Privacy Policy
Last Updated: August 25, 2026
The protection of your personal data and privacy is our highest priority. This Privacy Policy explains how we collect, process, protect, retain, and delete personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and applicable data protection laws.
1. Data Controller
The Data Controller responsible for determining the purposes and means of processing your personal data is:
- Business Name: Marcel Havlík – Marcello Production
- Owner/Controller: Marcel Havlík
- Company ID (IČO): 56 748 493
- Trade Register: Registered in the Trade Register of the District Office Bratislava (Okresný úrad Bratislava), Trade Register No.: 110-350586
- Registered Address: Dobrovičova 126/5, 811 02 Bratislava, Slovak Republic
- Contact Email: production@ceeauditions.com
2. Age Restriction (18+) & Prohibition of Minors’ Data
The website ceeauditions.com and all associated production activities, castings, and services are strictly intended for adults aged 18 and older.
- We do not knowingly solicit, collect, process, or store personal data from any person under the age of 18.
- If we become aware or suspect that personal data of a minor (under 18) has been submitted, such data and files will be immediately and permanently purged from all systems, and the application will be rejected.
3. Categories of Personal Data We Process
To evaluate adult applicants, manage casting procedures, secure digital submission records, and produce audiovisual or photographic content, we process the following categories of data:
- General Personal Data & Physical Characteristics: First and last name, stage name (alias/pseudonym), email address, phone number, age/date of birth, photographic/video materials, signed contracts, government-issued identification documents, physical measurements/body proportions, details regarding tattoos, piercings, and breast implants or other aesthetic enhancements.
- Technical & System Data (Form Submissions): Upon submission of a form, we automatically collect metadata including your IP address, browser type and version, operating system (OS), and timestamp of the submission.
- Special Categories of Personal Data (Sensitive Data):
- Health-related data: Information regarding the date and results of your most recent Sexually Transmitted Disease (STD/STI) tests.
- Sexual orientation and preferences: Information regarding your sexual orientation, sexual preferences, and boundaries related to adult content production.
4. Legal Basis and Purpose of Processing
- Performance of Contract / Pre-contractual Relations (Art. 6(1)(b) GDPR): Processing general personal data, stage names, physical measurements, aesthetic details, and media files necessary for casting evaluation, matching roles, and production planning.
- Legitimate Interests & Legal Compliance (Art. 6(1)(f) and Art. 6(1)(c) GDPR):
- Permanent retention of age verification records to prove compliance with legal adult production standards and protect against legal liabilities.
- Processing of Technical Data & IP Addresses: Collected specifically for the purposes of system security, preventing automated spam/bot abuse, fraudulent submissions, maintaining technical compatibility across devices, and establishing a legally valid audit trail (proof of submission and consent timestamps).
- Explicit Consent for Sensitive Data (Art. 9(2)(a) GDPR): The processing of special categories of data—specifically health/STD test results, sexual orientation, and sexual preferences—is conducted strictly on the basis of your explicit, voluntary consent, granted by checking the designated boxes in the submission form solely to ensure safety, consent boundaries, and appropriate project placement.
5. Storage, Encryption, and Physical Security
We strictly adhere to high-level technical and organizational data protection standards:
- Zero Web Database Storage: Your submission responses and uploaded files are never stored in the website’s database or on the web hosting server’s permanent storage.
- Encrypted Cloud Storage & Communication: Submitted forms and attachments are immediately transferred into a secure, encrypted cloud environment utilizing End-to-End Encryption (E2EE) provided by specialized privacy-focused service providers based within Switzerland/EU, adhering to strict European data protection standards.
- Automatic Server Cleanup: All temporary files created during form transmission are automatically and permanently purged from the web server immediately after delivery.
- Physical Secure Storage: Hard-copy documents (such as printed age verification records, physical consent forms, or signed contracts) are securely stored in physically locked, restricted-access locations accessible strictly by authorized personnel.
6. Data Retention Schedules
Data retention timelines strictly depend on the nature, purpose, and legal necessity of the specific data category:
- Age Verification Documentation (Permanent Archiving): To comply with strict legal requirements and protect the Controller against future legal liabilities regarding adult content and performer eligibility, records proving that a participant was at least 18 years of age at the time of production (government-issued ID copies, age verification forms, and signed contracts) are retained permanently in encrypted digital storage and/or secured physical archives.
- Technical Data & IP Address Logs: Technical metadata (IP address, browser, operating system, and submission timestamps) linked to form submissions is retained for a period of 1 to 3 years from the date of submission for security logging, legal audit trails, and fraud prevention purposes.
- Health Data (STD/STI Test Results): Sensitive health data is stored strictly in encrypted digital storage and is permanently deleted within 30 to 90 days or immediately upon completion/termination of the specific production project.
- Sexual Orientation & Preferences Data: Information regarding boundaries and preferences is stored for the duration of the project and deleted within 90 days post-production or immediately upon withdrawal of consent.
- General Casting & Physical Data (Unsuccessful Applicants): Application materials, measurements, and audition photos for candidates who are not selected are permanently deleted or shredded within 3 to 6 months from the conclusion of the casting process.
- General Casting Data (Selected Talent Database): With your explicit consent, general profile details and photos of selected performers may be retained for up to 2 to 3 years for future project matching, after which consent must be renewed or data will be purged.
7. Data Sharing and Third Parties
Your personal data, particularly sensitive health records, information on sexual orientation/preferences, technical logs, and identification documents, are never sold, rented, or publicly disclosed. They will not be shared with unauthorized third parties without your explicit prior written consent.
8. Your Rights Under GDPR
As a data subject, you hold the following rights:
- Right to Withdraw Consent: You may withdraw your consent for sensitive data processing (health records, sexual orientation/preferences) at any time by contacting us via email.
- Right of Access & Rectification: You have the right to request confirmation or correction of the personal data we hold about you.
- Right to Erasure (“Right to be Forgotten”): You may request the deletion of your general and sensitive personal data. However, the Right to Erasure does not apply to age verification records, proof-of-age documentation, and security logs (IP records), as the Controller maintains a legal obligation and legitimate legal interest to permanently retain proof of legality and protect system integrity.
- Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, such as the Office for Personal Data Protection of the Slovak Republic (Hraničná 12, 820 07 Bratislava 27, Slovakia).
9. Changes to This Privacy Policy
We reserve the right to modify, update, or amend this Privacy Policy at any time to reflect changes in legal requirements, operational practices, or technical security measures. Any updates will be posted directly on this page with an updated “Last Updated” date at the top of the document. We encourage users to review this Privacy Policy periodically.
