Privacy Policy

Privacy policy of

(as of 25.05.2018)

As part of our privacy policy we inform the clients of our agency and the visitors of our Internet presence about the collection and processing of personal data by us. Personal data is any information that can be related to an identified or identifiable natural person, for example names, addresses, e-mail addresses, but also user behaviour.

1. Who is to be responsible for data processing?

Siemanet S.L. is responsible in the meaning of the General Data Protection Regulation (GDPR).

If there are any questions regarding data protection, feel free to contact us for assistance.

2. On what legal basis do we process personal data?

We process personal data in accordance with the guidelines of the European General Data Protection Regulation (GDPR).

According to Article 6 of the GDPR, data may be processed on the basis of consent, for the fulfilment of contractual obligations or pre-contractual measures, due to statutory provisions, in the public interest or insofar as the processing is necessary to protect our legitimate interests or the legitimate interests of a third party, unless the interests and fundamental freedoms of the data subject, which require the protection of personal data, prevail.

3. Which data is collected and processed by us during visits to our website?

When you visit our website for information purposes, i.e. if you do not register or otherwise provide us with information, we will only collect the personal data that your browser transmits to our server (the so-called "server log files"). The following data is of technical importance to present our Internet pages to you:

The IP address, date and time of the request, the time zone difference to Greenwich Mean Time (GMT), the exact content of the request (the specific page), the access status/HTTP status code, the amount of data transmitted, the source/internet page which sent the request, the browser you are using, the operating system used and its surface as well as the language and version of your browser software.

The processing is carried out in accordance with Article 6 paragraph 1 f) of the GDPR to ensure a smooth connection setup of our Internet pages, to guarantee a comfortable use of our website, to evaluate the system security and stability as well as for further administrative purposes.

Under no circumstances do we use the data collected for the purpose of drawing conclusions about you personally.

4. Which data is collected and processed by us upon registration as a member and in the course of bookings?

If you wish to send us an inquiry, we require and process specific data, such as, in particular, information on the booking you wish to make, your address and e-mail address and the method of payment chosen. You have the option of voluntarily providing us with additional information, such as a telephone number, e.g. to enable us to contact you more quickly.

Under the terms and conditions stated on our homepage you may gain access to the VIP Member Lounge. The acceptance of access to the VIP Member Lounge is at your discretion. Upon acceptance of access to the VIP Member Lounge, the data provided by you will be stored for the duration of access to the VIP Member Lounge.

As part of the operation of our company, we process your data using our IT systems. In some cases, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly inspected.

5. How is data processed by us in case of inquiries or messages by mail, fax, e-mail or via contact form?

If you send us inquiries or messages by mail, fax, e-mail or via contact form which refer to bookings, we will store your inquiry or message and our reply as part of the correspondence for the respective booking, pursuant to our legal obligation to preserve records.

If you wish to create a VIP Member account, we store your personal data, which was transmitted via contact form, in the VIP Member account. The data provided by you will be revocably stored for the period of the existence of the VIP Member account.

If you send us feedback about your experiences with one of our escort ladies by mail, fax, e-mail or via contact form, we will save this feedback and publish it on our website in anonymous form at our discretion.

If you send us inquiries or messages by mail, fax, e-mail or via contact form regarding a banner exchange, we may store your inquiry or message and our reply as part of the correspondence for the respective banner exchange, pursuant to our legal obligation to preserve records.

If you send us your application for a job as an escort lady by mail, fax, e-mail or via contact form, we will save your inquiry or message as well as our reply until the subsequent decision on your application.

In case of other inquiries or messages by mail, fax, e-mail or via contact form, we use your personal data provided exclusively to answer your inquiry, but do not subsequently store your inquiry and personal data provided in the inquiry.

6. With whom do we share personal data?

When you visit our website, we use cookies and/or analysis services. We will provide you with a detailed explanation in the further course of our privacy policy.

As part of bookings we pass on your personal data as far as this is necessary for the execution of bookings. For the processing of payments, we pass on the required payment data to the credit institution commissioned with the payment and, if applicable, to the payment service provider commissioned by us.

7. How long will personal data be stored by us?

The storage period of personal data is determined by the respective legal obligation to preserve records. The legal basis for the corresponding use of data complies with Article 6 paragraph 1 c) of the GDPR.

After expiry of the respective legal retention period, the corresponding data will be routinely deleted, provided that they are no longer necessary for the contractual performance or contract initiation and/or there is no longer any legitimate interest on our part in the continuation of a storage.

8. What rights are available to persons who are involved in data processing?

The applicable data protection law grants our customers and visitors of our Internet presence the following rights with regard to personal data concerning them:

- Right of access pursuant to Article 15 of the GDPR

You have the right to request information from us about the existence and details of the processing of personal data concerning you under the conditions of Article 15 of the GDPR.

- Right to rectification pursuant to Article 16 of the GDPR

You have the right to request us to instantly correct any inaccurate personal data concerning you.

- Right to erasure pursuant to Article 17 of the GDPR

You have the right to request us to delete your personal data under the conditions of Article 17 paragraph 1 of the GDPR.

- Right to restriction of processing pursuant to Article 18 of the GDPR

Under the conditions of Article 18 of the GDPR you have the right to request us to restrict the processing of your personal data.

- Right to data portability pursuant to Article 20 of the GDPR:

Under the conditions of Article 20 of the GDPR, you have the right to receive the personal data, which you have provided us, in a structured, current and machine-readable format or to request the transmission to another person responsible.

- Right to revoke consents granted, pursuant to Article 7 paragraph 3 of the GDPR

You have the right to withdraw a consent to the processing of your personal data you have provided to us at any time.

- Right to lodge a complaint pursuant to Article 77 of the GDPR

You have the right to lodge a complaint to a competent supervisory authority, in particular in the Member State of your residence, place of work or place of suspected infringement, if you consider that the processing of your personal data is contrary to the General Data Protection Regulation.

9. What personal data has to be provided?

It is not possible to carry out any bookings, without providing the correct specification of specific personal data.

10. What consents have been given to us?

You may have given us consents for making contact for advertising purposes or for certain data uses (for example to submit a newsletter). If you have given us a consent, the corresponding texts are stored by us and can be recalled. To access these texts, simply contact us by e-mail at the address given in section 1 of this privacy policy. We will subsequently send you the requested information by e-mail.

11. Use of cookies

We use so-called cookies on various pages to make our website more attractive and to enable the use of certain features. Cookies are small text files which are stored on your terminal device (laptop, tablet, smartphone or the like) when you visit our website. Cookies are used to make our website more user-friendly and effective overall. Cookies do no damage to your terminal device, do not contain viruses, Trojans or other malware.

Some of the cookies we use are deleted at the end of the browser session, i.e. after closing your browser (so-called transient or session cookies).

Other cookies remain on your terminal device and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (so-called persistent cookies). If cookies are set, they collect and process certain user information such as browser and location data as well as IP address values to the individually defined extent. Persistent cookies are automatically deleted after a specified period, but the duration up to deletion may vary depending on the cookie.

If any personal data is collected by individual cookies used by us, it is processed in accordance with Article 6 paragraph 1 f) of the GDPR to safeguard our legitimate interests in the best possible functionality of our Internet presence and a customer-friendly and effective configuration of the site visit.

We may work with third-party providers who help us to make our website more appealing to you. For this purpose, third party cookies will also be stored on your terminal device when you visit our website. If we cooperate with the aforementioned third-party providers, you will be informed separately about the use of such cookies and the extent of the information collected in each case in the further course of our privacy policy.

Please note that you can adjust your browser so that you are informed about each setting of cookies. You can also configure your browser so that you can decide whether to accept cookies or to exclude the acceptance of cookies in certain cases or in general. There are various ways in which different browsers determine the cookie settings. Changing the settings regarding the acceptance or rejection of cookies is described in the help menu of each browser, which will show you how you can change your cookie settings. You may also request that the stored cookies be deleted at any time with regard to the browser you are using.

Please note that the functionality of our Internet pages may be limited if cookies are not accepted.

12. Subscription to our newsletter

By giving your consent, you can subscribe to our newsletter, with which we will inform you about news in the context of our Internet presence.

For the registration to our newsletter we use the so-called double opt-in procedure. This means that after your registration we will send you an e-mail to the given address in which we will ask you to confirm that you would like to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

The only mandatory information for receiving the newsletter is your e-mail address. The disclosure of further, separately marked data is voluntary and will be used to address you personally.

After your confirmation we will save your e-mail address for the purpose of submitting the newsletter. The legal basis is pursuant to Article 6 paragraph 1 a) of the GDPR.

You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can revoke your consent by clicking the link provided in each newsletter, or by sending an e-mail to the address specified in section 1 of this privacy policy.

13. Use of Google Analytics

For the purpose of a demand-oriented configuration and continuous optimization of our Internet pages, we use Google Analytics, a web analysis service provided by Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google"). This involves the creation of pseudonymous user profiles and the use of cookies. The information generated by the cookie about your use of this website such as

- Browser type/version,

- the operating system used,

- Referrer URL (the previously visited page),

- Host name of the accessing computer (IP address),

- Time of the server request,

are transferred to a Google server in the USA where they will be stored. The information is used to evaluate the use of our website, to compile reports on the activities and to provide other services associated with the use of our website and the use of the Internet for the purposes of market research and demand-oriented configuration of these Internet pages.

This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be linked with other data from Google. The IP addresses will be anonymized, which disables any identification (IP masking).

You may prevent the installation of cookies by adjusting your browser software accordingly; however, we would like to point out that in this case not all features of our website may be fully usable.

You can also prevent the collection of data generated by the cookie and relating to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on.

(https://tools.google.com/dlpage/gaoptout?hl=en).

For further information on data protection in connection with Google Analytics, please refer to the Google Analytics Help: (https://support.google.com/analytics/answer/6004245?hl=en).

14. Use of social media plug-ins

In order to make us better known, we use social plug-ins from the social networks Facebook, Twitter, Instagram, Pinterest, LinkedIn and Google+ on our Internet pages, pursuant to Article 6 paragraph 1 f) of the GDPR. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of the GDPR.

a) Facebook

Facebook social media plug-ins are used on our web pages to make their use more personal.

For this purpose, we use the "Share" button. This is an offer made by Facebook.

When you access a page of our website that contains such a plug-in, your browser will establish a direct connection to the servers of Facebook. The content of the plug-in will be transmitted directly from Facebook to your browser and integrated into the website.

By integrating the plug-ins, Facebook will receive information that your browser has called up the corresponding page of our website, even if you do not have a Facebook account or are not currently logged on to Facebook. This information (including your IP address) will be transmitted directly from your browser to a Facebook server in the USA where it will be stored.

If you are logged in to Facebook, Facebook is able to assign your visit to our website directly to your Facebook account.

If you interact with the plug-ins, for example by clicking the "Like" or "Share" button, the corresponding information will also be transmitted directly to a Facebook server where it will be stored. The information will also be published on Facebook and displayed to your Facebook friends.

Facebook may use this information for advertising, market research and demand-oriented configuration of Facebook pages. For this purpose, Facebook creates usage, interest and relationship profiles, e.g. to evaluate your use of our website with regard to the advertisements displayed to you on Facebook, to inform other Facebook users about your activities on our Internet pages and to provide further services associated with the use of Facebook.

If you do not want Facebook to assign the data collected via our website to your Facebook account, you must log out of your Facebook account before visiting our website.

For the purpose and extent of the data collection and the further processing and use of the data by Facebook as well as your rights and setting options for the protection of your privacy, please refer to the data privacy statement of Facebook.

b) Twitter

Our website includes plug-ins of the short message network Twitter Inc. (Twitter). You can recognize the Twitter plug-ins (Tweet button) by the Twitter logo on our site. An overview of tweet buttons can be found here.

When you access a page of our website that contains such a plug-in, a direct connection will be established between your browser and the server of Twitter.

By doing so, Twitter will receive the information that you have visited our site with your IP address. If you click the Twitter "Tweet button" while logged into your Twitter account, you can link the contents of our pages on your Twitter profile. This allows Twitter to assign the visit of our pages to your user account.

We would like to point out that, as the provider of the website, we do not have any information about the content of the transmitted data or its use by Twitter.

If you do not want Twitter to assign your visit to our pages, please log out of your Twitter account before visiting our website.

For more information on this topic, please refer to the privacy policy of Twitter.

c) Instagram

Our website also uses so-called social plug-ins ("plug-ins") from Instagram, which is operated by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA ("Instagram").

The plug-ins are marked with an Instagram logo, e.g. an "Instagram camera".

When you visit a page of our website that contains such a plug-in, your browser will establish a direct connection to the servers of Instagram. Instagram will send the content of the plug-in directly to your browser and integrate it into the page. This integration informs Instagram that your browser has called up the corresponding page of our website, even if you do not have an Instagram profile or are not currently logged in to Instagram.

This information (including your IP address) will be transmitted directly from your browser to a server of Instagram in the USA where it will be stored. If you are logged in to Instagram, Instagram can immediately assign your visit to our website to your Instagram account. If you interact with the plug-ins, for example by pressing the "Instagram" button, this information will also be transmitted directly to a server of Instagram where it will be stored.

The information will also be published on your Instagram account and displayed to your contacts.

If you do not want Instagram to assign the data collected via our website directly to your Instagram account, you must log out of Instagram before visiting our website.

For further information, please refer to the privacy policy of Instagram.

d) Pinterest

Our website also contains plug-ins from Pinterest Inc. "("Pin it" button). Among other things, Pinterest enables users of its social network to publish image collections and individual images as well as descriptions on virtual pinboards, share them with other users and make comments.

The operating company of Pinterest is Pinterest Inc. 808 Brannan Street, San Francisco, CA 94103, USA.

By including the "Pin it" button, Pinterest will receive the information that you called up the corresponding page of our website. If you are logged in to Pinterest, Pinterest is able to assign the visit to your Pinterest account.

The data transmitted by clicking the "Pin it" button will be saved by Pinterest. If you want to prevent this, you must log out of your Pinterest user account before clicking on the "Pin it" button.

Please refer to the privacy policy of Pinterest for the purpose and extent of the data collection and the further processing and use of the data by Pinterest and your corresponding rights and setting options for protecting your privacy.

e) LinkedIn

Our website includes plug-ins of the LinkedIn Corporation.

LinkedIn is operated by the LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. Privacy matters outside the USA are under the responsibility of LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Every time you access our website, which features a LinkedIn plug-in, this component will cause your browser to download a corresponding representation of the LinkedIn component. Further information on the LinkedIn plug-ins can be found at https://developer.linkedin.com/plugins. As part of this technical process, LinkedIn will be informed about the specific subpage of our website that you are visiting.

If you are simultaneously logged in to LinkedIn, every time you visit our website and for the entire duration of your stay on our website, LinkedIn will recognize which specific subpage of our website you are visiting. This information will be collected by the LinkedIn plug-in and assigned to your LinkedIn account by LinkedIn. By pressing a LinkedIn button integrated on our website, LinkedIn will assign this information to your personal LinkedIn user account and the personal data will be stored. If you do not wish LinkedIn to receive such information, you can prevent the transmission by logging out of your LinkedIn account before visiting our website.

The privacy policy of LinkedIn is available at https://www.linkedin.com/legal/privacy-policy. For the cookie policy of LinkedIn please refer to: https://www.linkedin.com/legal/cookie-policy

f) Google+

The Google+ button is integrated as a component on our website.

Google+ is operated by Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Each time you visit one of the individual pages of our website, which features a Google+ button, your Internet browser will be automatically prompted by the respective Google+ button to download a representation of the corresponding Google+ button from Google. As part of this technical process, Google will be informed about the specific subpage of our website you are visiting. More detailed information about Google+ is available at https://developers.google.com/+/.

If you are simultaneously logged in to Google+, every time you visit our website and for the entire duration of your visit to our website, Google will recognize which specific subpage of our website you are visiting. This information will be collected by the Google+ button and assigned to your Google+ account by Google.

If you click on one of the Google+ buttons integrated on our website and thus make a Google+1 recommendation, Google will assign this information to your personal Google+ user account and will store the personal data. Google will save your Google+1 recommendation and make it publicly available in accordance with the corresponding terms you have accepted. Along with other personal information, e.g. the name of the Google+1 account you use and the photo included, a Google+1 recommendation made by you on our site will subsequently be stored and processed in other Google services, such as Google search engine results, your Google account or other locations, for example on websites or in connection with advertising. Furthermore, Google is able to link the visit to this website with other personal data stored by Google. Google also records this personal information for the purpose of improving or optimising the various services provided by Google.

If you do not wish your personal data to be transmitted to Google, you can prevent the transmission by logging out of your Google+ account before visiting our website.

Further information and the current data protection regulations of Google can be found at https://www.google.de/intl/de/policies/privacy/. Further information of Google on the Google+1 button can be found at https://developers.google.com/+/web/buttons-policy.

15. Data security

For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries), our website uses SSL or TLS encryption. Whether an individual page of our website is transmitted in encrypted form is indicated by the closed key or lock symbol in the lower status bar of the browser you are using.

Apart from that, we use suitable technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

16. No application of automated decision making

Hereby we assure that we do not conduct any automatic decision making including profiling.

17. Information on the right to object to processing pursuant to Article 21 of the GDPR

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is carried out by us on the basis of Article 6 paragraph 1 e) or f) of the GDPR.; this also applies to profiling based on these regulations.

We will then no longer process the personal data unless we can prove compelling reasons worthy of protection for the processing which outweigh the interests, rights and freedoms of the data subject or the processing serves to assert, exercise or defend legal claims.

If we process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing. If you object to the processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Please send your objection informally to the contact address given at the beginning of our privacy policy under section 1.