Effective Date: 11 November 2025
Controller: Drunken Yeti Ltd., Nicosia, Cyprus
Contact: privacy@myvipfantasy.com | legal@myvipfantasy.com

1. Purpose and Scope

This Privacy Notice explains how Drunken Yeti Ltd. (“we,” “us,” “our”) collects, uses, and protects personal data of users of MyVIPFantasy.com, including creators, fans, and visitors, in accordance with the EU General Data Protection Regulation (GDPR) and the Cyprus Data Protection Law.

By using the Platform, you acknowledge that your personal data will be processed as described below.

2. Categories of Data We Collect

• Account information (name, email address, username, password hash).
• Identity and age-verification data (ID document, selfie image, verification metadata).
• Payment and payout details (through our third-party processors).
• Device and usage data (IP address, browser type, logs, cookies).
• Audio, video, or chat records from AI or human calls (used for moderation and service continuity).
• Support communications and reports of abuse.

3. Legal Bases for Processing

Processing occurs on the following legal grounds under Article 6 GDPR:

• Performance of a contract (Art. 6 (1)(b)).
• Compliance with legal obligations (Art. 6 (1)(c)) such as AML/KYC and tax.
• Legitimate interests (Art. 6 (1)(f)) for fraud prevention, security, and analytics.
• Consent (Art. 6 (1)(a) and Art. 9 (2)(a)) for biometric and marketing data.

4. How We Use Your Data

• Operate and maintain the Platform.
• Verify identity and age.
• Process transactions and payouts.
• Detect and prevent fraud or illegal activity.
• Provide customer support and respond to requests.
• Moderate content and enforce policies.
• Comply with legal and tax requirements.

5. Data Retention

Personal data is kept only as long as necessary for its purpose:

• Account records: 5 years after account closure.
• Verification metadata: 5 years after account closure.
• Financial and transaction records: 10 years under Cyprus tax law.
• Chat/audio logs: up to 12 months for moderation and quality control.

After those periods, data is deleted or anonymized.

6. Sharing and Processors

We share data only as necessary with:

• Payment processors for transactions and payouts.
• Verification providers (e.g., Veriff OÜ).
• Hosting and security providers.
• Law-enforcement agencies when required by law.

Each processor acts under a written Data Processing Agreement and is bound by confidentiality and security obligations.

7. International Transfers

Where data is transferred outside the EEA (e.g., to U.S.-based processors), we use Standard Contractual Clauses (SCCs) or rely on EU Adequacy Decisions to ensure adequate protection.

8. Your Rights under GDPR

You have the right to:

• Access your personal data.
• Rectify inaccurate information.
• Request erasure (“right to be forgotten”).
• Restrict or object to processing.
• Receive a portable copy of your data.
• Withdraw consent at any time without affecting prior lawful processing.

Requests should be sent to privacy@myvipfantasy.com.
If unsatisfied, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus).

9. Cookies and Tracking

We use essential and analytics cookies to operate and improve the Platform. See our Cookie Policy for details on consent and management.

10. Security

We implement technical and organizational measures including TLS encryption, access controls, and periodic security audits. While no system is 100% secure, we take reasonable steps to protect personal data.

11. Contact

Drunken Yeti Ltd. | Nicosia, Cyprus
privacy@myvipfantasy.com | legal@myvipfantasy.com