1. Introduction

hotlair.net (the “Website”, “we”, “us”, or “our”) operates an adult entertainment platform intended exclusively for individuals who are at least 18 years of age (or the age of majority in their jurisdiction). This Privacy Policy explains how we collect, use, disclose, retain, and protect information obtained through your use of the Website.

We are committed to protecting your privacy and handling any personal data in compliance with applicable laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA) as amended by the CPRA, and other relevant data protection legislation.

By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We collect minimal personal data and strive to operate with privacy-by-design principles. The types of information we may collect include:

• Automatically Collected Data: When you visit the Website, we (or our third-party service providers) may automatically collect non-personal information such as IP address, browser type, device information, operating system, referring URLs, and usage data (e.g., pages viewed, time spent, clickstream data).
• Account Data (optional) Creating an account is not required to browse the Website. If you choose to register, we collect a username, an email address, and a securely stored (hashed) password.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies as described in our separate Cookie Policy.
• Voluntarily Provided Data: If you contact us (e.g., via email or support forms), we may collect your email address and any other information you choose to provide.

We do not collect sensitive personal information (e.g., health, racial, or ethnic data).

3. How We Use Your Information

We use the collected information for the following purposes:

• To provide, operate, and maintain the Website, including age verification and core functionality;
• To personalize your experience and deliver relevant content recommendations;
• To analyze usage patterns, improve the Website, and develop new features;
• To create and manage optional user accounts;
• To detect, prevent, and address technical issues, fraud, or abuse;
• To communicate with you in response to inquiries or support requests;
• To comply with legal obligations or enforce our policies.

4. Legal Bases for Processing (GDPR)

Where GDPR applies, we process personal data based on:

• Legitimate interests (e.g., site operation, security, analytics);
• Consent (e.g., for non-essential cookies);
• Performance of a contract (e.g., providing an account you have registered for);
• Legal obligations (e.g., responding to lawful requests).

5. Sharing and Disclosure of Information

We do not sell, rent, or trade your personal information. Information may be shared only in the following circumstances:

• With trusted service providers who are contractually obligated to protect your data, including our hosting provider and our content delivery network, Bunny CDN (bunny.net), which delivers static assets and video content, and, where used, analytics tools;
• When required by law, regulation, or legal process (e.g., court orders or subpoenas);
• To protect the rights, property, or safety of the Website, our users, or the public.

6. Hosting and International Data Transfers

The Website is hosted on servers located in the Netherlands. Static assets and video content are delivered through Bunny CDN (bunny.net), a global content delivery network that may cache and serve content from data centers located in various countries around the world.

As a result, information such as your IP address may be transferred to and processed in countries outside the European Economic Area (EEA) or your country of residence. Where required by applicable law, we rely on appropriate safeguards for such transfers, such as Standard Contractual Clauses approved by the European Commission.

7. Data Security

We implement reasonable technical and organizational measures, including HTTPS encryption, secure servers, and firewalls, to protect information from unauthorized access, loss, or misuse. However, no method of transmission over the internet or electronic storage is completely secure.

8. Data Retention

We retain personal data only for as long as necessary for the purposes outlined in this Policy or as required by law. Account data is retained for as long as your account remains active and deleted upon account closure, subject to any legal retention requirements. Automatically collected usage data is typically anonymized or deleted within a reasonable period (e.g., analytics data up to 26 months).

9. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal data:

• Access, rectification, or erasure;
• Restriction of processing or objection;
• Data portability;
• Withdrawal of consent;
• Opt-out of certain processing (e.g., CCPA opt-out for California residents).

To exercise these rights or for any privacy-related inquiries, contact us at support@hotlair.net. We will respond within the timeframes required by applicable law.

10. Third-Party Links and Content

The Website contains embedded content and links to third-party sites (e.g., video platforms). We are not responsible for their privacy practices. We encourage you to review their policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with a revised “Last Updated” date. Your continued use of the Website after changes constitutes acceptance of the updated Policy.

12. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact the operator of HotLair at: support@hotlair.net