Privacy Policy

1. Introduction

This Privacy Policy explains how Glow-tip ("we", "us", or "Operator") collects, uses, stores, and shares your personal data when you visit or use glow-tip.com (the "Website"). It applies to all users of the Website, including buyers and creators.

We are the data controller for personal data collected through the Website. We are established in Lithuania and process personal data in accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and applicable Lithuanian data protection law.

This Website is strictly intended for adults aged 18 and older. We do not knowingly collect personal data from minors.

If you have any questions about this Policy or wish to exercise your rights, please contact us at support@glow-tip.com.

2. What personal data we collect

We collect the following categories of personal data depending on how you use the Website:

All users (buyers and visitors)

• Email address — provided at checkout, registration, or when contacting support.
• Order and transaction details — including product descriptions, purchase amounts, and order history.
• Payment metadata — provided by our third-party payment provider. We do not store full card numbers, CVV codes, or raw payment credentials. Payment processors handle these directly under their own privacy policies.
• IP address and basic device/browser information — collected automatically for fraud prevention and security purposes.
• Communication records — messages sent to us via support email or through the Website.
• Cookie and local storage data — see Section 8 below.

Creators (content uploaders)

• Full legal name and date of birth — collected as part of the identity and age verification process.
• Government-issued photo ID — such as a passport, national identity card, or driver's licence, collected for age and identity verification.
• Consent records — documentation confirming that all individuals depicted in content have provided informed written consent and are aged 18 or over.
• Payout and banking details — required to process earnings disbursements.
• Instagram username — only where relevant to specific membership or creator tier eligibility.

3. Legal bases for processing

We rely on the following legal bases under Article 6 GDPR to process your personal data:

• Performance of a contract (Article 6(1)(b)) — processing your order, delivering purchased content, managing your account, and disbursing creator earnings.
• Legal obligation (Article 6(1)(c)) — retaining transaction records for tax and accounting purposes; retaining creator age verification and consent records as required by applicable law.
• Legitimate interests (Article 6(1)(f)) — fraud detection and prevention, platform security, enforcing our Terms and Conditions, and defending against legal claims. We have assessed that our legitimate interests are not overridden by your rights and freedoms in these contexts.
• Consent (Article 6(1)(a)) — for non-essential cookies and any processing for which we explicitly request your consent. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

Where we process special category data (for example, ID documents that may reveal nationality or other sensitive attributes), we rely on Article 9(2)(g) GDPR (substantial public interest) and applicable national law in the context of age verification obligations.

4. How we use your personal data

• To process payments and deliver purchased digital products.
• To create and manage your account.
• To verify the age and identity of creators before they publish content.
• To retain age verification and consent records in relation to content published on the platform.
• To send order confirmations, download links, and support communications.
• To prevent, detect, and investigate fraud, abuse, chargebacks, and violations of our Terms and Conditions.
• To comply with our legal and tax obligations.
• To defend against legal claims or disputes, including payment disputes and chargebacks.
• To improve and maintain the Website.

5. Payment processing

Payments on the Website are processed by our third-party payment provider. When you make a payment, you provide your payment details directly to the relevant processor. We receive only transaction metadata (such as transaction ID, amount, and status) — we never see or store your full card number, CVV, or bank credentials.

Our payment provider acts as an independent data controller in respect of the payment data it handles. Their privacy policy governs that processing. You should review their privacy policy before making a payment.

Where we suspect fraud or receive a chargeback, we may share relevant order and delivery records with our payment provider, card schemes, or other parties as necessary to investigate and resolve the dispute.

6. Data sharing and recipients

We do not sell your personal data. We share personal data only where necessary with the following categories of recipients:

• Our third-party payment provider — to process transactions and manage disputes.
• Email service providers — to send order confirmations, download links, and support communications.
• Hosting and infrastructure providers — to operate the Website and store data securely.
• Law enforcement or regulatory authorities — where required by law, court order, or to protect against illegal activity (including reporting of CSAM or other illegal content).
• Legal or professional advisers — where necessary to protect our rights or comply with legal obligations.

Some of our service providers are located outside the European Economic Area (EEA), including in the United States. Where personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or we rely on an adequacy decision. You may request further information about these safeguards by contacting us at support@glow-tip.com.

7. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including to comply with our legal obligations. Our retention periods are as follows:

• Transaction and order records — retained for a minimum of 10 years to comply with Lithuanian accounting and tax law.
• Creator age verification and identity documents — retained for a minimum of 7 years from the date of verification or from the last date on which the creator's content was available on the platform, whichever is later.
• Consent records for depicted individuals — retained for the same period as the associated creator verification records.
• Support and communication records — retained for up to 3 years from the date of the communication, unless a longer period is required by an ongoing dispute or legal matter.
• Fraud and security records — retained for up to 5 years from the relevant incident.
• Cookie and analytics data — retained in accordance with the periods set out in Section 8.

Where you request deletion of your account or personal data, we will erase data that we are not legally required to retain. Data subject to mandatory retention periods will be securely stored and restricted from further processing until the retention period expires.

8. Cookies and local storage

We use cookies and local storage to operate the Website. Our use is minimal and does not include third-party advertising or behavioural tracking cookies.

Strictly necessary

These are required for the Website to function (for example, maintaining your session, remembering your language preference and theme, and storing age gate confirmation). These do not require your consent.

Analytics

We use Google Analytics only if you accept analytics cookies in the cookie preferences banner. If you reject analytics, Google Analytics is not loaded, analytics cookies are removed, and our page/click analytics are not collected. You may withdraw consent at any time via the cookie preferences control on the Website.

You can also manage or delete cookies through your browser settings at any time.

9. Your rights under GDPR

As a data subject under GDPR, you have the following rights:

• Right of access — to obtain a copy of the personal data we hold about you.
• Right to rectification — to have inaccurate or incomplete data corrected.
• Right to erasure ("right to be forgotten") — to request deletion of your data, subject to legal retention obligations.
• Right to restriction of processing — to request that we limit how we use your data in certain circumstances.
• Right to data portability — to receive your data in a structured, machine-readable format.
• Right to object — to object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

Buyer account holders can request a portable data export from their account page. For security, the export is sent only to the verified email address on the account and requests are rate-limited. You may also exercise any of these rights by contacting us at support@glow-tip.com. We will respond within one month. We may need to verify your identity before processing your request.

You also have the right to lodge a complaint with the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, VDAI) at www.ada.lt, or with the supervisory authority in your country of residence within the EU.

10. Children

This Website is strictly intended for adults aged 18 and older. We do not knowingly collect, process, or retain personal data from persons under 18. If you believe that a minor has submitted personal data through the Website, please contact us immediately at support@glow-tip.com and we will take prompt steps to delete the information.

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These include access controls, encrypted data transmission (HTTPS), and restricted internal access to sensitive records such as creator verification documents.

No method of transmission over the internet is 100% secure. If you become aware of any security concern relating to your account or our systems, please notify us immediately at support@glow-tip.com.

12. Changes to this Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you by posting the updated Policy on the Website with a revised "Last updated" date and, where appropriate, by sending a notification to your registered email address. We encourage you to review this Policy periodically.

Continued use of the Website after an updated Policy takes effect constitutes acceptance of the revised terms.

13. Contact

For privacy questions, data subject requests, or to report a concern, please contact us at:

Email: support@glow-tip.com

Legal / content reporting: support@glow-tip.com

We aim to respond to all privacy-related enquiries within 30 days.