients or anything else.
Every invitation has a link that stops all future invitations to your address. After you use it we keep only a scrambled fingerprint of the address, so that we can refuse to write to it, and nothing else about you.
05If you only visit the website
Nothing is collected about you. The public website sets no cookies, runs no analytics and loads nothing from other companies. Our server keeps a technical log with IP addresses for up to 30 days, for security.
06Sensitive data
The documents of an account holder show that the person does sex work. The law treats this as data about a person’s sex life, a special category with the highest level of protection. We process it only with your explicit consent, which you give when you open your account, and where it is needed to establish or defend a legal claim.
You can withdraw that consent at any time. We then close your account, because we cannot run it without those documents, and we keep only what the law obliges us to keep.
07Why we use your data
- To carry out our contract with you: open the account, take payments, issue invoices, pay you.
- To meet legal duties: anti-money-laundering checks, tax and accounting rules.
- For our legitimate interest in preventing fraud and keeping the service secure.
- With your explicit consent, for the sensitive data described above.
We do not use your data for advertising and we do not sell it.
08Who receives it
- the payment institution that processes the card payments: [licensed payment institution to be completed];
- the identity-verification provider that checks IDs and selfies, when we use one;
- the bank that sends your payouts;
- the company that hosts our servers, inside the European Economic Area;
- our accountants, auditors and lawyers, bound by confidentiality;
- public authorities, when the law obliges us.
A paying client never receives your legal name, your address or your bank details. A provider never receives a client’s card details.
If any of these recipients is outside the European Economic Area, the transfer is covered by an adequacy decision or by standard contractual clauses.
09How it is protected
Documents and personal details are encrypted at rest and kept in an archive apart from the rest of the system. Only our compliance officer can open them. Every view and every download is written to a log that cannot be edited or deleted.
10How long we keep it
- Account documents, invoices and payment records: at least 5 years after your account is closed, and longer where tax or accounting law requires, up to 10 years.
- An application that was not approved: 6 months, unless the law obliges us to keep it longer.
- Payment records of paying clients: as long as the matching invoice must be kept.
- Server logs: up to 30 days.
After that the data is deleted for good.
11Your rights
You can ask us for a copy of your data, to correct it, to delete it, to restrict its use or to hand it to you in a format you can reuse. You can object to processing based on our legitimate interest. Where the law obliges us to keep something, we tell you what and until when.
Write to [privacy e-mail address to be completed]. We answer within one month. You can also complain to the data protection authority of the country where you live or, in Romania, to ANSPDCP.
12Automated decisions
Our fraud filters can block a payment automatically, for example when the card and the device are in different countries. If that happens to you, you can ask for a person to look at it.
13Age
Invozo is for adults. We do not knowingly collect data about anyone under 18, and we delete it if we find any.