Privacy Policy

1. Data Protection at a Glance

Thank you for your interest in our website.
We take the protection of personal data very seriously. Should you have any questions
or concerns regarding data protection, please do not hesitate to contact us directly
at any time.

The following information provides a simple overview of what
happens to your personal data when you visit this website.
Personal data is any data with which you
can be personally identified. Detailed information
on the subject of data protection can be found in our under this
text listed Privacy Policy.

Data processing on this website is carried out by the website operator.
You can find their contact details in the section
“Information on the Responsible Party” in this Privacy Policy.

On the one hand, your data is collected by you providing it to us.
This may include, for example, data you enter into a contact form.

Other data is collected automatically or with your consent when
you visit the website by our IT systems. This primarily includes
technical data (e.g., internet browser, operating system, or
time of page view). This data is collected automatically
as soon as you enter this website.

The processing of personal data always takes place in
accordance with the General Data Protection Regulation (GDPR)
and other relevant data protection regulations.

Some of the data is collected to ensure the error-free provision
of the website. Other data may be used to analyze
your user behavior.

You have the right to receive information free of charge at any time about the origin,
recipient, and purpose of your stored personal data.
You also have the right to request the
correction or deletion of this data. If you have given consent for
data processing, you can revoke this consent at any
time for the future. Furthermore, you have the right, under
certain circumstances, to request the restriction of the processing of your
personal data. You also have the right to lodge a
complaint with the competent supervisory authority.

For this and other questions on the subject of data protection, you can
contact us at any time.

The responsible party for data processing
on this website is:

Zoe Escort
Anna Schmidt
Theresienstr. 1
80333 Munich
Phone: 0173/3209526
Email: office@zoe-escort.de

The responsible party is the natural or legal person who, alone
or jointly with others, decides on the purposes and means of processing
personal data (e.g., names, email addresses, etc.).

Unless a more specific storage period has been mentioned within this Privacy Policy,
your personal data will remain with us until the
purpose for data processing ceases. If you assert a legitimate request for deletion
or revoke consent for data processing,
your data will be deleted, unless we have other legally permissible
reasons for storing your personal data
(e.g., retention periods under tax or commercial law); in
the latter case, deletion will occur after these reasons cease to apply.

Recipients of personal data

In the course of our business activities, we cooperate with various
external parties. In some cases, this also requires the transmission
of personal data to these external parties.
We only pass on personal data to external parties
if this is necessary for the fulfillment of a contract, if we
are legally obliged to do so (e.g., disclosure of data to tax authorities),
if we have a legitimate interest according to Art. 6 para. 1 lit. f GDPR in the
disclosure, or if another legal basis permits
the data transfer. When using processors, we only pass on
personal data of our customers on the basis of a valid
contract for commissioned processing. In the case of joint
processing, a contract for joint processing is concluded.

You have the right to have data that we process automatically on the basis of your consent or in
fulfillment of a contract handed over to you or to a
third party in a common, machine-readable format.
If you request the direct transfer of the data to another controller,
this will only be done if it is technically feasible.

Within the framework of applicable legal provisions, you have the
right at any time to free information about your stored personal
data, its origin and recipient, and the purpose of data processing and
, if applicable, a right to rectification or deletion of this data. For this and
further questions on the subject of personal data, you can
contact us at any time.

You have the right to request the restriction of the processing of your personal
data. For this, you can contact us at any time. The right to
restriction of processing exists in the following cases:

If you dispute the accuracy of your personal
data stored with us, we usually need time to verify this.
For the duration of the review, you have the right to request the restriction of the
processing of your personal data.
If the processing of your personal data was/is unlawful,
you can request the restriction of data processing instead of
deletion.
If we no longer need your personal data, but you
require it for the exercise, defense, or assertion of legal claims,
you have the right to request the restriction of the
processing of your personal data instead of deletion.
If you have lodged an objection pursuant to Art. 21 para. 1 GDPR,
a balancing of your and our interests must be carried out. As long
as it has not yet been determined whose interests prevail, you have
the right to request the restriction of the processing of your personal
data.

If you have restricted the processing of your personal data,
this data – apart from its storage – may only be processed with your consent
or for the assertion, exercise, or defense of legal claims or
for the protection of the rights of another natural or legal person or for
reasons of important public interest of the European Union or a
Member State.

For security reasons and to protect the transmission of confidential
content, such as orders or inquiries that you send to us as the site operator,
this site uses SSL or TLS encryption. You can recognize an encrypted connection
by the address line of the browser changing from “http://” to “https://” and by
the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us
cannot be read by third parties.

Objection to advertising emails

The use of contact data published within the framework of the impressum obligation for
sending unsolicited advertising and information material is hereby
objected to. The operators of the pages expressly reserve the right to take legal
action in the event of unsolicited sending of advertising information, for example by
spam emails.

If you send us inquiries via the contact form, your details from
the inquiry form, including the contact data you provided there, will be stored with us
for the purpose of processing the inquiry and for any follow-up questions. We
will not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, provided
your inquiry is related to the fulfillment of a contract or is necessary for the implementation
of pre-contractual measures. In all other cases, the processing
is based on our legitimate interest in the effective processing of inquiries
addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR)
if this was requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request
its deletion, revoke your consent to storage, or the purpose for
data storage ceases (e.g., after your inquiry has been processed).
Mandatory legal provisions – in particular retention periods – remain
unaffected.

If you contact us by email, telephone, or fax, your inquiry, including
all resulting personal data (name, inquiry), will be stored and processed
by us for the purpose of handling your request. We will not
pass on this data without your consent.

The data you send us via contact inquiries will remain with us until you
request its deletion, revoke your consent to storage, or the purpose
for data storage ceases (e.g., after your request has been processed).
Mandatory legal provisions – in particular statutory retention periods –
remain unaffected.

This website uses the open source web analytics service Matomo for anonymous
evaluation of user behavior. The analysis is carried out without cookies and without
passing on data to third parties.

You can object to the anonymized evaluation at any time:

We offer you the opportunity to apply to us (e.g., by email, post, or
via online application form). In the following, we inform you about the scope, purpose, and
use of your personal data collected during the application
process. We assure you that the collection, processing, and use of your data will be carried out in
accordance with applicable data protection law and all other legal
provisions, and that your data will be treated strictly confidentially.

Scope and Purpose of Data Collection

If you send us an application, we process your associated
personal data (e.g., contact and communication data, application documents,
notes from job interviews, etc.) to the extent necessary for the decision on
establishing an employment relationship. The legal basis for this is
§ 26 BDSG under German law (initiation of an employment relationship),
Art. 6 para. 1 lit. b GDPR (general contract initiation) and – if you have given consent –
Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time. Your
personal data will only be passed on within our company to
persons involved in processing your application.

If the application is successful, the data you submitted will be stored in our data processing systems
on the basis of § 26 BDSG and Art. 6 para. 1 lit. b GDPR for the purpose of carrying out the
employment relationship.

Data Retention Period

If we cannot offer you a job, you reject a job offer,
or withdraw your application, we reserve the right to retain the data you
submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR)
for up to 6 months from the end of the application process (rejection or withdrawal
of the application). Afterwards, the data will be deleted and the
physical application documents destroyed. The retention serves in particular
for evidentiary purposes in the event of a legal dispute. If it is apparent that the data will be
required after the 6-month period (e.g., due to a pending or
threatened legal dispute), deletion will only take place when the purpose for further
retention ceases.

Longer retention may also occur if you have given corresponding
consent (Art. 6 para. 1 lit. a GDPR) or if legal retention
obligations prevent deletion.

In accordance with Art. 32 GDPR, we have taken appropriate technical and
organizational measures to ensure an adequate level of protection.
Furthermore, we have established procedures that ensure the exercise
of our rights, the deletion of data, and the response to a data breach.
The protection of your personal data was already considered during
the development and selection of the hardware and software used.
With this, we comply with the principle of data protection by design and
data protection-friendly default settings according to Art. 25 GDPR.
Security measures include, in particular, the encrypted transmission (SSL
encryption) of data between your browser and our server.

I. Controller
Please refer to the impressum or the section above for information on the controller within the meaning of the General Data Protection
Regulation.

II. Storage of Data/Information when accessing the Website
When accessing the website, general data and information are collected and stored in
the server log files. This includes the following
data/information:

Browser types and versions used by you – the operating system
used by you, – the website from which you access our website –
sub-websites that you click on our website – date and time of access
to our website, – your IP address/your internet service provider – other similar
data and information that serve to avert danger in the event of attacks on our
IT systems.
We need this information to be able to correctly provide the content of the website,
to ensure the permanent functionality of our IT system, and to be able to
provide the authorities with the information necessary for criminal prosecution in the event of a cyberattack.
The legal basis for the processing of this data is our
legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR. When using this general data and information,
we do not draw any conclusions about your person. We store the anonymous data of the server log files
separately from all personal data.

III. Data processing in the context of your booking
If you book one or more escorts, we process all data
that you provide to us in this context. Data processing
is carried out exclusively for the processing and execution of your booking or
the coordination of the appointment with the escort. Your booking data will be
passed on to the booked escort to the extent necessary for this purpose,
insofar as this is required for the fulfillment of the contract. The legal basis
for processing this data is Art. 6 para. 1 lit. b) GDPR. The retention period
for billing-relevant data is 10 years according to tax regulations and 6 years for business letters.
Otherwise, we delete your data at the latest one year
after the last booking.

Consent to the processing of data on sexual life or sexual
orientation

We require your consent for the processing of special categories of personal data, such
as data on sexual life or sexual orientation. By actively and voluntarily
providing us with such data, you give your express
consent to the processing of this data. The data will only be passed on
to the booked escort for the stated purpose.
The data remains stored until you revoke your consent.
Your consent constitutes the legal basis for the processing of this data (Art.
9 para. 2 lit. a) GDPR).

Consent to the processing of your ID data for desired home visits
and/or for age verification

For home visits, proof of your identity and current address
is required. Proof of your legal age may also be necessary if we
have reason to believe that you might be underage. If you send us
a copy of your ID to prove your identity/address/age,
you consent to the processing of the data contained therein by sending the ID copy.
The ID data will only be stored by us
and not passed on to third parties. We will only delete your ID copies when you revoke your
consent, but at the latest one year after your last booking.
Your consent also constitutes the legal basis for the processing of this
data (Art. 6 para. 1 lit. a) GDPR).

IV. Your contact with us

Due to the regulations of the Telemedia Act (TMG), we are obliged to provide a
general email address and a telephone number in the impressum of our website,
through which you can contact us. Furthermore, you have the option
to contact us via contact forms on our website. The personal
data transmitted by you to us via email, telephone, or our contact form
will be automatically stored for the purpose of processing or contacting you.
This personal data will not be passed on to third parties. If no booking
and/or contractual relationship with us comes about, your data will be deleted
after your inquiry has been fully processed.

If the processing of personal data transmitted by you to us via email, telephone, or our contact form
is necessary for the fulfillment of a contract or for the implementation of pre-contractual measures,
the legal basis for processing is Art. 6 I lit. b GDPR.

If the aforementioned conditions are not met, the legal basis for the
processing of personal data transmitted by you to us via email or our contact form
is Art. 6 I lit. f GDPR.

V. Legal basis for processing

If we obtain your consent for a specific processing purpose,
Art. 6 I lit. a GDPR serves as the legal basis for the
processing operation.

If the processing of personal data is necessary for the fulfillment of a contract,
the processing is based on Art. 6 I lit. b GDPR. This also applies to
processing operations that are necessary for the implementation of pre-contractual measures,
such as inquiries about our products or other services.
If we are subject to a legal obligation that requires the processing of
personal data, such as for the fulfillment of tax obligations,
the legal basis for processing is Art. 6 I lit. c GDPR.
If the processing of personal data is necessary to protect
the vital interests of the data subject or another natural
person, the processing would be based on Art. 6 I lit. d GDPR.
Finally, Art. 6 I lit. f GDPR can be the legal basis for a processing operation.
This is the case if the processing operation is not covered by any of the
aforementioned legal bases and the processing is necessary to protect a
legitimate interest of our company or a third party,
provided that the interests, fundamental rights, and freedoms of the data subject do not
override. If the processing of personal data is based on Art. 6 I lit. f GDPR,
our legitimate interest is the conduct of our business activities
for the benefit of our employees/shareholders.

VI. Legal or contractual provisions for the provision of
personal data

The provision of personal data is partly legally required
(e.g., tax regulations) and may also result from contractual regulations (e.g.,
information on the contractual partner). In the event that you wish to conclude
a contract with us, it is necessary that you provide us with personal data,
which will subsequently be processed by us. Failure to provide
the personal data would mean that we cannot conclude a contract with you.

VII. Routine deletion/blocking of personal data

We process and store personal data only for the period necessary to
achieve the storage purpose or as provided for by the
European legislator or other legislators in laws or regulations.
If the storage purpose ceases or a storage period prescribed by the
European legislator or another competent legislator expires, the
personal data will be routinely blocked or deleted in accordance with legal
provisions.

After the respective statutory retention period has expired, the
corresponding data will be routinely deleted, unless they are still required for
contract fulfillment or contract initiation.

VIII. Existence of automated decision-making
We refrain from automated decision-making or profiling.

IX. Your Rights

In accordance with Art. 15 GDPR, you have the right to request information as to whether
personal data concerning you is being processed by us. If this is the case, you have
the right to know the specific circumstances of the data processing.
In particular, you can request information about:

the purposes of processing; – the categories of personal data that are processed; –
the recipients or categories of recipients to whom the personal data has been or will be disclosed,
in particular recipients in third countries or international organizations;
if possible, the envisaged period for which the personal data will be stored
, or, if not possible, the criteria used to determine that period; –
the existence of a right to request rectification or erasure of the
personal data concerning them or restriction of processing by the
controller or to object to such processing.
In accordance with Art. 16 GDPR, you have the right to obtain without undue delay the rectification of
inaccurate personal data concerning you. Taking into account
the purposes of the processing, you have the right to have
incomplete personal data completed.
In accordance with Art. 17 GDPR, you can request the deletion of the
personal data stored with us, insofar as a right to storage has ceased to
exist.

You can request the restriction of the processing of your personal data
in accordance with Art. 18 GDPR, insofar as the accuracy of the data is disputed by you,
the processing is unlawful, but you oppose its erasure or we
no longer need the data for the purposes of processing, or you have
objected to the processing in accordance with Art. 21 GDPR.

In accordance with Art. 20 GDPR, you have the right to receive the personal data
concerning you, which you have provided to us, in a structured, commonly used, and
machine-readable format, and to transmit this data to another
controller.

You can revoke your given consent at any time in accordance with Art. 7 para. 3 GDPR.
You can address the revocation to the contact details mentioned above, in particular to the
email address listed.

In accordance with Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority,
in particular in the Member State of your habitual residence, your place of work, or the
place of the alleged infringement, if you consider that the processing of personal data
relating to you infringes this Regulation.

In accordance with Art. 21 GDPR, you have the right to object, on grounds relating to your particular
situation, at any time to processing of personal data concerning you which is based on
Article 6 paragraph 1 letters e) or f). We shall no longer process the personal data
unless we demonstrate compelling legitimate grounds for the processing
which override your interests, rights, and freedoms, or the processing
is for the establishment, exercise, or defense of legal claims. You can address
the objection to the contact details mentioned above, in particular to the email address listed.

X. Cooperation with Processors/Third Parties

Insofar as we disclose your data to other persons/companies, transmit it to them, or grant them access to your data
within the scope of our data processing, this is done exclusively on the basis of a legal
permission, your consent, a legal obligation, or on the basis of our legitimate interests.
If third parties have been or are commissioned by us to process data
on the basis of a so-called “data processing agreement”, this is done on the basis of Art. 28 GDPR.

XI. Transfers to Third Countries

Insofar as we process data in a third country or this occurs within the scope of
using third-party services, this only happens if it is necessary for the
fulfillment of our (pre-)contractual obligations, on the basis of your consent,
due to a legal obligation, or on the basis of our legitimate
interests. Subject to legal or contractual permissions,
we only process or have data processed in a third country if the
special conditions of Art. 44 et seq. GDPR are met. Accordingly,
processing takes place, for example, on the basis of special guarantees, such as the officially
recognized determination of a data protection level equivalent to that of the EU or
compliance with officially recognized special contractual obligations (so-called
“standard contractual clauses”).

XII. Profiles in “Social Networks”

We maintain profiles in so-called “social networks” and similar
platforms to communicate with our customers and other interested parties
in our company there. The terms and conditions and data processing policies
of the respective operators apply in this regard.
Unless otherwise specified in this privacy policy, the data of users
who communicate with us via “social networks” and similar
platforms will be processed by us.

XIII. Integration of Third-Party Services and Content

On our website, based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f.
GDPR, we use offers from third-party providers to integrate their content.
The providers of this content receive knowledge of your IP
address, as without knowledge of the IP address, the content cannot be transmitted to your browser.
You remain anonymous as the IP address is masked and no precise location tracking is possible,
nor is any data stored on your device. Zoe Escort stands for absolute discretion and you leave
no traces after your visit.

We only use content from third-party providers where your IP address
is used exclusively for the delivery of the content. There is also the
possibility that third-party providers use so-called “pixel tags” – these are invisible
graphics, also known as “web beacons” – for statistical or
marketing purposes. “Pixel tags” can evaluate information, such as
visitor traffic on our website.