Last Updated: July 6, 2023

This website hyepnude.com (‘site’) is operated by SP Internet Media, Ltd. (‘we’, ‘us’, ‘our’). We process personal data about our site's visitors (‘you’, ‘your’). This Privacy Statement is intended to explain to you what personal data we process through your use of the site and what we do with that data. SP Internet Media, Ltd. is a company based in Cyprus. Our services mainly consist of providing website traffic to third-parties, which provide content to us, which is then made available to be viewed by you.

If you have any questions regarding the processing of personal data, you can find our contact details at the end of this Privacy Statement.

Use of personal data

We care about your privacy; therefore, we do our best to comply with relevant laws and regulations regarding the processing of personal data, such as the General Data Protection Regulation (‘GDPR’). This means we:

• clearly specify our purposes before we process personal data, by using this privacy statement;
• limit our collection of personal data to only the personal data needed for legitimate purposes;
• first ask for explicit permission to process your personal data in cases where your permission is required;
• take appropriate security measures to protect your personal data and we demand the same from parties who process personal data on our behalf;
• respect your right to access, correct or delete your personal data held by us.

Legal basis for processing

We will always process your personal data on one of the following basis:

• You have given consent to the processing of your personal data;
• The processing is necessary for the performance of the agreement with you or in order to take steps at your request prior to entering into a contract;
• We are legally obliged to process your personal data;
• We need to protect your or another person’s vital interests;
• We have a legitimate interest in the processing of your personal data.

Categories of personal data

We use the following personal data for the purposes mentioned in this privacy statement:

• E-mail address if you send us an email;
• Geolocation, namely country, state and region;
• Any other information you enclose with in the reporting, contact form or by email;
• Information on your use of our website (such), cookie identifier and as IP-address (limited processing );

Cookies

A cookie is a small file that is being delivered to you through the pages of this website and that is being stored on your computer. Local storage is an industry-standard technology that allows a website or application to store information locally on your computer or mobile device. The information stored in cookies is being used by us each time you visit our website. Cookies help us to analyze the traffic to and from our website and deliver our visitors a better experience during their visit. We use cookies to enable functionalities of the website (technical or functional cookies) and analyze the use of the website and improve the website on that basis (analytical cookies).

This website uses cookies and other similar technologies, such as local storage (collectively referred to as “cookie" or "cookies” in this document). According to the GDPR parts of this information could be interpreted as (online) identifiers and therefore may qualify as personal data, especially when these types of data are combined. However, for most of our functionalities and features, we process data through anonymous cookies since this information does not relate to an identified or identifiable natural person (unless stated otherwise). For full transparency we have outlined more information on the cookies that are placed through our website below.

Cookie consent

When you visit our website for the first time, we will show you a message containing an explanation about cookies. Insofar as we are obliged to do so, we will ask for your consent to the use of those cookies. Your consent to our use of other cookies is automatically given by a clear affirmative act on our website, such as clicking on a specific website feature, for example the language filter. For further information on which categories of cookies we use, please see below.

Withdrawing cookie consent

You can easily withdraw your consent to our use of cookies by clearing your cookies and closing your browser. Your browser settings allow you to delete and/or block certain cookies. If you do not agree (anymore) to the use of cookies, we recommend that you change your preferences and use the correct browser settings. To clear your cookies in your browser settings, please visit the help-page of the browser you use. Changing these settings and preferences may limit your ability to take full advantage of our website.

Categories of cookies we use

• Strictly necessary cookies – These cookies are necessary for the site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as changing your cookie settings or browsing the site.
• Analytical cookies – This website uses first party and third-party analytical cookies to collect information about your visit to this website.

• First Party Analytics - We place our own analytical cookie. The information in this persistent cookie has a retention period of 12 months. We consider the data We process through analytical cookies anonymous, since this information does not relate to an identified or identifiable natural person. We may disclose aggregated, anonymous information to third parties to operate our services properly.
• Third Party Analytics by Google Universal Analytics - A third party analytical cookie is placed by Google as part of our use of the service Google Universal Analytics. Google may transfer this information to third parties only when required by law or in cases where third parties process the information on Google's behalf. We have no influence on this. We have not allowed Google to use the information acquired through the analytical cookies for other Google services or advertisements. When we use Universal Analytics’ IP-address anonymization opt-in service, Universal Analytics will anonymize the address as soon as technically feasible. The IP-anonymization feature in Universal Analytics sets the last octet of IPv4 user IP addresses and the last 80 bits of IPv6 addresses to zeros in memory shortly after being sent to Google Analytics. The full IP address is never written to disk in this case. Geographic dimensions are later derived from anonymized IP addresses. The information is transmitted to Google and stored on its servers in the United States. We have executed a Data Processing Agreement (or Data Processing Amendment) with Google regarding their Google Universal Analytics service. We do not use other Google services, such as DoubleClick and Adwords, in conjunction with the Google Universal Analytics cookies. Please note that Google offers a browser Add-on which enables you opt-out of Google Universal Analytics' use of your (personal) data. You can find the add-on here.
• Third Party Analytics by Google Optimize - We use Google Optimize to analyze which parts and pages of the website perform well. Google Optimize is used to register and measure mouse clicks, mouse movements and scrolling behavior of the website visitors. This gives us insights into the parts of the webpage that perform well. The tool allows us to test webpages and components such as buttons, images or texts through A/B testing. The test splits up the visitor groups in two. One group gets to see version A of the webpage and the other group gets to see version B. With A/B testing we can determine which webpage is an improvement to our services. The data collected by Google Optimize is completely anonymous and cannot be traced back to a person. For more information about anonymously collected data, see Google Optimize's privacy statement. The privacy statement can change regularly.

• Functional Cookies – This website uses cookies to enable the site to provide enhanced functionality and personalization by allowing you to choose your desired language from the language selector.

For an overview of cookies and similar technologies that may be placed through our site see the table below:

Name	Type	Purpose	Expiration date
ta	Persistent cookie	First party analytics	365 days
variation	Persistent cookie	First party analytics	90
splashPageAccepted	Persistent cookie	First party cookie, stores if splash page is accepted	365 days
colorScheme	Persistent cookie	First party cookie, stores which color scheme is selected	365 days
tag	Persistent cookie	First party cookie, stores which tags are selected (pricing)	30 days
tag-t-closed	Session based cookie	First party cookie, stores if a notice or suggestion is closed	session
hiring	Persistent cookie	First party cookie, stores if a notice or suggestion is closed	365 days
session	Session based cookie	First party cookie, stores user session	session
locale	Persistent cookie	First party cookie, stores language setting	365 days
_gid	Persistent cookie	Third party analytics by Google	1 day
_ga	Persistent cookie	Third party analytics by Google	730 days
_gat	Persistent cookie	Third party analytics by Google	0 days
_utma	Persistent cookie	Third party analytics by Google	730 days
_gaexp	Persistent cookie	Third party analytics by Google	90 days

Use of other (technical) information containing personal data and anonymization

When you visit and interact with our website, your browser or device automatically transmits certain technical information to our website. Among other technical information, your IP address will temporarily be viewed, for less than a second, before certain technical information is aggregated and anonymized. We have a legitimate interest in processing personal data before making the data anonymous for the purposes described below. Such information enables us to know for example, which browser type you use, what your browser settings are, what country you are in and what your referrer is. With this information we can optimize your user experience by showing the website in your language, optimize rankings, customize the user interface etc.

However, we mainly use this information for analytical, statistical and research purposes, such as tracking referrals and incoming and outgoing traffic. We anonymize these data to the extent the data is not already anonymous. This means that the personal data originally obtained by us is made anonymous in such a way that the person concerned can no longer be identified based on this data and this process cannot be reversed. The data is therefore no longer personal data and there are no privacy risks associated with this. By means of this anonymized data we can perform statistical research and improve our website without compromising your privacy.

What happens to my personal data when I use certain features?

When you provide your personal data to use one of our website features, then we may temporarily process your personal data. For example, you may voluntarily provide us with your e-mail address when reporting malware through our report tool or provide us with other (personal) data by sending us a(n) (e-mail) message. We have a legitimate interest to process this personal data.

E-mails and other messages/mediums

The data processed by sending us an e-mail is limited to your e-mail-address, the content of the message and the standard technical information included in e-mails. We will process whatever personal data you included in the message. However, we will only process this data to handle your request or feedback. The period for which we retain personal data included in your e-mail, depends on the scope of your request and our legal obligation to retain such data to comply with local laws and regulations, if any. Please do not send us copies of passports or identification documents. Also, please refrain from sending us unnecessary personal data through any of our features.

Report tool

If there is an issue with content on our website, you can notify us by using our Report Tool. The information we process with such a report is stored temporarily and limited to technical data, which is anonymous data since this does not relate to an identified or identifiable natural person. However, if you voluntarily provide any personal (contact) information, this will be temporarily processed by us, depending on the extent of your request and our legal obligation to retain such data, if any. We will solely use this information to process your report.

No memberships, subscriptions, accounts, profiles etc.

We do not provide memberships, subscriptions, accounts, profiles or any other means that lead to an agreement between you and us, except from your use of the website. We do not collect your personal data for such purposes. If you come across a feature on this website that requests your personal data for such a purpose, for any reason, please note this is not our feature and you should proceed with caution and report this to us.

Overview

Below you will find an overview of the information (including personal data) that we process, if you choose to actively provide this information to us. Please note that the Report Tool feature we use below requires your personal data to be transferred to our database located in the USA, and that you therefore need to consent to this in order to use this feature:

E-mails (or other messages)	Purpose of storage	Data Retention period
E-mail address and/or username/account-name	To process your request	Deleted after 1 year *
Personal data included in your message (if you chose to provide this to us)	To process your request	Deleted after 1 year *
Report Tool	Purpose of storage	Data Retention period
E-mail address (if you chose to provide this to us)	To process your report	Masked after 1 month
Any other (technical) information included in your report	To process your report	Deleted after 1 year

* The extent of your request might result in a longer (or shorter) storage period. This will be communicated to you if applicable.

Transferring your personal information to other countries

We use third-party providers in order to provide the features and services described above. If any such third-party provider is located outside of the EEA, and cross-border transfers will be made pursuant to standard contractual clauses approved for use by the European Union (“EU”). In order to use certain features/services, you will need to consent to such transfers.

Security

We take your privacy seriously and, therefore, we have taken appropriate technical and organizational measures to prevent and minimize the risk of unauthorized or unlawful processing, inappropriate use, inaccuracy, accidental loss, destruction and/or damage of (personal) data stored on our network and systems, insofar as this is reasonably possible and expected of us.

Retention periods

We do not store your personal data longer than necessary to achieve the purposes stated in this privacy statement. Some data must be retained for a longer period due to statutory obligations.

Your rights

If we process your personal data, you have the following rights:

• Right of access: you have the right to see what kind of personal data we process about you;
• Right of rectification: you have the right to rectify any personal data we process about you, if this information is (partially) wrong;
• Right to be forgotten: you can file a request to delete any personal data we process about you;
• Right to data portability: if technically feasible, you have the right to ask us to transfer your processed personal data to a third party;
• Right to restriction: you can file a request with us to (temporarily) restrict the processing of your personal data;
• The right to withdraw your consent; if we process your personal data on the legal bases of consent, you are always free to withdrawal your consent.

If you exercise any of the rights mentioned above, we will ask you to identify yourself, to ensure that you are the person to whom the personal data belongs to.

Complaints

You also have the right to lodge a complaint with a supervisory authority. We suggest that you contact the competent supervisory authority in the country of your habitual residence, place of work or place of the alleged infringement.

Changes to this Privacy Statement

We reserve the right to make changes to this Privacy Statement. We recommend that you regularly visit this page and check if you have read the latest version of the Privacy Statement, which is indicated by the ‘Last Modified’ date stated above. Please refresh your browser when you re-visit this page to make sure that your browser shows you the latest version of this Privacy Statement.

Any Questions

If you wish to exercise your right as described in this Privacy Statement, or if you have questions about this Privacy Statement, please contact our Data Protection Officer via: compliance@hypenude.com.

General contact information

• SP Internet Media, Ltd.
• Office Archiepiskopou Makariou III
• 18B, Annnitas Complex, House 6,
• Anafotia, 7573, Larnaca, Cyprus
• Registration #: HE381896
• compliance@hypenude.com