Privacy Policy for Cherrywine.org

Last Updated: August 30, 2025

Cherrywine Digital Inc. (“we,” “us,” or “our”) operates the website cherrywine.org (the “Site”) and related services (collectively, the “Services”). We are committed to protecting your privacy and handling your personal information in a transparent and secure manner. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Site or use our Services, including any content, features, or subscriptions related to adult-oriented digital media.

We are a Canadian company incorporated under federal law (Corporation Number: 1725542-0) and registered in British Columbia (Registration Number: A0138456), with our head office at 2628 Duke St, Unit 102, Vancouver, BC V5R 4S9, Canada. As such, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA) and UK, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) for California residents, and applicable data protection laws in Colombia (Ley 1581 de 2012 and Decreto 1377 de 2013) for users there. If you are a resident of another jurisdiction, additional rights may apply under local laws.

By accessing or using our Services, you agree to this Privacy Policy. If you do not agree, please do not use our Services. Our Services are intended for individuals who are at least 18 years old (or the age of majority in your jurisdiction). We do not knowingly collect information from minors, and access is prohibited for those under 18.

#### 1. Information We Collect
We collect personal information that you provide directly, information automatically collected through your use of the Services, and information from third parties. “Personal Information” means any data that identifies or can be used to identify you, alone or in combination with other data.

a. Information You Provide Directly:
– Account and Registration Data: When you create an account, subscribe, or interact with features (e.g., forums, comments, or content uploads), we may collect your username, email address, password, date of birth (for age verification), gender, preferences, and payment details (processed via third-party providers like CCBill).
– User-Generated Content: Photos, videos, messages, or other content you upload or post, which may include sensitive personal information related to sexual orientation or preferences if voluntarily shared.
– Communications and Support: Information you provide when contacting us via email (info@cherrywine.org), forms, or support tickets, including your name, contact details, and inquiry content.
– Age and Identity Verification: Government-issued ID, selfies, or biometric data (e.g., face scans) processed by third-party verification services to confirm you are 18+ and comply with laws like 18 U.S.C. § 2257 (US age verification for adult content).
– Payment Information: Billing details, such as credit card numbers or bank information, handled securely by payment processors (we do not store full payment details).

b. Information Collected Automatically:
– Device and Usage Data: IP address, browser type, operating system, device identifiers, pages viewed, time spent, search queries, and referral sources.
– Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to track user activity, personalize content, and serve ads. See the “Cookies and Tracking Technologies” section below for details.
– Location Data: Approximate location based on IP address (we do not collect precise geolocation without consent).

c. Information from Third Parties:
– From payment processors (e.g., CCBill) or social media platforms if you log in via third-party accounts (e.g., profile information).
– From analytics providers (e.g., Google Analytics) for aggregated usage data.
– From age verification partners for compliance checks.
We do not collect special categories of sensitive data (e.g., biometric, health, or sexual orientation data) without your explicit consent, except as necessary for age verification or where you voluntarily provide it in content.

#### 2. How We Use Your Information
We use your personal information for the following purposes, based on legal grounds such as your consent, contractual necessity, legitimate interests (e.g., site security and marketing), or legal obligations:

– To Provide and Improve Services: Create and manage accounts, process subscriptions and payments, deliver content, and enable features like personalized recommendations.
– Age and Compliance Verification: Ensure users are 18+ and comply with adult content laws (e.g., PIPEDA accountability principle, GDPR Art. 6(1)(a) consent for sensitive data).
– Marketing and Communications: Send newsletters, promotions, or updates about our brands (lacelestina.co, colombiaeroticvacations.com) with your consent. You can opt out anytime.
– Analytics and Personalization: Analyze usage to improve the Site, customize content, and measure ad effectiveness.
– Security and Fraud Prevention: Detect and prevent abuse, fraud, or illegal activities, including monitoring for prohibited content.
– Legal Compliance: Respond to legal requests, enforce terms, and fulfill obligations under laws like CCPA (for California residents’ rights) or Colombian data protection decrees.
– Business Operations: For internal purposes like auditing, data analysis, and research to expand our services.

We process sensitive data (e.g., related to adult content preferences) only with explicit consent and for the purposes you agreed to.

#### 3. Sharing Your Information
We do not sell your personal information. We may share it in limited circumstances:

– Service Providers: With third-party vendors (e.g., payment processors like CCBill, hosting services, analytics tools) who assist in operations, bound by confidentiality and data protection agreements.
– Affiliates and Brands: Within our related companies (e.g., for cross-marketing with lacelestina.co or colombiaeroticvacations.com), subject to this Policy.
– Legal and Safety Reasons: To comply with laws, respond to subpoenas, protect rights, or prevent harm (e.g., sharing hash values of illegal content with authorities).
– Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred.
– With Your Consent: For other purposes where you explicitly agree, such as sharing content publicly on the Site.

For GDPR/CCPA compliance, we ensure third parties process data lawfully. California residents: We disclose categories of personal information to service providers for business purposes (e.g., identifiers to analytics providers).

#### 4. Data Security
We implement reasonable technical, administrative, and physical measures to protect your information, including encryption (e.g., SSL for transmissions), access controls, and regular security audits. However, no system is 100% secure, so we cannot guarantee absolute protection. Report any suspected breaches to info@cherrywine.org.

#### 5. Data Retention
We retain personal information only as long as necessary for the purposes outlined (e.g., account data while active, plus 7 years for tax compliance under CRA rules). We anonymize or delete data when no longer needed, unless required by law (e.g., PIPEDA retention for accountability).

#### 6. Your Rights
Depending on your location, you have rights over your data:

– Access, Correction, Deletion: Request to view, update, or delete your information.
– Opt-Out of Sharing/Sale: For CCPA/CPRA, opt out of “sales” or sharing for targeted ads.
– Withdrawal of Consent: Under GDPR/PIPEDA, withdraw consent anytime (e.g., for marketing), without affecting prior processing.
– Portability: Receive your data in a portable format.
– Non-Discrimination: We won’t discriminate for exercising rights.
To exercise rights, email info@cherrywine.org with verification (e.g., account details). We respond within 30-45 days (PIPEDA/GDPR timelines). For Colombian users, rights under Ley 1581 include habeas data petitions.

#### 7. Cookies and Tracking Technologies
We use cookies for essential functions (e.g., session management), performance (analytics), and targeting (ads). You can manage preferences via browser settings or our cookie banner. For details, see our Cookie Policy (link if separate). Under CCPA, this may constitute “sharing” personal information.

#### 8. International Data Transfers
As a Canadian company, data is primarily stored in Canada or secure servers in the US/EU. For GDPR users, we use Standard Contractual Clauses or adequacy decisions for transfers. We comply with the EU-US Data Privacy Framework where applicable.

#### 9. Children’s Privacy
Our Services are for adults 18+. We do not knowingly collect data from children under 18. If we discover such data, we delete it immediately. Parents: Contact us at info@cherrywine.org for removal.

#### 10. Changes to This Privacy Policy
We may update this Policy periodically. Changes are effective upon posting, with the “Last Updated” date revised. Significant changes will be notified via email or Site notice. Continued use constitutes acceptance.

#### 11. Contact Us
For questions or requests, contact:
– Cherrywine Digital Inc.
– 6545 rupert street, Vancouver, BC V5s 2z2, Canada
– Email: info@cherrywine.org
– Phone: +1 (778) 952-7492

For GDPR data protection officer or CCPA inquiries, use the same email. We appoint representatives in the EU/UK as required.

This Policy is governed by British Columbia and Canadian laws. As your full-stack developer and legal advisor, implement this as a dedicated page (e.g., /privacy) with a footer link. Customize further if needed for specific features.