Privacy policy

At Embera, privacy and transparency are fundamental commitments. This Policy describes, in detail, the processing of personal data carried out by the Platform and the rights available to data subjects.

This Policy complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation — “GDPR”) and with Law No. 58/2019 of 8 August, which implements the GDPR in Portuguese law.

Basic information on data protection

• Controller: [YOUR FULL NAME]
• Purpose: administrative, accounting, and tax management of the Platform; verification of identity and age of advertisers; publication of listings; communication with applicants and advertisers.
• Legal basis: consent, performance of contract, legal obligation, legitimate interest.
• Recipients: no data is shared with third parties, except service providers strictly necessary to operate the Platform and competent authorities when legally required.
• Rights: access, rectification, erasure, objection, portability, and restriction of processing.

Detailed information

1. Who is the controller of your data?

• Name: [YOUR FULL NAME]
• NIF: [YOUR NIF]
• Address: [YOUR ADDRESS]
• Contact: [EMAIL]

Given the scale and nature of the processing carried out, the Operator is not required to appoint a Data Protection Officer (DPO) under Article 37 GDPR. For any questions regarding the processing of your data, please contact us directly at [EMAIL].

2. What data do we collect?

We collect only the minimum personal data necessary for the Platform to function:

a) From visitors:

Visitors do not need to create an account. We only collect:

• IP address and basic browser information, for security and abuse prevention;
• Cookies strictly necessary for Website functionality (see Section 7);
• Information voluntarily submitted through contact forms.

b) From listing applicants:

Through the application form, we collect:

• Name or stage name;
• Age and date of birth;
• City;
• Contact details (phone, WhatsApp, email);
• Short description or biography;
• Photographs submitted for verification and possible publication;
• Identification document, provided exclusively for verification of age and identity.

c) From published advertisers:

In addition to the above, we retain the contact details necessary for ongoing management of the listing and the advertising relationship.

3. For what purposes do we process your data?

Personal data collected is processed exclusively for:

1. Verification of adulthood (18+) and identity of applicants;
2. Publication of approved listings;
3. Communication with applicants and advertisers regarding their listings;
4. Responding to contact requests, reports, and removal requests;
5. Maintaining Website security and preventing abuse;
6. Compliance with legal obligations (tax, accounting, cooperation with authorities).

We do not use personal data for third-party marketing, nor do we sell, rent, or share it for such purposes.

4. What is the legal basis for processing?

Processing of your personal data is based on:

1. Consent (Art. 6(1)(a) GDPR) — for publication of listings and for non-essential cookies;
2. Performance of contract (Art. 6(1)(b) GDPR) — for management of the relationship with advertisers;
3. Legal obligation (Art. 6(1)(c) GDPR) — for age verification and compliance with tax and regulatory obligations;
4. Legitimate interest (Art. 6(1)(f) GDPR) — for Platform security, abuse prevention, and defence in legal proceedings.

Where the processing involves special categories of data (data concerning sexual life or sexual orientation), processing is based on the data subject's explicit consent under Article 9(2)(a) GDPR.

5. How long do we keep your data?

Personal data is retained only for as long as necessary for the purposes for which it was collected:

1. Identification documents submitted for verification: once verification is complete, the documents are securely deleted, unless a legal obligation requires longer retention;
2. Published content (photographs, biography, contacts): during the period the listing is active and for up to 30 days after its removal;
3. Billing and commercial records: for the period legally required by Portuguese tax and commercial law (10 years);
4. Website access logs: up to 90 days, for security purposes;
5. Data of applicants not approved: up to 30 days after the decision.

6. To whom is your data disclosed?

We do not share personal data with third parties, except:

1. With service providers strictly necessary for the operation of the Platform (web hosting, CDN), under GDPR-compliant subcontracting agreements, who process data only according to our instructions;
2. When required by law, court order, or legitimate request from Portuguese or European Union authorities;
3. To protect the rights, safety, or property of Embera or others, including reporting suspected criminal activity to competent authorities.

We do not transfer personal data outside the European Economic Area (EEA), except under appropriate safeguards as required by the GDPR.

7. Cookies

The Website uses only cookies strictly necessary for its operation (session management, age confirmation, security). We do not use advertising cookies, tracking pixels, or third-party analytics services that identify individual visitors.

8. Your rights

Under the GDPR and Law No. 58/2019, you have the following rights:

1. Right of access (Art. 15 GDPR) — to obtain confirmation of whether your data is being processed and, if so, to access that data;
2. Right to rectification (Art. 16 GDPR) — to request correction of inaccurate or incomplete data;
3. Right to erasure, “right to be forgotten” (Art. 17 GDPR) — to request deletion of your data, subject to legal retention obligations;
4. Right to restrict processing (Art. 18 GDPR);
5. Right to data portability (Art. 20 GDPR) — to receive your data in a structured, commonly used, and machine-readable format;
6. Right to object (Art. 21 GDPR);
7. Right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
8. Right to lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD): www.cnpd.pt

To exercise any of these rights, contact us at [EMAIL]. We will respond within a maximum of 30 days. In particularly complex cases, this period may be extended by up to 2 further months, and the data subject will be informed of this within the first 30 days.

9. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. Data is stored on secure servers located within the European Economic Area. Access to data is restricted to strictly authorised personnel.

10. Minors

The Platform is exclusively for persons aged 18 and over. We do not knowingly collect data from minors. Any listing or application found to involve a minor will be immediately removed and, where applicable, reported to Portuguese authorities.

11. Source of data

All personal data processed is obtained directly from the data subject, through the application form or other contact channels provided on the Website.

Categories of data processed include:

• Identification data;
• Postal and electronic addresses;
• Professional data (insofar as published in the listing).

Due to the nature of the Website, special categories of personal data may be processed (data concerning sexual life or sexual orientation of the data subject, as defined in Article 9 GDPR), always with the data subject's express consent under Article 9(2)(a) GDPR.

12. Changes

This Policy may be updated periodically. The current version will always be available at [URL].

13. Contact

For any privacy-related questions or to exercise your rights:

Email: [EMAIL]

Supervisory authority:
Comissão Nacional de Proteção de Dados (CNPD)
Av. D. Carlos I, 134, 1st floor
1200-651 Lisbon
Tel: +351 213 928 400
www.cnpd.pt