Privacy Policy

Last update: 17 April, 2019.

Considerations

abbywinters.com is an adult website where customers pay to access erotic material online. We take our customers privacy seriously, and work hard to collect minimal data about our customers in the first place, to keep the data we do collect secure, to never share it with others, and to permanently erase it when we no longer need it.

We use Google Analytics to track how Guests and Customers use our website. More details on how and why are below. Google Analytics maintains a page with more information on the specific cookies used, and the reason for each. We offer the ability to opt-out of Google Analytics tracking.

Some data about you is gathered and tracked by cookies. We have a FAQ page on what cookies we set and why we set them.

Definitions

Biller” Billing for access to abbywinters.com is managed by third parties we call “Billers”, who have their own Privacy Policies that we consider reasonable. To get a full picture of how your personal information is used when you buy access on abbywinters.com, review the Privacy Policy of our primary biller GMBill.com, and / or our secondary biller CCBill.com.

🐶 TIP: Check your credit card statement for who you are being billed through (around 99.5% of our customers use GMBill.com).

Note that this, the abbywinters.com Privacy Policy, only covers information we ourselves collect, store and use about you. Note that we have a separate Privacy Policy for models.

Customer”, “Customers” We consider anyone who pays for access to our site, or is granted a free account for our site (for example, review sites, business partners, models, staff, contractors) to be a Customer. They have access to the paid-only areas of abbywinters.com. We gather and process more data about Customers than we do about Guests.

Guests” We consider anyone who visits our site but does not pay for access to be a Guest. We gather limited data about Guests.

Our Data Security Standards”. We have a page on how we securely store data – data about you, and our own data.

Our Company”. This includes our staff, Owners, and Contractors and the business entity abbywinters.com BV.

Our Sites” or “Sites”. While our main site is www.abbywinters.com, we have many related sub-domain sites – for example, support.abbywinters.com. We also have some sites we use for related business purposes such as recruiting models, for example, www.femalephotofun.com. When we say “Our Sites”, we include all the sites we directly operate and are responsible for.

PPS” or “Pay Per Scene” refers to the system we use for customers to buy credit and spend that credit on individual scenes on our site (this is as opposed to a subscription, where access is granted to many or all scenes for a time-limited period). Once made, a PPS purchase is for the lifetime of the site, and are not time limited. This includes the PPS-Wallet and PPS-Direct systems.

Staff”. This term includes salaried employees, regular and temporary contractors, and business owners.

Topping Up” and “Top Up” refers to adding money to a Pay Per Scene Wallet account from your credit card, via our GMBill.com Biller. This term also includes making PPS-Direct purchases (that is, individual scene purchases).

User Agent”. This is a set of information your web browser passes to us when you browse our website or submit a form. It includes your precise web browsing software program (name and version number, for example, Chrome 76), and your precise Operating System name and number (for example, Windows 10). More info.

Personal information we collect about you

Common to Guests and Customers

Our web servers track the IP (that is, your device’s address on the internet), date/time, web address (URL), and the User Agent for every page request we serve (that means, every page you visit on our Sites, and every media file you download from us).

ABOVE: Example of one line from our web server log file.

If you agree to allow third-party cookies (we ask you the first time you visit the site), we’ll instruct Google Analytics to set cookies. Google Analytics cookies track what pages you visit on our site, track what you do on the page, and track how long you are on that page. Information about your computer setup (browser, Operating System, display size, and similar) is also recorded.

If you subscribe to our newsletter, we collect your email address.

If you send us a customer support request or enquiry, we gather the information you provide, for example, your email address and message, and your subsequent replies and any attachments to us. If you use a form on our site, we also gather User Agent information.

We set several cookies with your preferences for various media handling options on abbywinters.com. See our page on the cookies we set, and why we set them.

Guests

If you agree to allow third-party cookies, but later change your mind, you can reset this preference by deleting the cookie_accept cookie for abbywinters.com.

Customers

When you pay for access to our site, you tell the Biller some personal information (how they manage that is outside the scope of this document, see above in the definition of “Biller” for more information on this). Some of that information (email address, encrypted username, encrypted password) is passed to us.

When you attempt to log in, if that login attempt fails (for example, incorrect username or password or CAPTCHA) we log the incorrect attempt details in plain text.

If you submit a contact form on our site, your abbywinters.com site username, SubID, join date/time, access groups, PPS balance, User Agent, IP and recently visited pages are sent along with your message.

ABOVE: An example of the information we receive when you submit a support request. Some info in this example has been redacted for privacy.

When you first accesses the paid area of our site, we set up an account on our self-hosted web forum software (vBulletin). You may choose to update your profile on that software with your personal location information, though we recommend you do not for privacy reasons. You may choose to make posts on our web forum. If you do so, they will be available to our customers, staff, models and the general public (images you post are only accessible to registered users, being customers, staff and models).

If you participate in Playdates, messages you send to the model in a Public chat room are visible to all customers in that room at that time. Messages in a Private chat room are only visible by the model in that chat room. Messages sent in Public or Private rooms are logged by our servers. The video stream of the model is recorded on our servers and stored indefinitely, so words the model may address to you in her video stream are also recorded.

Transactions to purchase time to engage with models on a one-to-one basis in our Playdates system (“Private Playdates”) are recorded with the amount, date, time and model name.

If you provide feedback about a Private Playdate interaction at the conclusion of the Private Playdate (in the form of a star-rating, and a comment), we receive and store that.

Pay Per Scene purchases you make are stored in your Digital Locker, a page customised to you showing only the scenes you purchased.

If we email you a message reminding you about your un-spent PPS credit, we track if you click on a link in that email, and if you make a purchase soon after.

When you Top Up a PPS account, you may be asked security questions to verify you are who you say you are. These questions come from GMBill.com, and answers you provide are passed securely back to GMBill.com. If you provide an incorrect answer, we store the fact your answer to that question was incorrect.

You can disable third-party cookies if you choose; be logged in to abbywinters.com. In the user Control panel top right, select My Account, Preferences, General tab, Disallow third-party cookies.

How your personal information is stored

Guests & Customers

All personal information we collect about you is stored per Our Data Security Standards.

How your personal information is used

Common to Guests and Customers

For the Newsletter, we need your email address to send you our newsletter each month. We track the clicks you make so we can calculate how effective the newsletter is in encouraging people to join. This data is anonymised (that is, we don’t know if you specifically joined because of the newsletter, we just know that someone who subscribes to the newsletter joined).

If you send a message via customer support, we’ll use the information you provide to understand the issue you have reported, to fix it, and to respond to you professionally and promptly. We may use the information to improve our services (for example, fixing bugs).

We ask Google Analytics to set cookies to help us understand how people use our website, and to consider how we can improve the service we offer to Guests and Customers in aggregate. For example, if we find that more people are browsing our site using a mobile device, we may improve our support for mobile devices to provide a more enjoyable experience.

The data collected by our web server is used for testing our services are working well, and for tracing issues we or our users identify.

Customers

Information passed to us from the Biller is used to manage your access to our site, and to send you notifications about our site. For example, if you request to reset your password, we will send you an email with information on how to do that.

Failed login attempts are used to support you when logging in, and to suspend user accounts that appear to be abused (for example, cracking dictionary attacks). Some data is displayed to you on your “May Account” page, including the date and time and IP address, to help you identify any suspicious behaviour with your account (for example, someone else logging in as you).

We use cookies to make the site work better for you. For example, the specific video file download quality you prefer is a setting you can make, so the site is more convenient to use (more information on the cookies we set, and why).

If you provide positive feedback (by email, on a web form, or on our forums), we may choose to post it on Our Sites or on our DVD’s with a view to encouraging other people to become our customer (for example, on our Testimonials page). Your real name will never be used, and we’ll redact any personal identifying information. At your request when you submit feedback to us, we will not use your feedback for promotional purposes.

We may use your email address to send you information about your account (for example, someone with PPS unspent money in their account may get a reminder of the balance and suggestions on what to spend it on). We use the information about what you clicked and what you bought to improve how we communicate with our PPS customers.

We may use your email address to send you offers or reminders about our site – this is very rare, once a year at most.

We may use Playdate chat logs (Public and Private) to troubleshoot technical issues, to understand how customers use our products, or to address complaints about customer behaviour. We may use Playdate video recordings of the model to assess the quality of the model’s work and provide feedback to her.

We may use your Private Playdate transaction history to track trends in our Playdate system (usually in aggregate), to investigate possible fraud, and to support your requests for more information or to track an issue you have reported.

We may use your feedback about a Private Playdate to help the model improve her services, to encourage her to continue as she is, and to design training for future models.

For PPS scenes purchased, we use the anonymised and aggregated data of how many people have purchased a given scene to plan our future offerings (for example, if many people purchase a scene of Mary, we may offer more shoots to the model Mary). We may use the list of PPS scenes you have purchased to support you if you ask us questions about your PPS account.

If you experience issues with a PPS Topup, we may check our logs to see the security question you were asked, and your incorrect answer so we can support you in solving this problem.

Who can access your personal information

Common to Guests and Customers

Only Staff who have a clear and present business need to access your personal information are able to, in order to complete their assigned work, or to support you in solving problems and answering questions about the service we provide.

For example, a Customer Support technician might review your Private Playdate transactions to answer your request for how money you have paid for our services has been allocated. A web developer might process several customer support requests to identify a bug in our systems.

Staff can only access your data in secure online environments (that is, never download it for their personal use). Staff sign agreements that have strict confidentiality clauses.

How your personal information is shared

Common to Guests and Customers

Our general “default” policy is to share no data with anyone outside our organisation, except for as described in this document.

We never directly share the information we collect about guests with anyone outside our business, other than the data passed to Google Analytics, which is anonymised.

We may share aggregated and anonymised data about how people use our site (for example, a Biller may ask us what percentage of our sales are from the US).

Requesting access to the personal information we hold about you

Guests

Apart from submitted customer support tickets, we do not have an option for Guests to access the limited personal data we hold about them.

Customers

Most customer information is accessible and editable by you, via our Billers or directly on the abbywinters.com site.

We take all requests for access to information not already visible to you seriously, and work to provide your request. However, we may not be able to provide access to information about you that:

  • Is not stored in a way unique to you (that is, has been anonymised), or
  • Has been erased per our Data Erasure policy (below), or
  • Is stored by means that is no longer identifiable (for example, your IP has changed from what it was on a certain date).

Updating your personal information

Guests

Apart from submitted customer support tickets, we do not offer an option for Guests to update us on the limited personal data we collect about them.

Customers

The nature of the data we hold directly about customers is limited, and can be changed by customer changing their user preferences on the site, or by updating information on the Biller’s site.

We invite customers to notify us as soon as possible if a technical issue they had has been resolved, or if they have more information on a technical issue they are experiencing.

We are not able to edit Playdate chat logs.

Requesting we remove personal information about you

Common to guests and Customers

For the Newsletter, you can click the unsubscribe link at the bottom of any newsletter, make a customer support request, or use the newsletter unsub tool.

Log files cannot have data manually removed, but data is erased after a set time period.

At your request, we can delete customer support tickets you have created with us, but you must email us from the address that the customer support tickets were created under, to request this.

Customers

Information relating to your account on abbywinters.com can be removed on the relevant Biller’s site, under the terms of their Privacy Policy under the Data Erasure subset.

We do not remove transactional information about Private Playdate purchases, as that forms part of the records of how much models have earned with us, and thus our financial narrative.

We cannot remove failed login information individually.

At your request, we can remove all or some posts you have made on our discussion forums, and your forums account.

We are not able to remove individual purchased PPS scene from your Digital Locker, and nor are you.

We are not able to remove items from our logs about incorrect security questions you answered.

Customers who joined via Biller GMBill.com can choose to erase their data from GMBill.com in some circumstances. Doing so will remove username and email address information in the abbywinters.com database at the same time.

Our data erasure policy

Common to Guests and Customers

For the Newsletter, email addresses are never erased by us – only you can request removal, using the “unsubscribe” function that.

The data our web servers collect (“log files”) is kept for the last rolling 30 day period, then is permanently erased.

Customer Support tickets are permanently deleted 12 months after the last message on that ticket was added (by you, or by our workers).

Customers

Failed login information is stored permanently.

Incorrect answers to security questions are stored permanently.

Playdate chat logs and video recordings of the model are stored indefinitely for troubleshooting and quality control purposes.

Usernames and email addresses are never deleted from our site unless you explicitly ask us to. This allows ex-customers to log in and reactivate their account.

Private Playdate transaction data is never erased. However, only the username, subscription ID, period of time and amount of money is present in this information.

The list of scenes purchased and stored in our Digital Locker can be requested to be erased entirely, but if so, you have no further claim to those scenes and they would need to be purchased again.

End.