Privacy Policy
Comprehensive template — bracketed items must be completed and the document reviewed by privacy counsel (GDPR, UK GDPR, CCPA/CPRA, state AV laws, LGPD) before launch. This page is not legal advice.
1. Who We Are
[ENTITY NAME] ("BWBB", "we") operates BigWetBrazilianButts.com. We are the data controller for personal information processed through the Site. Contact: [privacy@bigwetbrazilianbutts.com] · [POSTAL ADDRESS]. [If required: EU/UK representative — NAME & ADDRESS.]
2. The Short Version
We run a no-account website. We do not ask for your name or email. We never see your ID. The data we handle is limited to: (a) technical logs and approximate location needed to operate the Site and comply with age-verification laws; (b) a yes/no age-verification outcome where required; (c) anonymous, aggregated analytics; and (d) local preferences (like your age-gate acknowledgment and watch history) stored only in your own browser.
3. Information We Process
Technical/log data: IP address, user-agent, requested URLs, referrer, and timestamps — processed by our hosting provider to deliver pages, prevent abuse, and derive approximate (country/state-level) location for legal compliance. Age-verification outcome: where law requires verification, an independent provider ([AV VENDOR]) performs the check on its own systems; we receive and store only a pass/fail signal — never your identity documents, face scans, or date of birth, consistent with state laws prohibiting retention of identifying verification data. Local storage: your age-gate acknowledgment and optional watch history live in your browser's localStorage and are never transmitted to us. Communications: if you email us (e.g., a removal request), we process what you send. We do not knowingly collect names, payment data (we sell nothing directly), precise geolocation, or any data from minors.
4. Cookies & Similar Technologies
We use a minimal set of first-party cookies: [bwbb_region] (legal compliance region flag) and any session-integrity cookies set by our host. Embedded third-party players and advertising partners (Section 6) may set their own cookies or use device identifiers under their own policies. Where consent rules apply (EU/UK), non-essential cookies load only after consent via our cookie notice. You can clear or block cookies in your browser; the Site works with cookies disabled except for compliance features.
5. Purposes & Legal Bases
We process data to: operate and secure the Site (legitimate interests / Art. 6(1)(f) GDPR); comply with age-verification and other legal obligations (legal obligation / Art. 6(1)(c)); measure aggregate usage (legitimate interests or consent where required); and respond to your requests (legitimate interests or contract). We do not use automated decision-making producing legal effects.
6. Third Parties We Work With
Processors: hosting/CDN (Vercel Inc.), database (Supabase Inc.), [ANALYTICS PROVIDER — e.g., self-hosted Plausible]. Independent controllers: embedded content platforms (Aylo network embeds, RedGifs), cam and affiliate networks (e.g., Chaturbate), advertising networks ([AD NETWORK]), and the age-verification provider ([AV VENDOR]). When you interact with their players, links, or checks, they process your data under their own privacy policies — review them. We do not sell personal information, and we do not share it for cross-context behavioral advertising as defined by the CPRA; if that ever changes we will provide a "Do Not Sell or Share" mechanism first.
7. International Transfers
Our providers may process data in the United States and other countries. Where GDPR/UK GDPR applies, transfers rely on adequacy decisions or Standard Contractual Clauses implemented by our processors. Details available on request.
8. Retention
Server logs are retained by our host for [30–90] days for security, then deleted or anonymized. Age-verification outcomes are retained only as long as the law requires and never include identifying documents. Emails are kept as long as needed to resolve the matter and for [2] years for legal defense. Browser-stored data persists until you clear it.
9. Your Rights
Depending on your location, you may have rights to access, correct, delete, port, or restrict processing of your personal information, to object to processing, to withdraw consent, and to not be discriminated against for exercising rights (GDPR/UK GDPR; CCPA/CPRA and similar US state laws; LGPD for Brazilian residents). Exercise them via [privacy@bigwetbrazilianbutts.com]. We will verify requests without requiring more data than necessary and respond within the statutory period. You may also lodge a complaint with your supervisory authority (EU/UK) or state attorney general. Authorized agents may submit CCPA requests with proof of authorization.
10. Global Privacy Control & Do Not Track
Because we do not sell or share personal information, GPC and DNT signals do not change our processing; if our practices change, we will honor GPC as required by applicable law.
11. Minors
The Site is strictly for adults 18+. We do not knowingly process minors' data; if we learn a minor accessed the Site, we delete associated data. Parents: use device-level parental controls — the Site broadcasts the RTA (Restricted To Adults) label so filtering software can block it.
12. Security
We use TLS everywhere, minimal data collection by design, least-privilege access to infrastructure, and reputable processors with their own security programs. No system is perfectly secure; we will notify affected users and regulators of breaches as required by law.
13. Changes
We will post updates here with a new effective date, and for material changes provide prominent notice on the Site.
Effective date: [DATE] · Version 1.0