Privacy Policy

We have recently updated our Privacy Policy to comply with the new requirements set out by the EU General Data Protection Regulation and to make it easier to read. The updated Privacy Policy will automatically come into effect for all existing Program Participants on May 25, 2018. Your continued use of our Program(s) from that day on will be subject to our new Privacy Policy.

AWE is the official partner and provides exclusive affiliate Programs of,, and our other adult entertainment sites. We have created the best Programs to give you the opportunity to be successful with us, through promoting our premium sites.

When you participate in one of the Programs (Whitelabel and/or Promo Tools) and use our platform, you will share some personal information with us. Because we want you to enjoy your participation in our Programs in a peaceful and trustworthy way, please be assured that we are fully dedicated to the protection of your personal information.

Because your privacy is so important to us, we provide you with this Privacy Policy, explaining how we collect, use and share your personal information, so that you can make informed choices about the use of your data.

Please read this Privacy Policy carefully. We have tried to write it in a way, which is free of long boring sentences and legal terms. You can contact us if you have any question about our privacy practices or about what we are doing with your personal information. We will be happy to provide you any assistance you may need.


The company which decides how and why your personal data is processed, and which is called "Data Controller" is:

Duodecad IT Services Luxembourg S.à r.l., a private limited liability company ("société à responsabilité limitée") organized and existing under the laws of Luxembourg, registered in the Luxembourg Trade and Companies register under number B171.358, having its registered office at 44 Avenue John F. Kennedy, 1855 Luxembourg, Grand Duchy of Luxembourg.


We collect, use, share, transfer, and store different types of your personal data as a result of your registration on our site and participation to our Programs.

The personal data we collect includes the following categories of data:

Personal data you give us

  • When you create a Program Participant account and complete your profile

    When you create a Program Participant account on our site, we only require the following details from you:
    • Your email address;
    • A username;
    • A password.
    After your account is created, we will ask you to add additional details to your profile. This information is necessary for us to execute the payment due to you for your participation in our Program(s):
    • your identification information, including your first name and last name, your birth date;
    • your site URL;
    • your full address;
    • your payment method.

    Please note that, if you choose to receive your money through a virtual account, we will not be responsible for the data you provide to this third party to create and manage your virtual account. Please check directly the privacy policy of the virtual account provider if you want to learn more.

    You are also free to additional information to your profile, such as your Skype name and Tax ID.

  • When you create a Program Participant account and complete your profile

    We collect all information you choose to share with the AWEmpire Support, like your personal e-mail, your feedback, comment or request and your conversations with Support.

    More generally, when you communicate with us in any other way, we will collect whatever information you provide us.

Personal Information we get regarding your Program Participant activity

We collect certain information about you when you use or navigate on our site (even if you have not created an account), when you check you Stats or Dashboard, when you create or edit a Whitelabel and/or generate a Promo Tool.

  • Usage information

    We collect information about your activity on our site and about how you interact with the features of our site. Basically, we know:
    • the date of your signup, your Program Participant status (active or inactive) and your referrer (if applicable),
    • the type(s) of Program(s) you are using, your URL, and the volume of traffic generated.

    Moreover, when you receive your payment, our Billing Team collects all information related to the transaction (e.g. date of payment, method of payout) in order to facilitate the payment and to be able to answer any question you might have.

  • Content information

    We collect any content (such as your logo and/or favicon) you upload when you are creating your whitelabel site with us.

    We store any other communication data such as telephone conversations, chat logs, text messages, faxes and letters you send to us.

    Finally, we also collect any feedback or comment you post on our site.

  • Earnings/Bonus

    Based on your activity and the traffic generated by your Program(s) participation, we calculate what your earnings/bonus are on a given period.

    You can access the details of your earnings/bonus in your account settings in your Dashboard and/or in your Stats.

  • Log data and device information

    We automatically collect log data and information from or about your computer, phone, or other device you use to access or navigate on our site. This includes:
    • your IP address;
    • the date and time you logged on your account;
    • pages viewed;
    • the hardware, software or internet browser you use;
    • information about your computer’s operating system, like application version;
    • your language settings;
    • identifiers associated with cookies or other technologies that may uniquely identify your device or browser.
    If you are using a mobile device, we might also collect:
    • data that identifies your mobile device;
    • the operating system of your device and the browser used;
    • your location details;
    • app crashes and other system activity.
  • Information collected by cookies and other technologies

    Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device.

    Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may impact your use of the services on our site. To learn more about how we use cookies and your choices, please check out our Cookies Policy.


We use the information we collect for the following purposes:

Open your Program Participant account and allow your participation in our Programs(s)

  • First and foremost, we use the personal data you give us when you create your account to open and administer your online account and enable you to participate in our Program(s).
  • Your account is also a way to exercise control over your personal data. In your account, you can see your earnings, your stats and you can choose the information you wish to share with us.

We process this information as it is necessary for the adequate performance of the contract we have with you once you register on our site.

Display your Stats and Earnings/Bonus

  • We use your payout information and your activity related data in order to display Stats about your activity as a Program Participant and your earnings/bonus.
  • Please note that this information is only showed to you in your account and help you to have visibility on your activity, payments made to you and your earnings/bonus.

We process this information given our legitimate interest in providing a good user’s experience and a perfect visibility on your activity.

Improve our services

  • We use your personal data for analytical and statistical purposes. We place great emphasis on the improvement of our platform, and to offer the best affiliate Programs and commissions to you.
  • In order to better understand what your needs are (besides the trends in the industry) and how we can improve our services, we use your personal information to generate statistical reports about your activity.
  • We also use your personal data for troubleshooting and improving the functionality and quality of our services. Our main goal is to optimize our site and the related services to your needs.

We process this information given our legitimate interest in developing and improving our site and our users’ experience.

Program Participant relationship management and communication with you

  • We provide Support service on regular business days in office hours (CET). Sharing your personal details with our Support team allows us to respond to any question you might have about our Programs.
    All your communications with the AWEmpire Support and all information you provide in the course of such communications, including any review, opinion or comment about our programs are collected and analyzed so that we may respond to your request.

    Be also aware that, when receiving a request or claim from you, our Support Team can access all information you give to us and all information we collected about you within the course of your participation to our Program(s). We want to make sure that our Support team has all information needed to appropriately and immediately respond to your request, but also to be able to detect any fraudulent activity.

  • Please note that we may also communicate with you through emails or any other means, if appropriate, in order to inform you of certain changes regarding our site or of certain events/actions, for example, when you successfully register on our site.

We process this information given our legitimate interest in improving our users’ experience and delivering appropriate customer services.

Payment and Accounting

  • We use your data for payment and accounting purposes to process transactions and maintain legally required business records.

We process this information, as it is necessary for the adequate performance of the contract we have with you once you register on our site.

Ensure a safe and trustworthy environment

  • Because we want to create and ensure a safe environment, we use your personal data to detect and prevent fraud and other illegal activities related to the participation in our Programs.
  • We also use your data to detect potential breaches to the rules of our site, as explained in our Terms of Service.
  • Finally, we use your personal information for security purposes and risk assessment, such as to authenticate you on our site and verify your identity.

We process this information given our legitimate interest in ensuring compliance with the rules of our site, fraud detection and prevention, as well as, information, system, network and cyber security.

Sending of marketing emails

If you have accepted to receive marketing emails, we will use your personal data for sending emails about special offers and services, or information that may be of interest for you.

You can very easily revoke such consent at any time in your "Privacy Settings". Revoking consent means you might miss out special offers.

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data, such as for accounting purposes, to respond to requests of competent authorities or to establish, exercise or defend legal claims.


We implement serious security measures to grant maximum protection to your personal information against unauthorized access, modification, disclosure or deletion. Your data is always protected by our highly sophisticated security systems.

We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our site and the entire IT infrastructure related to it are updated against the latest network security vulnerabilities. We periodically test our IT systems and do sophisticated penetration tests. Our site incorporates the most advanced security technologies available in order to ensure maximum safety of its users and the safekeeping of their related information.


We share your data with the following parties:

With other users of the site

If you manage to become one of our top Program Participants, we will post your username on the website. If you do not wish to appear in the top Program Participants list, you can anytime ask our Support Team to remove your username from the list.

Entities of our company’s group

We share your personal information with the following companies of our group based in Luxembourg and Hungary, as they are helping us to deliver the services to you:

  • Jasmin IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary.

Service providers

We use carefully selected and trusted third parties, who act as service providers to our site.

We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our site, our third party service providers may regularly change. Such entities mainly belong to the following areas: (a) business intelligence and analytics; (b) customer care; (c) marketing and sales.

Payment providers and financial institutions

In order to receive your payment, you may share certain information with a third party bank or payment processor (i.e. Paxum or ePayService).

You may receive transactional emails from this party confirming the receipt of your referral fees, including other possible relevant notifications.

If you share information with third parties directly, this Privacy Policy does not govern that information.

We may furthermore share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.

Law enforcement agencies or governmental authorities

We may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our Terms of Service, and/or (d) protect our rights or defend ourselves against any claims.

Business transfers

Finally, please also note that your information may also be transferred to another company in the event of sale of the whole or part of our business to a third party.


As we are a Luxembourg based company, we comply with the EU Data Protection Regulation commonly called "GDPR" (If you want to learn more you can check: EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC), which provides a high level of protection of your personal data.

In the course of the operation and exploitation of the site and the provision of the services, your personal information may be transferred outside of the European Economic Area ("EEA") to third parties data processors for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.


We did our best to explain what your rights are and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, do not worry, our Support Team will provide you with all the assistance you need when exercising your rights.

You may also contact us, at any time, before exercising any of your rights, and we will reply to your request as quickly as possible.

Please note that we created a specific interface called "Privacy Rights" in your account settings in order for you to be able to easily exercise your rights.

Our Support Team will provide you with information on actions taken within 30 days of when we receive your request. Only in exceptional circumstances, when we face complex or a high number of requests, we may extend this period of response up to 60 days.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Data access and data portability

You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge through the "Data Download" section in your account settings.

Upon verification of your identity, your request will be sent to our Support Team.

If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period of time), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you the information.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). For this purpose, you can send an email to

Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can send an email to

Data retention and erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations.

If you no longer want us to use your information, you can request that we erase your personal information and close your model account. In such case, please select "Forget my Data" in the "Privacy Rights" section of your account settings.

Your request will be sent to our Support Team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time.

Please note that if you request the erasure of your personal information:
  • We might retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we close or suspend your account for fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information shall also be kept available in case of ongoing judicial proceedings/and or investigations.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that according to Luxembourg legislation financial related information shall be kept for a period of ten years.
  • Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  • In order to protect our site and your personal information from accidental or malicious loss and destruction, we have backup systems. Residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Right to object

  • We process your data for a variety of reasons as explained in "WHY DO WE PROCESS YOUR PERSONAL DATA?". Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.
  • In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.
  • Please keep in mind that objecting to the use of your data might disable the use of your account.
  • Please note that you may, at any time, ask us to stop processing your data for any direct marketing activities that we may do by sending an email to

Right to restriction of processing

You have the right to request that we hold your personal data in "limbo", while other challenges are resolved.

Basically, you can ask us to put on hold the use of your data in 4 cases:
  • If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.
  • You have objected to a processing activity based on legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.
  • You consider that the processing is unlawful but you object to erasure and request restriction, instead.
  • We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (in particular in the Member State where you live, place of work or of an alleged infringement of the GDPR).


We may occasionally amend this Privacy Policy to reflect changes to our services and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the relevant app/site and/or contact you using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force. Your continued use of our site from that day on will be subject to the new Privacy Policy.


If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to or via mail to the address indicated below, and we will get quickly back to you. We are always glad to talk about our privacy practices

Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at: or mail to the following address:

To the attention of the DPO
Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg