Privacy Policy

Privacy Policy

This Privacy Policy has been updated on May 11 , 2024


PAXTERN LIMITED (Legal address: 4-8 Ludgate Circus, London, England, EC4M 7LF, United Kingdom, company number: 14690414) («PORNGAP», «We», «Our») understands that Your privacy is important to You and is committed to providing You with the needed level of transparency and control over the data We are collecting and using.

This Privacy Policy describes how We collect and use the Personal Data You provide. It also describes the choices available to You regarding Our use of Your Personal Data and how You can access the information. We respect Your privacy and We take protecting it seriously, and respect Your desire to keep track of the data We collect, along with knowing what exactly it is used for.

When You use Our Service, You consent to the collection, storage, use, disclosure, and other uses of Your Personal Data as described in this Privacy Policy.

This Policy applies to:

  • people who use the Service;
  • people who make complaints to Us by email.


The Privacy Policy is required to be read and interpreted in conjunction with Our Terms and Conditions accessible at We encourage You to take the time and pay attention to it.


    • 1.1 Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in Our Terms and Conditions.
    • 1.2 The following terms shall have the following meaning:
      • 1.2.1. «Personal Data» means data that is related to an identified or identifiable natural person;
      • 1.2.2. «Usage Data» is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit);
      • 1.2.3. «User» also corresponds to the Data Subject, who is the subject of Personal Data.
    • 2.1. We adhere to the following principles to protect Your privacy:
      • 2.1.1. Lawfulness and fairness of processing. Personal Data is collected and processed lawfully, fairly, and correctly in relation to the User in order to protect its individual rights;
      • 2.1.2. Limitation of purpose. Personal Data is only collected for specific, explicit, and legitimate purposes defined prior to data collection and communicated to the intended User and is not further processed in a manner that is incompatible with those purposes;
      • 2.1.3. Transparency. The User has the right to be informed about the manner of the processing and use of the data, collected directly from the User;
      • 2.1.4. Precise and current data. We accurate Personal Data and, where necessary, keep it up to date. We take every reasonable step to ensure that inaccurate Personal Data, having regard to the purposes for which they are processed, are erased or rectified without delay;
      • 2.1.5. Data reduction and minimization. Before processing Personal Data, We determine whether and to what extent processing of Personal Data is necessary to achieve the purpose for which it is being processed;
      • 2.1.6. Storage Limit. We store Personal Data in a form that allows the identification of the Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed;
      • 2.1.7. Integrity and confidentiality. Personal Data is processed using appropriate technical, organizational, and security measures on Our side with the intention to protect such data against unauthorized or unlawful processing, as well as against accidental loss, destruction, or deterioration. In the event of an incident, We restore in a timely manner the availability and access to personal data.
    • 2.2. PAXTERN LIMITED (Legal address: 4-8 Ludgate Circus, London, England, EC4M 7LF, United Kingdom, company number: 14690414) acts as the data controller of the personal information collected and processed through the Website.
    • 3.1 To full fill Our obligations on the provision of the Service for You and applicable Terms and Conditions, We are entitled to ask You to provide Us with Your Personal Data, including (but not limited to):
      • 3.1.1. Email address;
      • 3.1.2. First name, Last name, Date, month, year of birth, gender, city and country of residence, education and professional experience, and other identifying information at Your discretion;
      • 3.1.3. Other identifying information in emails or letters from You.
    • 3.2. We may collect Personal Data from You in various ways and circumstances, including, but not limited to, when accessing the Website, filling out a registration form in order to register a Personal Account, updating a Personal Account, or providing feedback. We shall be entitled to combine Personal Data collected during Your interaction with different Website sections with any other relevant information.


    • 4.1. We may also automatically collect data as Users interact with Our Service. Personal Data automatically collected by or transmitted to Us in the course of accessing, interacting, and operating the Service may include, without limitation, the following Personal Data:
      • 4.1.1. Usage Data (Server log information). Using the Service generates data about Your activity on Our Service which may include (but is not limited to) Your login details, the date and time of visits, the pages viewed, Your IP address, time spent at the Service, features You’ve been using, actions taken, the information shown to You, referring webpages addresses and ads that You interacted with;
      • 4.1.2. Device information. We may collect information from and about the device(s) You use to access Our Service, including hardware and software information such as device ID, type, operating system, and version, identifiers associated with Cookies, or other technologies that may uniquely identify a device or browser;
      • 4.1.3. Information collected by Cookies and other similar technologies. We and Our service providers use various technologies to collect information when You interact with the Service, including Cookies and other similar technologies. Where required, You will be asked for consent to Our use of Cookies. To view more information on what Cookies We use and how We use them, please review our separate Cookies Section in this Privacy Policy.
    • 5.1 Subject to possible restrictions under national law, as a Data Subject under the General Data Protection Regulation (GDPR), You may have certain rights regarding the Personal Data that We collect regarding You.
    • 5.2 Under Chapter 3 of the GDPR, the rights of the Data Subjects include the following:
      • 5.2.1. Right to access. You may contact Us to get confirmation as to whether or not We are processing Your Personal Data. When We process Your Personal Data, We will inform You of what categories of Personal Data We process regarding You, the processing purposes, the categories of recipients to whom Personal Data have been or will be disclosed, and the envisaged storage period or criteria to determine that period;
      • 5.2.2. Right to withdraw consent. In case Our processing is based on the consent granted, You may withdraw the consent at any time by contacting Us or by using the functionalities of the Website. You can withdraw Your consent at any time by replying to the email with Your withdrawal, and Your Personal Data will be deleted immediately. Withdrawing consent may lead to fewer possibilities to use the Website;
      • 5.2.3. Right to object. In case Our processing is based on a legitimate interest to run, maintain, and develop Our business, You have the right to object at any time to Our processing. We shall then no longer process Your Personal Data unless for the provision of Our services or if We demonstrate other compelling legitimate grounds for Our processing that override Your interests, rights, and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, You have the right to prohibit Us from using Personal Data for direct marketing purposes, by contacting Us or by using the functionalities of the Website, or unsubscribing possibilities in connection with Our direct marketing messages;
      • 5.2.4. Right to restriction of the processing. You have the right to obtain from Us restriction of processing of Your Personal Data, as foreseen by applicable data protection law, e.g. to allow Our verification of the accuracy of Personal Data after You contest the accuracy or to prevent Us from erasing Personal Data when Personal Data are no longer necessary for the purposes but still required for Your legal claims or when Our processing is unlawful. Restriction of processing may lead to fewer possibilities to use the Website;
      • 5.2.5. Right to data portability. You have the right to receive Your Personal Data from Us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case Our processing is based on Your consent and carried out by automated means;
      • 5.2.6. Right to complain. You have the right to complain to any relevant Data Protection Authority, in particular in the Member State of Your residence, place of work, or the place of processing Your Personal Data. If You wish to exercise any of the aforementioned rights, please contact Us via
    • 5.3. How to use these rights. To exercise any of the above-mentioned rights, You should primarily use the functions offered by the Website. If such functions are however not sufficient for exercising such rights, You shall send Us an email to the address set out below under this Privacy Policy, including the following information: name, address, phone number, email address, and a copy of a valid proof of identity. We may request additional information necessary to confirm Your identity. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.
    • 5.4. You may have other rights under the law applicable in Your jurisdiction.
    • 6.1. Consent to Personal Data Processing
      • 6.1.1. By accepting this Privacy Policy, You approve to have reached the age of majority or the legal age in Your jurisdiction (generally 18 (eighteen) or older), and that You are solely responsible for all Your actions, and fully understand the statements outlined in this Privacy Policy.
    • 6.2. EU Persons Consent to Personal Data Processing
      • 6.2.1. If You are an EU Person and to process Your Personal Data, We need to receive Your consent, as prescribed by the GDPR, We will process Your Personal Data only in the case We have received from You a freely given, specific, informed, and unambiguous indication of Your wishes by which You signify agreement to the processing of Your Personal Data («Consent»).
      • 6.2.2. We only collect the location information where Users have granted Us permission to do so through the obtaining permission system used by their mobile or computer device platforms, including, but not limited to, IOS, Android.
      • 6.2.3. You may give your consent by ticking the respective box when You register for a Personal Account with Our Service. In the case You tick the respective box, You irrevocably and unconditionally consent and agree that We shall be entitled to process Your Personal Data as indicated by Your Consent.
      • 6.2.4. Your Consent covers all processing activities with Your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, Your Consent should be deemed given for all of them.
    • 6.3. Non-EU Persons Consent to Personal Data Processing
      • 6.3.1. If You are not an EU Person, by transferring to Us Your Personal Data via the Website or otherwise, You irrevocably and unconditionally consent and agree that We shall be entitled, in accordance with this Privacy Policy:
        • to process in any manner, including to collect, store, use, disclose, share, and transfer (including cross-border), Your Personal Data so provided to Us, as well as Your Personal Data collected from Your use of the Service (i.e. Your Personal Data which We collect automatically and/or from other sources); and
        • to use Cookies and similar technologies to collect Your Personal Data.
    • 7.1. We may have to share Your Personal Data with the parties set out below:
      • 7.1.1. Internal concerned parties. We may share Your Personal Data with companies in Our group, in order to provide You with Our services. Please note that this information is anonymized automatically;
      • 7.1.2. Business partners. We may share Your Personal Data with Our business partners, such as storage and analytics providers who help Us provide You with Our Service. These third parties may have access to Your Personal Data so that they may perform these tasks on Our behalf, but they are obligated to comply with this Privacy Policy and may not use Your Personal Data for any other purpose;
      • 7.1.3. Compliance with laws and law enforcement entities. We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose an individual’s Personal Data to the government or law enforcement officials as We, at Our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including, but not limited to, subpoenas), to protect Our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity We may consider to be or to pose a risk of being, illegal, unethical, inappropriate, or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
    • 7.2. PORNGAP does not sell Your Personal Data to third parties. A «sale» of Personal Data under the CCPA is defined broadly to include the «selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means» the Personal Data of a User to another business or third party «for monetary or other valuable consideration». However, We may share Your Personal Data if We enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of Our assets. Any party that acquires Our assets as part of such a transaction may continue to use Your Personal Data in accordance with the terms of this Privacy Policy. If We decide to sell Our assets including the Service, We will inform You about this, so You can forbid Us to transfer Your Personal Data together with Our business. If so, We will delete Your Personal Data from the databases prior to a business transfer.
    • 8.1. We work with third-party service providers who provide website hosting, maintenance, and other services for Us. They may be located outside of the EEA. These contractors may have access to or process Personal Data on Our behalf as part of providing those services for Us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions.
    • 8.2. For Users in EEA: All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the EEA may be possible only in the case when We have obtained Your consent for it.
    • 8.3. For Users in the US: All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the US may be possible only in the case when We have obtained Your consent for it.
    • 8.4. We host Our Website on UNIHOST. UNIHOST is a service provider that provides a variety of hosting services, including servers for hosting, streaming, storing, and processing large amounts of data. We have chosen to host Our Website on UNIHOST because We believe that they offer a high level of security and reliability. UNIHOST must not sell or rent your Personal Data to third parties. You can find more information about UNIHOST’s privacy practices here:
    • 8.5. All data processed by Us is stored exclusively in secure hosting facilities provided by UNIHOST (Finland).
    • 8.6. We may share Your Personal Data with Our insurers, Our professional advisors (lawyers, bankers, auditors, corporate financiers, barristers, and brokers), and Our technical specialists in connection with the services they provide to Us. If We share Your Personal Data with those processors, We will require the recipient to keep it confidential and secure by concluding a nondisclosure agreement.
    • 9.1. We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it.We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, disclosure, loss, misuse, or destruction of Your Personal Data. We limit access to Your Personal Data only to those persons on a «need to know» basis, in order to enable the carrying out of the agreement between Us.
    • 9.2. While We seek to protect Your information to ensure that it is kept confidential, We cannot absolutely guarantee its security. You need to help Us prevent unauthorized access to Your account by protecting Your device appropriately and limiting access to Your account. You should also be aware that there is always some risk involved in transmitting information over the internet. While We strive to protect Your Personal Data, We cannot ensure or warrant the security and privacy of Your Personal Data or other content You transmit using the service, and You do so at Your own risk.
    • 9.3. We never process any kind of criminal offense data. Also, We never undertake to profile Personal Data.
    • 9.4. Due to the nature of Internet communications and evolving technologies, there is no 100% secure method of transmission over the Internet or method of electronic storage. Although We do Our best to protect Your information, We cannot guarantee its absolute security. We cannot provide, and we hereby disclaim, assurance that the data You provide Us will remain absolutely secure.
    • 9.5. SENSITIVE DATA. We may collect and process certain sensitive data provided by You. You may provide such sensitive data to Us when filling out Your information in Your Personal Account using the functionality of Our Website. By providing such sensitive data to Us, You are giving Us a freely given, specific, informed, and unambiguous indication of Your wishes by which You signify agreement to the processing of such Personal Data («Consent»).
    • 9.6. We process such sensitive data to provide You with a greater and better experience with the Website and customize the content and advertising on Our Website for different Users groups. Please note that such sensitive data will not be available to other Users of the Website, and We will not share such sensitive data with third parties unless We received Your Consent to it.
    • 10.1. The Service contains hyperlinks to third-party websites. We are not responsible for the content of such websites, or for how those websites collect, hold, use, and distribute any personal information You provide, or for their Cookies policy.
    • 10.2. When visiting third-party websites from hyperlinks displayed in this Service, We encourage You to review the privacy policies of those websites so that You can understand how the personal information You provide will be collected, held, used, and distributed.
    • 11.1. We use a browser feature known as “Cookies”, which assigns a unique identification to Your device. Cookies are small data files that are stored on Your device when You visit a website, which enables Us to collect information about Your device identifiers, IP address, web browsers used to visit the website, pages or features viewed, time spent on the website, and links clicked. If You do disable the use of Cookies, You may not be able to use or experience some of the features of Our Website.
    • 11.2. Cookies are used for the purposes specified in this Privacy Policy — to provide a greater and better experience with Us and for other related purposes. Information collected from Cookies is used by Us to evaluate the effectiveness of our Website, analyze trends, and administer the Website. The information collected from Cookies allows Us to determine which parts of Our Website are most visited and the difficulties Our Users may experience in accessing Our Website. With this knowledge, We can improve the quality of Your experience on the Website by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties.
    • 11.3. We also may use technologies known as web bugs or clear gifs, which are typically stored in emails to help Us confirm Your receipt of, and response to, Our emails and to provide You with a more personalized experience when using Our Website.
    • 11.4. Types of Cookies we use:
      • 11.4.1. We use Strictly Necessary Cookies required to navigate Our Website and to operate the basic functions of the Website. Examples of Strictly Necessary Cookies are Cookies to remember Your Cookies preferences or to access secure areas of the Website. Without these Cookies, certain basic functions cannot be offered. Strictly Necessary Cookies are always active and will be placed without Your consent. These Cookies cannot be disabled.
      • 11.4.2. We use Functionality Cookies which help Us to enhance Our Website’s performance and functionality, and personalize Your experience on Our Website. This type of Cookies allows Us to recognize You when you return to Our Website, and to remember your choices (such as the region you are located in).
      • 11.4.3. We use Analytics Cookies which allow Us understand how You use Our Website. These Cookies help Us to improve Our Website, for example by ensuring that all users are able to find what they are looking for easily. They identify, for example, the pages visited, the duration and number of visits to the Website, the websites You have visited before, the websites You have visited most often, and the errors You have encountered during visits. The information collected is aggregated and anonymous. It does not allow identification of a person. It only serves the purpose of evaluating and improving the usability of Our Website.
      • 11.4.4. We use Targeting Cookies (also called Advertising Cookies or Marketing Cookies) in order to enable Us to make Our Website more relevant to the User’s interests and to help Us serve ads that might be of interest to the User. These cookies record visits of a User on Our Website, the pages a User visits, and the links a User follows. Based on these interests, we develop a segmented profile and then customize the content and advertising on Our Website for different Users groups.
    • 11.5. Cookies may expire at the end of the browser session (from the moment You open the browser window until the moment You leave the browser), however, Cookies may be stored longer:
      • 11.5.1. Session Cookies allow Our Website to synchronize the actions of the User during the browser session. They are used for various purposes, such as recording the information viewed on the Website. Session Cookies expire after the browser session, so they will not be stored after it is closed.
      • 11.5.2. Persistent Cookies are stored on Your device between browser sessions, which allows to remember Your preferences or actions on websites. Persistent Cookies are used for various purposes, including remembering the preferences and actions of Users while using Our Website or personalizing advertising. All Persistent Cookies have a validity period, after which they are automatically deleted from the User’s device. We store anonymous and aggregated data for an indefinite period of time for analysis purposes.
    • 11.6. We use Cookies set by Our Website (displayed in the URL window) (First-Party Cookies) and Cookies set by a third-party domain (not by our Site) (Third-Party Cookies).
      • 11.6.1. We use third-party service providers, to assist Us in better understanding the use of Our Website. Our service providers will place Cookies on the hard drive of Your device and will receive information that We select that will educate Us on how Users navigate around Our Website, what products are browsed, and other related information – to better understand Our Users’ interests in Our Website and how to better serve those interests. Our service providers analyze this information and provide Us with aggregate reports. The information collected by Our service providers may be linked to and combined with information that We collect about You while You are using the Website. Our service providers are contractually restricted from using information they receive from Our Website other than to assist Us.
      • 11.6.2. Such third-party services place their Cookies:
        • Google Analytics. Types of Cookies used: security, processes, session state, functionality, and analytics. Google uses the data collected to track and analyze the use of our Website, prepare reports on its operation, and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the advertising of its advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: USA — Privacy PolicyOpt Out.
      • 11.7. We provide You with the option to allow (deny) certain types of Cookies by choosing the preferred (undesired) ones in the Website’s Cookies Settings, or decline all Cookies, except strictly necessary Cookies, by choosing “Reject All” in the Website’s Cookies Settings. Please note if You choose to opt out of the use of Cookies, You may still receive an opt-out Cookie so that Your decision is saved. If You regularly delete Your Cookies in Your browser, the opt-out Cookie may be deleted as well. You will have to decide again whether to opt out of the use of Cookies or to accept them for use on our Website.
      • 11.8. With respect to most device systems, You may set Your browser so that it does not accept Cookies. You may control the Cookies through the browser settings. Find out how to manage Cookies on browsers:
      • 11.9 Taking into account the objective difficulty associated with the identification of technologies based on Cookies, We advise You to contact Us if You wish to receive additional information about Our use of Cookies.


    • 13.1 We store Your Personal Data for as long as needed to provide You with Our Service, or as long as You use Our Website, or continue communicating with Our support team. We may store Personal Data longer, but only in a way that it cannot be tracked back to You. When Personal Data is no longer needed, We delete it using reasonable measures to protect the Personal Data from unauthorized access or use.
      • 13.1.1. EU Territory. We store Personal Data as long as it is needed for the provision of Our Service. Traffic information is erased or made anonymous when it is no longer needed for the transmission. Direct marketing and provision of value-added service information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities, or up to the time when a User opts out from such use under this Privacy Policy. Other information is stored for as long as We consider it to be necessary for the provision of Our Service. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary for Us to provide the Service You requested.
      • 13.1.2. As explained in the GDPR statement, We strive to anonymize the data when possible. If You decide to exercise Your right to erasure, We will also inform Our providers to delete all Your data.
      • 13.1.3. US Territory. We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.
    • 13.2. Storing might differ depending on the territory of collecting the information and the applicable legislation, but We always strive to store the information only as long as it is needed to provide, improve, or personalize Our Service.
    • 13.3. When deciding what the correct time is to keep the data, We look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, processing purposes, if these can be achieved by other means, and legal requirements.
    • 13.4. In some circumstances, We may anonymize and aggregate Personal Data for research or statistical purposes, in which case We may use, disclose, and transfer this information, as well as any information that does not identify an individual, indefinitely without further notice to Our Users.
    • 14.1. We understand the importance of protecting children’s privacy, especially in an online environment. The Service is not designed for or directed at persons under 18 (eighteen) years of age.
    • 14.2. Please note that according to each country’s applicable laws, the processing of the Personal Data of a child will be lawful where the child is at another age.
    • 14.3. We do not knowingly collect Personal Data from persons under such age. If a parent or guardian becomes aware that their child has provided Us with Personal Data, they should contact Us at to have it deleted.
    • 14.4. We also encourage parents to monitor their children’s Internet activities, and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.
    • 14.5. If You believe that We might have any information from or about a child under 18 (eighteen) years of age please contact Us at
    • 14.6. If We become aware that We have unknowingly collected personally identifiable information from a child under 18 (eighteen) years of age through this Website, We will make reasonable efforts to delete such information from Our databases as quickly as possible.
    • 15.1. This Privacy Policy is subject to changes from time to time, at Our sole discretion, effective upon their posting to the Website. Your continued access to or use of the Website shall be considered Your acceptance of the revised Privacy Policy, and its application to all information gathered before and after its effective date. We may notify You about the updates to this Privacy Policy but We assume no obligation for such notification. Therefore, We encourage You to periodically check this Privacy Policy for any updates.
    • 16.1. Notices relating to this Privacy Policy may be sent to You via email to the email address You used for registration or provided to Us otherwise. You expressly authorize Us to contact You via such email in the event We or Our affiliate is required by law to notify You of a data security incident or data breach.
    • 16.2. Please submit any notices, feedback, comments, requests for technical support, and other communications to Us relating to this Privacy Policy via email to