Privacy Policy

Who We Are & Responsible Party

Velvet & Vice ("we", "us", or "our") is an adult entertainment and services business operating in Johannesburg, Gauteng, South Africa.

In terms of POPIA, we are the Responsible Party — the entity that determines the purpose and means of processing your personal information. Our Information Officer is responsible for ensuring compliance with POPIA and can be contacted via the details in Section 16.

This Privacy Policy applies to all personal information collected through our website (velvetandvice.co.za), via telephone, WhatsApp, email, and in the course of providing our services.

Personal Information We Collect

We may collect the following categories of personal information:

• Identity information: First name (surname is optional and not required)
• Contact information: Email address, telephone number, WhatsApp number
• Event information: Event type, date, venue location, number of guests, service preferences
• Financial information: Payment details processed via our payment provider (we do not store card details)
• Communications: Records of correspondence with us via email, WhatsApp, or our contact form
• Technical information: IP address, browser type, device type, pages visited, time spent on site (collected via cookies — see Section 12)
• Age verification information: Confirmation that you are 18 years of age or older

We apply the principle of data minimisation — we only collect information that is adequate, relevant, and not excessive relative to the purpose for which it is processed.

How We Collect Personal Information

We collect personal information through the following means:

• Completion of our website contact or enquiry form
• Direct communication via email, telephone, or WhatsApp
• Age verification on entry to our website
• Booking and payment processes
• Automatic collection via cookies and web analytics tools when you browse our website

Where possible, we collect personal information directly from you. We do not purchase or acquire personal information from third-party data brokers.

Purpose of Processing

We process your personal information for the following specific, explicitly defined, and legitimate purposes:

• To respond to your enquiries and provide you with information about our services
• To process and fulfil bookings for our services
• To process payments and issue receipts
• To communicate with you before, during, and after the provision of services
• To verify that you are of legal age (18 years or older) to access our content and services
• To comply with our legal obligations under South African law
• To send you marketing communications about our services, where you have given consent (see Section 13)
• To improve our website and services through analytics
• To handle any complaints, disputes, or legal claims

We will not process your personal information for any purpose other than those listed above without your prior consent, unless required or permitted to do so by law.

Lawful Basis for Processing

In terms of section 11 of POPIA, we process your personal information on the following grounds:

• Consent: Where you have given us specific, voluntary, and informed consent to process your information (e.g. direct marketing, age gate confirmation)
• Contractual necessity: Where processing is necessary to fulfil a contract with you or to take steps at your request prior to entering into a contract (e.g. processing a booking)
• Legitimate interest: Where processing is in our legitimate business interests and does not unduly infringe upon your rights (e.g. responding to enquiries, improving our services)
• Legal obligation: Where processing is necessary to comply with a legal obligation applicable to us under South African law

Special Personal Information

POPIA affords heightened protection to certain categories of sensitive information referred to as "special personal information", including information relating to sexual behaviour or orientation.

The nature of our business means that your engagement with specific services (e.g. BDSM equipment, adult parties) may, by implication, relate to aspects of your private or sexual life. We treat any such inferences with the utmost discretion and apply the following safeguards:

• We do not record, document, or retain any information relating to your sexual preferences beyond what is strictly necessary to provide the requested service
• Such information is never shared with any third party
• Service-specific preferences shared during booking are deleted after the service is delivered, unless you request otherwise
• We apply the strictest access controls to any records containing sensitive details

Sharing of Personal Information

We treat your personal information as strictly confidential. We do not sell, rent, or trade your personal information to any third party.

We may share your personal information only in the following limited circumstances:

• Service providers (Operators): Third-party service providers who assist us in delivering our services, such as payment processors, hosting providers, and communication platforms. These parties are contracted to process information only on our instructions and in accordance with POPIA.
• Legal requirements: Where we are required to disclose your information by law, court order, or a competent authority under South African law.
• Protection of rights: Where disclosure is necessary to protect our legal rights, prevent fraud, or ensure the safety of our staff or clients.

All third parties with whom we share your information are required to maintain equivalent standards of confidentiality and data protection.

Cross-Border Transfers of Personal Information

In terms of section 72 of POPIA, we may only transfer personal information to a third party in a foreign country if:

• The recipient country has adequate data protection laws substantially similar to POPIA; or
• You have consented to the transfer; or
• The transfer is necessary for the performance of a contract between you and us; or
• The transfer is for your benefit and it is not reasonably practicable to obtain your consent.

Some of our third-party service providers (such as cloud hosting or communication tools) may process your data outside South Africa. Where this occurs, we ensure that appropriate safeguards are in place to protect your information in accordance with POPIA.

Retention of Personal Information

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by law.

Our general retention periods are as follows:

• Enquiry records (no booking made): 6 months from the date of last contact, then securely deleted
• Booking and transaction records: 5 years from the date of the transaction, as required by the Tax Administration Act No. 28 of 2011
• Communication records: 12 months from last contact, unless part of an active dispute
• Service preference details: Deleted within 30 days of service delivery
• Website analytics data: 13 months in aggregate, anonymised form

When personal information is no longer required, we securely destroy or anonymise it in a manner that prevents reconstruction or identification.

Security Safeguards

In terms of section 19 of POPIA, we take reasonable and appropriate technical and organisational measures to protect your personal information against:

• Unauthorised access, disclosure, or acquisition
• Loss, damage, or destruction
• Unlawful processing

Our security measures include, but are not limited to:

• SSL/TLS encryption for all data transmitted via our website
• Password protection and access controls on all systems containing personal information
• Limiting access to personal information to staff members who require it to perform their functions
• Confidentiality obligations imposed on all staff and service providers
• Regular review of our security practices

In the event of a security compromise or data breach that poses a risk to your rights and freedoms, we will notify you and the Information Regulator as required by section 22 of POPIA, as soon as reasonably possible after discovery of the breach.

Your Rights as a Data Subject

POPIA grants you the following rights in respect of your personal information:

• Right to be notified (s18): You have the right to be informed when we collect your personal information and the purpose for which it is collected.
• Right of access (s23): You have the right to request confirmation of whether we hold personal information about you, and to access that information.
• Right to correction (s24): You have the right to request that we correct, update, or delete inaccurate, incomplete, or outdated personal information.
• Right to object (s11(3)): You have the right to object, on reasonable grounds, to the processing of your personal information. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the Information Regulator of South Africa (see Section 14).
• Right to object to direct marketing (s69): You have the right to object at any time to the processing of your personal information for direct marketing purposes.

To exercise any of these rights, please contact our Information Officer using the details in Section 16. We will respond to your request within a reasonable time, and no later than 30 days.

Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to improve your browsing experience and to gather analytics about site usage.

What are cookies? Cookies are small text files placed on your device by a website. They do not identify you personally but may be linked to personal information you provide.

We use the following types of cookies:

• Essential cookies: Required for the website to function, including your age-verification session. These cannot be disabled.
• Analytics cookies: Help us understand how visitors use our website (pages visited, time spent, entry and exit points). Data is aggregated and anonymised where possible.
• Preference cookies: Remember settings and choices you have made on our website.

You may control or delete cookies through your browser settings. Disabling non-essential cookies will not prevent you from using our website, but may affect some functionality.

Direct Marketing

In terms of section 69 of POPIA, we will only send you direct marketing communications (such as promotional emails or WhatsApp messages) if:

• You have given us your consent to do so; or
• You are an existing client and the communication relates to similar services to those you have previously used, and you have been given an opportunity to opt out.

Every direct marketing communication we send will include a clear and easy mechanism to opt out at any time. You may also opt out by contacting us directly. Once you have opted out, we will not send further marketing communications and will update our records promptly.

We will never share your contact details with third parties for their marketing purposes.

Complaints & The Information Regulator

If you believe that your personal information has been processed in a manner that does not comply with POPIA, you may lodge a complaint with us first by contacting our Information Officer (Section 16). We will investigate and respond within 30 days.

If you are not satisfied with our response, or if you prefer to lodge a complaint directly, you have the right to approach the Information Regulator of South Africa:

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will update the "Last updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically. Continued use of our website or services following any changes constitutes your acceptance of the updated policy.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights as a data subject, or need to contact our Information Officer, please reach out via the following: