Privacy Policy
1. Purpose
This Privacy Policy explains how The Naked Truth collects, uses, stores, shares and protects personal data when users, subscribers, creators, partners or other persons use or interact with the Platform.
The Policy is intended to be transparent and understandable while supporting account creation, subscriptions, payments, creator monetization, KYC, safety, support, legal compliance and operation of the Platform.
2. Controller and Contact
The main controller is The Naked Truth SHPK, registered in Albania, NIPT M61713051L, address Rruga Tre Deshmoret, Pallati Jera 3, Yzberisht, Tirana, Albania.
Privacy questions may be sent to info@thenakedtruth.tv or contact@thenakedtruth.tv.
3. Applicable Privacy Framework
Processing is primarily based on Albanian personal data protection legislation, including Law No. 124/2024 “On the Protection of Personal Data”. Where applicable, The Naked Truth may also apply GDPR, UK GDPR, CCPA/CPRA, COPPA and other privacy, consumer, payment or digital services rules to the extent they apply to the Platform, users, subscribers, creators, transactions or territories involved.
4. Categories of Personal Data
- Account data: email, username, password or login method, language, account settings and authentication logs.
- Subscriber data: subscription plan, paid Profile, billing status, renewal/cancellation status, transaction IDs and support history.
- Payment data: limited payment information, processor references, amount, currency, billing country, payment status, refund/chargeback data. The Naked Truth does not store full card numbers.
- Creator data: legal name, public name, Profile name, date of birth, country, address, email, phone, identity document, business documents, NIPT/VAT/Tax ID, tax residency, invoices, IBAN/Paysera/payment data, KYC status and payout history.
- Usage and technical data: IP address, device/browser information, cookies, session data, logs, access times, viewed content, security events and fraud-prevention signals.
- Communications: messages, requests, notices, complaints, copyright reports, support tickets and documents submitted to the Platform.
5. Purposes and Legal Bases
- To create and administer accounts and Profiles.
- To provide access to free previews, subscriptions, paid content and Platform features.
- To process payments, subscriptions, refunds, chargebacks, invoices, creator payouts and tax/accounting obligations.
- To verify creators, prevent fraud, protect subscribers and secure the Platform.
- To moderate content, enforce Terms, handle copyright notices and respond to legal claims.
- To provide support, send transactional communications and manage user preferences.
- To analyze and improve the Platform using proportionate data, analytics and security logs.
- To comply with applicable laws, court orders, authority requests and processor/banking requirements.
Legal bases may include contract performance, legal obligation, legitimate interests, consent, vital interests where relevant and establishment/exercise/defense of legal claims.
6. Data Minimization and Creator Verification
The Naked Truth follows a data minimization approach. Ordinary subscribers are not required to complete creator KYC. Creator verification is required only where monetization, payout, contractual, tax or risk-related obligations justify it.
Additional documents such as proof of address, tax residency certificates, bank proof, beneficial owner documents or selfie/video verification may be requested only where necessary for legal, payment, tax, fraud, risk or compliance reasons.
7. Sharing of Data
- Payment processors such as Stripe, Paysera, banks and financial providers.
- Hosting, CDN, video delivery, analytics, email, support, security and anti-fraud providers.
- Login providers such as Google or Facebook/Meta where the user chooses them.
- Legal, tax, accounting, audit and compliance advisers.
- Public authorities, courts, regulators or law enforcement where required or permitted by law.
- Creators, rights holders or complainants only where necessary to manage subscriptions, claims, disputes, copyright notices, refunds or Platform operations.
8. International Transfers
Personal data may be processed or accessed from countries outside Albania or the user’s country, depending on hosting, payment providers, support providers, partners and technical infrastructure. The Naked Truth will use appropriate contractual, technical and organizational measures where required by applicable law.
9. Retention
Data is kept only for as long as reasonably necessary for the purposes described in this Policy, including account administration, subscriptions, KYC, payments, taxes, accounting, legal claims, fraud prevention, security, chargebacks and regulatory obligations.
Creator financial/KYC, payout, tax and accounting records may be retained for longer where required by law, payment processors, tax rules, claims, audits or financial risk management.
10. Your Privacy Rights
- Access your personal data.
- Correct inaccurate or incomplete data.
- Request deletion where permitted by law.
- Object to or restrict certain processing.
- Withdraw consent where processing is based on consent.
- Request portability where applicable.
- Complain to a competent data protection authority.
Requests may be subject to identity verification and legal limitations. The Naked Truth may refuse or limit requests where necessary for legal obligations, security, fraud prevention, disputes, tax/accounting duties, chargebacks or defense of legal claims.
11. Security
The Naked Truth applies reasonable technical and organizational measures to protect personal data, including access controls, authentication, secure hosting, payment processor protections, backups, logging and internal restrictions. No digital system can be guaranteed absolutely secure.
12. Cookies and Similar Technologies
Cookies, pixels, local storage, device identifiers and similar technologies are governed by the Cookie Policy. Users can manage non-essential cookies where required by law through the cookie banner, settings panel or browser/device settings.
13. Changes and Contact
This Policy may be updated for legal, technical, operational, security, business or regulatory reasons. Material changes may be communicated through the Platform or other reasonable means where required.
Contact: info@thenakedtruth.tv / contact@thenakedtruth.tv.