Privacy Policy

Last updated: 21 September 2026

1. Introduction

Ladies.com.cy (“we”, “us” or “the platform”) takes the protection of your personal data seriously. This Privacy Policy explains what personal data we collect, why we collect it, how we process it and what rights you have.

This Privacy Policy applies to all users of ladies.com.cy. It is based on the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR) and the Cypriot law on the protection of natural persons with regard to the processing of personal data (Law 125(I)/2018), and constitutes the information required under Articles 13 and 14 GDPR.

2. Controller

The controller responsible for processing your personal data is the operator of the platform:

Ladies.com.cy
E-mail for data protection requests: [email protected]
General enquiries: [email protected]
Website: ladies.com.cy
Full details: Legal notice

No data protection officer has been appointed, as there is no legal obligation to do so.

3. What data do we collect?

3.1 Data you provide to us

3.2 Data collected automatically

The platform is hosted on servers in Germany (Frankfurt am Main), within the EU. Server log files are processed there by the hosting provider on our behalf.

3.3 Data from publicly available ad sources

Some ads on the platform were not submitted to us by the person concerned, but come from publicly available ad sources: other advertising websites on which the person concerned made the ad public themselves. As we did not collect this data directly from you, we inform you about it in this policy (Article 14 GDPR).

Legal basis. We base this processing on our legitimate interest (Article 6(1)(f) GDPR) in a complete and useful overview of ads. Where the data reveals something about a person's sex life or sexual orientation, it is data that the person concerned has manifestly made public themselves (Article 9(2)(e) GDPR).

Retention. These ads are removed as soon as the original ad is no longer available, as soon as the person concerned asks us to, or at the latest 12 months after the ad was last updated.

Objection and removal – no reasons needed, free of charge. Is your ad, photo or phone number shown on the platform without your wish? Then we remove this content at your request, without you having to explain why. There are two ways to do this:

• via ladies.com.cy/melden, choosing the reason that your photos or data were published without your consent;
• by e-mail to [email protected], with the link to the ad.

We handle such requests with priority and make sure that the ad is not added again afterwards. For this purpose we store a minimal block entry (such as the phone number or the source URL). This does not affect your other rights under section 10 of this policy, in particular your rights of access, rectification and objection (Article 21 GDPR).

3.4 Special categories of personal data in ads

Ads on the platform may contain information from which conclusions can be drawn about a person's sex life, sexual orientation, origin or health (special categories, Article 9 GDPR). Such information comes exclusively from the advertisers themselves: they decide what to publish in their ad and thereby make this information public deliberately. We process it on the basis of the explicit consent given when the ad is posted (Article 9(2)(a) GDPR), or because the person concerned has manifestly made it public (Article 9(2)(e) GDPR). Consent can be withdrawn at any time by changing the information or deleting the ad. Please note that published ads can be viewed by anyone and may be indexed by search engines.

3.5 Anonymous reviews

Ads can be rated with stars without an account. We store the rating given, the ad concerned, the time and the IP address from which the rating was submitted. The IP address is not published; it is used only to allow one rating per connection per ad, to show you your own rating again and to prevent manipulation (mass voting). The legal basis is our legitimate interest in genuine ratings (Article 6(1)(f) GDPR). Written reviews are checked by us and may be removed if they breach the Terms and Conditions. Advertisers who have been reviewed can challenge a review through our reporting form.

4. Legal bases for processing

We process your personal data on the following legal bases (Article 6 GDPR):

• Performance of a contract (Article 6(1)(b) GDPR): to create and manage your account, publish ads and process paid options.
• Legitimate interest (Article 6(1)(f) GDPR): for the security of the platform, fraud prevention, protection against misuse and the improvement of our services.
• Legal obligation (Article 6(1)(c) GDPR): to comply with legal obligations, for example under Regulation (EU) 2022/2065 (DSA) and tax record-keeping rules, and to cooperate with authorities where human trafficking or the involvement of minors is suspected.
• Consent (Article 6(1)(a) GDPR and the ePrivacy rules on cookies): for analytics cookies, for publishing special categories of data in ads and for sending newsletters or marketing messages (you can withdraw this consent at any time).

5. Purposes of processing

We process your personal data for the following purposes:

• creating, managing and maintaining your account;
• publishing and displaying ads;
• answering questions and enquiries via the contact form or by e-mail;
• handling reports and removal requests;
• processing credit top-ups and paid options;
• ensuring the security and integrity of the platform;
• preventing and detecting fraud and misuse;
• improving and optimising the platform;
• complying with legal obligations;
• producing statistics and analyses (anonymised).

No solely automated decision-making with legal effects and no profiling takes place. Automated content filters are described in the Terms and Conditions (section 6.4); final decisions are made by a person.

6. Sharing data with third parties

We do not share your personal data with third parties, except in the following cases:

• Processors: we use service providers that process data on our behalf, with whom we have concluded data processing agreements. These include:
  • Hosting: data centre in Germany (Frankfurt am Main) – storage of all platform data and server log files;
  • Cloudflare (Cloudflare, Inc., USA, with European subsidiaries) – content delivery network, DDoS and bot protection; see section 6.1;
  • E-mail delivery: system messages (registration, password, notifications, replies to enquiries) are sent via our hosting provider's mail server;
  • Google Analytics (Google Ireland Limited) – only with your consent; see section 8.
• Payment provider: when you top up credit with cryptocurrency, you are redirected to NOWPayments; see section 6.2.
• Legal obligation: where we are required to do so by law, by a court order or at the request of a competent authority.
• Suspected criminal offences: if human trafficking, exploitation or the involvement of minors is suspected, we pass data to the competent authorities, including the Cyprus Police, without delay.

We never sell your personal data to third parties.

6.1 Cloudflare

All traffic to the platform passes through Cloudflare's network. Cloudflare processes in particular your IP address, technical connection data and the URL requested, in order to deliver content faster and to fend off attacks and automated access. Cloudflare may set a strictly necessary cookie for this purpose (e.g. __cf_bm). The legal basis is our legitimate interest in secure and stable operation (Article 6(1)(f) GDPR). Processing in the USA cannot be ruled out; Cloudflare is certified under the EU-U.S. Data Privacy Framework, and standard contractual clauses also apply. More information: cloudflare.com/privacypolicy.

6.2 Payments via NOWPayments

Where credit top-ups are enabled on the platform, payment is made in cryptocurrencies via the external payment provider NOWPayments (nowpayments.io). We transmit the amount and an internal order number; NOWPayments processes the payment (wallet addresses, transaction data, IP address) as an independent controller under its own privacy policy. We receive only a payment confirmation with reference, amount and status. We never receive wallet credentials or bank details. Please note that blockchain transactions are publicly visible and cannot be deleted. The legal basis is the performance of a contract (Article 6(1)(b) GDPR).

6.3 Transfers outside the EU

Your data is stored within the EU (Germany). Where service providers process data in third countries (in particular the USA), this is done on the basis of an adequacy decision (EU-U.S. Data Privacy Framework, Article 45 GDPR) or standard contractual clauses (Article 46(2)(c) GDPR).

7. Retention periods

We do not keep your personal data longer than necessary for the purposes for which it was collected:

• Account data: until the account is deleted, plus a maximum of 6 months.
• Ad data: until the ad is deleted or the account is closed.
• Contact form and e-mail enquiries: a maximum of 12 months after the enquiry has been dealt with.
• Technical log files: a maximum of 6 months.
• Ads from public sources (section 3.3): until the original ad expires or the person concerned requests removal, at the latest 12 months after the last update.
• Anonymous reviews (section 3.5): as long as the reviewed ad exists; when the ad is deleted, the stored IP address is deleted too. On request we delete your review earlier.
• Reports and removal requests: up to 3 years after the procedure has been closed, so that decisions can be evidenced and repeated breaches recognised; block entries for as long as they are needed to prevent republication.
• Proof of age: only as long as needed for the check; afterwards it is deleted and only a record that and when the check took place is kept.
• Payment and booking data: for the period required by Cypriot tax and accounting law (generally 6 years).

When the retention period ends, the data is deleted or anonymised.

8. Cookies and local storage

Ladies.com.cy uses cookies and your browser's local storage so that the platform works properly. We distinguish between:

• Strictly necessary cookies and entries: required for the platform to work – session cookie (PHPSESSID), login cookie for logged-in users, Cloudflare security cookies, and the confirmation that you are an adult and your cookie choice stored in local storage. These are always set (Article 6(1)(f) GDPR).
• Analytics cookies: to collect usage statistics (Google Analytics). These are set only with your consent.

Google Analytics. With your consent we use Google Analytics 4, a web analytics service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The service is disabled by default (Google Consent Mode: analytics storage “denied”) and is only activated if you agree in the cookie notice. Pseudonymous usage data is collected (pages viewed, time on site, approximate location, device and browser information). IP addresses are anonymised by Google Analytics 4 and are not stored. We have concluded a data processing agreement with Google; a transfer to Google LLC in the USA is possible and takes place on the basis of the EU-U.S. Data Privacy Framework or standard contractual clauses. Analytics data is retained for a maximum of 14 months. The legal basis is your consent (Article 6(1)(a) GDPR). You can withdraw your consent at any time with effect for the future by clearing this site's data in your browser and choosing “necessary only” in the cookie notice, or by using Google's browser add-on.

You can manage or block cookies in your browser settings. Blocking strictly necessary cookies may limit the functionality of the platform.

9. Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration. These include:

• SSL/TLS encryption of all connections;
• encrypted (hashed) storage of passwords;
• regular security updates and checks;
• limiting access to personal data to what is necessary.

10. Your rights

Under the GDPR you have the following rights:

10.1 Right of access

You have the right to know what personal data we process about you and to obtain a copy of it (Article 15 GDPR).

10.2 Right to rectification

You have the right to have inaccurate or incomplete personal data corrected (Article 16 GDPR).

10.3 Right to erasure (“right to be forgotten”)

You have the right to request the erasure of your personal data (Article 17 GDPR) if:

• the data is no longer needed for the purpose for which it was collected;
• you withdraw your consent and there is no other legal basis for the processing;
• you object to the processing;
• the data has been processed unlawfully.

10.4 Right to restriction of processing

You have the right to have the processing of your data restricted, for example if you contest the accuracy of the data (Article 18 GDPR).

10.5 Right to object

You have the right to object to the processing of your data where it is based on our legitimate interest – in particular for ads from public sources (section 3.3) – and at any time to processing for direct marketing (Article 21 GDPR).

10.6 Right to data portability

You have the right to receive your data in a structured, commonly used and machine-readable format and to transmit it to another controller (Article 20 GDPR).

10.7 Right to withdraw consent

Where processing is based on your consent, you can withdraw it at any time. This does not affect the lawfulness of processing carried out before the withdrawal.

10.8 Exercising your rights

You can exercise your rights by sending a request to [email protected]. We reply within one month and free of charge. We may ask for additional information to verify your identity; for removal requests concerning ads from public sources, the link to the ad is sufficient.

11. Right to lodge a complaint

If you believe that we are not processing your personal data properly, you can lodge a complaint with the Commissioner for Personal Data Protection of the Republic of Cyprus (Article 77 GDPR):

Commissioner for Personal Data Protection
Iasonos 1, 1082 Nicosia, Cyprus
E-mail: [email protected]
Website: dataprotection.gov.cy

You can also contact the supervisory authority of your habitual residence or place of work in another EU member state.

12. Changes

Ladies.com.cy reserves the right to amend this Privacy Policy. Changes take effect as soon as they are published on the platform. We recommend that you check this page regularly.

13. Contact

If you have questions about this Privacy Policy or the processing of your personal data, you can reach us via:

E-mail: [email protected]

Report content: ladies.com.cy/melden · Legal notice: ladies.com.cy/impressum