ATTORNEY REVIEW REQUIRED BEFORE PUBLICATION

This is a working draft. It contains placeholders for facts MyLOL must supply, and flags for legal determinations that counsel must make per jurisdiction. It has not been reviewed or approved for publication, and it must not be presented to members as MyLOL's Privacy Policy in its current state.

Legal · Privacy

Privacy Policy

How MyLOL collects, uses, shares and retains personal information across our teen and adult communities — including age and identity assurance, moderation, subscriptions and your privacy rights.

Effective: [EFFECTIVE DATE] · Last updated: [LAST UPDATED DATE]

The plain-English version

This summary is for orientation only. The full policy below governs.

Who we are
[LEGAL ENTITY NAME], the operator of MyLOL and the controller of your personal information.
What we collect
What you give us (account, profile, photos, posts, messages, reports, payment details, verification information) and what we collect automatically (device, IP, session, security logs, usage).
Why
To run the service, confirm you are eligible for the community you joined, keep teen and adult communities separate, moderate content, prevent fraud, take payment, support you and meet legal obligations.
Age and identity checks
We use age assurance at sign-up. Depending on country and risk, that may involve a vendor performing a facial age estimation, a liveness check or a document check. Which specific data we receive and keep is set out in its own section — we have not buried it.
Advertising
MyLOL is a subscription product rather than an advertising-first one. [CONFIRM BEFORE PUBLISHING] whether any advertising exists and whether teen accounts are excluded entirely.
Selling data
[CONFIRM BEFORE PUBLISHING] — we make no claim here until it is verified against actual data flows and vendor contracts.
Sharing
We use service providers (hosting, email, payments, verification, moderation, analytics) who process data for us. We disclose to authorities where legally required.
Your rights
Depending on where you live: access, correction, deletion, portability, objection, restriction, withdrawal of consent, appeal, and complaint to a regulator.
Contact
[PRIVACY EMAIL]

If you're a teen member, here's the short version

Same rules, written the way we'd actually say them.

  • Adults on MyLOL can't see you, find you or message you. Teen MyLOL and Adult MyLOL are separate.
  • Your profile isn't on Google. It's visible inside the teen community, to the people you allow.
  • We don't sit and read your private messages. Automated systems look for danger signs — grooming, threats, scams — and a person checks what gets flagged or reported.
  • We don't track where you are. We know your country because eligibility depends on it, and we can tell roughly where a login came from for security. That's it.
  • When you sign up we check your age. That might mean a face scan or an ID check through a specialist company. What they keep, and for how long, is in the age assurance section — ask us if it's unclear.
  • You can ask to see your data, fix it, or delete your account. Email [PRIVACY EMAIL].
  • If something on MyLOL scares or upsets you, report it. Reporting never gets you in trouble.

See also our Safety page, the Community Guidelines and MyLOL for Parents.

Section 1

Who we are

MyLOL ("MyLOL", "we", "us") is operated by [LEGAL ENTITY NAME], a company registered in [JURISDICTION OF INCORPORATION] under company number [COMPANY NUMBER], with its registered address at [REGISTERED ADDRESS].

For the purposes of the UK GDPR, the EU GDPR and equivalent laws where they apply, [LEGAL ENTITY NAME] is the controller of the personal information described in this policy.

Data Protection Officer: [DPO IF APPLICABLE]. EU representative (Article 27): [EU REPRESENTATIVE IF REQUIRED]. UK representative: [UK REPRESENTATIVE IF REQUIRED].

[ATTORNEY REVIEW REQUIRED] — confirm whether an Article 27 representative and/or a DPO is required based on the volume and nature of processing, particularly the large-scale processing of children's data and any biometric processing.
Section 2

Scope

This policy applies to the MyLOL websites at [DOMAIN LIST], the MyLOL applications at [APP LIST], and the Teen MyLOL and Adult MyLOL communities, together with related support, billing and email communications (the "Service").

It does not apply to third-party sites or apps a member chooses to visit, including links posted by other members, or to the independent practices of the vendors named in Section 12 where they act as controllers in their own right.

[CONFIRM BEFORE PUBLISHING] the complete list of domains, apps and subdomains in scope, and whether any vendor acts as an independent controller rather than a processor.
Section 3

Age eligibility

MyLOL operates two separate communities. Which one a person may join — and whether they may join at all — depends on their age and their country.

  • Under 13

    MyLOL does not knowingly permit accounts for children under 13 in any country. See Section 17.

  • Teen MyLOL

    Intended for eligible members generally ages 13–17, subject to country-specific minimum ages and consent requirements.

  • Adult MyLOL

    Members 18 and over, in countries where MyLOL offers the Service.

  • Country-specific eligibility

    Minimum ages, parental-consent ages and age-assurance requirements differ by country. Some countries set a minimum age for social media accounts higher than 13. MyLOL does not apply a single worldwide minimum age.

  • If someone is ineligible

    Registration is refused, or an existing account is restricted or removed. Information collected during a refused registration is handled as described in Sections 5, 13 and 17.

[COUNTRY LEGAL REVIEW REQUIRED] — the eligible-country list, the minimum age applied in each market, and the parental-consent mechanism required in each market must be determined by counsel and maintained. This policy states no conclusion about the application of any particular country's law.[ATTORNEY REVIEW REQUIRED] — confirm the applicability and consequences of: COPPA and current FTC amendments (US); UK GDPR, the Data Protection Act 2018, the Data (Use and Access) Act changes and the ICO Children's Code; GDPR Article 8 and Member State consent ages; CNIL guidance and French rules for users under 15; PIPEDA, applicable provincial laws and current OPC age-assurance guidance (Canada); the Privacy Act and social-media minimum-age requirements (Australia).
Section 4

Information you provide

Categories of personal information members give us directly.

CategoryExamplesNotes
Account informationEmail address, password (stored hashed), username, date of birth, country of residence, community (teen or adult)Required to create an account
Profile informationDisplay name, bio, interests, profile theme, profile music selection, Top Friends, friends listMember-controlled; teen profiles may not contain contact or identifying details
Photos and mediaProfile photos, album photos, any images or video uploadedSubject to moderation (Section 8)
Posts and contentBlog posts, guestbook entries, group posts, comments, reactions
MessagesOne-to-one and group message content, attachments, timestamps, participantsSee Sections 6, 8 and 13
Interests and groupsGroups joined, interests selected, activity within groups
Support communicationsEmails and support tickets, their contents and attachments
ReportsReports you submit about others, and reports submitted about you, including any evidence attachedReporter identity is not disclosed to the reported member
Payment and subscription informationSubscription plan, status, renewal dates, billing contact, transaction records, partial card details as returned by the processorFull card details are handled by [PAYMENT PROCESSOR]; MyLOL does not store full card numbers — [CONFIRM BEFORE PUBLISHING]
Verification informationSee Section 5 — set out separately because of its sensitivity
Section 5

Age and identity assurance

This section is deliberately detailed. Age assurance can involve facial analysis and identity documents, and we do not think that belongs in a footnote. Only the methods MyLOL actually uses may remain in the published version — every row below must be confirmed or removed.

Depending on the member's country, age band and the risk signals attached to a sign-up, verification may be performed by a specialist vendor, [AGE ASSURANCE PROVIDER], acting as [PROCESSOR / INDEPENDENT CONTROLLER — CONFIRM]. Where a vendor performs the check, MyLOL may receive only a result rather than the underlying material. The table records that distinction for each data type.

Age and identity assurance data — one row per data type
Data typeCollected byPurposeProcessed whereWhat MyLOL receivesRetentionWho can accessDeletion
Raw selfie image or video[AGE ASSURANCE PROVIDER] — [CONFIRM whether MyLOL ever receives or stores this]Age estimation and liveness detection[PROCESSING LOCATION][CONFIRM — result only, or image?][DATA RETENTION PERIOD][VENDOR PERSONNEL / MYLOL REVIEWERS — CONFIRM][DELETION TRIGGER AND TIMING]
Face geometry / biometric template (if any is created)[AGE ASSURANCE PROVIDER] — [CONFIRM whether any template is generated at all][CONFIRM — age estimation, liveness, or duplicate-account detection][PROCESSING LOCATION][CONFIRM — MyLOL should not receive templates unless there is a documented need][DATA RETENTION PERIOD][ACCESS LIST][DELETION TRIGGER AND TIMING]
Age estimation result[AGE ASSURANCE PROVIDER]Determine eligibility and community placement[PROCESSING LOCATION]Estimated age band and confidence score — [CONFIRM][DATA RETENTION PERIOD]MyLOL safety and support personnel on a need-to-know basis[DELETION TRIGGER AND TIMING]
Liveness result[AGE ASSURANCE PROVIDER]Confirm a live person is present, deter spoofing[PROCESSING LOCATION]Pass/fail result — [CONFIRM][DATA RETENTION PERIOD]MyLOL safety personnel[DELETION TRIGGER AND TIMING]
Identity document image (government ID, or other permitted evidence)[AGE ASSURANCE PROVIDER] — [CONFIRM which document types are accepted and in which countries]Confirm date of birth where other methods are insufficient or contested[PROCESSING LOCATION][CONFIRM — result only, or document image?][DATA RETENTION PERIOD][ACCESS LIST][DELETION TRIGGER AND TIMING]
Extracted document fields (name, date of birth, document number, expiry)[AGE ASSURANCE PROVIDER]Verify age; fraud prevention[PROCESSING LOCATION][CONFIRM which fields, if any, are transmitted to MyLOL][DATA RETENTION PERIOD][ACCESS LIST][DELETION TRIGGER AND TIMING]
Verification token / outcome recordMyLOLRecord that a member has been verified and for which community, without re-storing underlying evidence[CLOUD HOST] — [HOSTING REGION]Verification status, method used, timestamp[DATA RETENTION PERIOD]MyLOL safety, support and engineering personnel on a need-to-know basis[DELETION TRIGGER AND TIMING]
Manual review data (case notes, escalation records, appeal submissions)MyLOL and/or [AGE ASSURANCE PROVIDER] — [CONFIRM]Resolve checks that cannot be decided automatically; handle appeals[PROCESSING LOCATION]Case record and decision[DATA RETENTION PERIOD]Trained MyLOL reviewers[DELETION TRIGGER AND TIMING]

For teen members: In plain terms: when you sign up we need to be confident about your age. A specialist company may check a selfie or a document. We are telling you exactly what they keep and what we see, because you should know that before you hand over your face.

MyLOL does not publish the circumstances that trigger each check, because doing so would assist circumvention. That non-disclosure concerns triggering logic only — the categories of data processed are set out in full above.

[ATTORNEY REVIEW REQUIRED] — determine whether any element of this processing constitutes biometric data under GDPR Article 9, the Illinois BIPA, Texas CUBI, Washington My Health My Data or other US state biometric laws, and identify the lawful basis, notice, consent and retention-schedule requirements that follow. Do not publish this section until each row is confirmed or deleted.[ATTORNEY REVIEW REQUIRED] — confirm the lawful basis for processing children's verification data, and whether a Data Protection Impact Assessment / Children's Code conformance assessment has been completed and documented.[CONFIRM BEFORE PUBLISHING] — remove every method MyLOL does not actually use. A published policy describing a check that does not exist is itself a misrepresentation.
Section 6

Information collected automatically

Collected when you use the Service, whether or not you are logged in.

CategoryExamples
Network informationIP address (which indicates approximate region — see note below), connection metadata
Device and browserDevice type, operating system, browser type and version, language, screen characteristics
Session informationLogin and logout times, session identifiers, authentication events, device fingerprint signals used for security — [CONFIRM]
Security logsFailed login attempts, suspected automation, rate-limit and abuse-prevention events
Cookies and similar identifiersSee Section 18 and the Cookie Policy
Approximate regionDerived from IP address and/or the country of residence you provide
Referral informationReferring URL, campaign parameters where present
Usage analyticsPages and features used, interaction events, error and performance data, via [ANALYTICS PROVIDER]

Important accuracy point: MyLOL does not use precise or GPS location, and does not offer location-based discovery for teen members. That is not the same as collecting no location information at all — an IP address indicates an approximate region, and we use it for security, fraud prevention and eligibility purposes.

[CONFIRM BEFORE PUBLISHING] the analytics tooling actually deployed, its configuration for teen accounts, and whether any device-fingerprinting technique is used.
Section 7

How we use information

Purposes of processing
PurposeWhat this involvesMain categories used
Provide the ServiceCreate and maintain your account, display your profile, deliver messages, run groups and feedsAccount, profile, content, messages
Authenticate youLog you in, keep sessions secure, detect account takeoverAccount, session, device, security logs
Verify eligibilityConfirm age and country eligibility and place you in the correct communityAccount, verification (Section 5)
Keep communities separatedEnforce that teen and adult accounts cannot discover, view, search or contact each otherAccount, community flag
ModerationReview content and behaviour against the Community Guidelines, act on reportsContent, messages, media, reports, moderation records
SafetyDetect grooming, sexual solicitation, exploitation, threats, harassment and other harms; escalate serious casesContent, messages, reports, risk signals
Prevent fraud and abuseDetect fake accounts, ban evasion, scams, spam and automationDevice, session, security logs, verification outcome
Process subscriptionsTake payment, manage renewals, cancellations and refundsPayment and subscription information
Customer supportAnswer questions, investigate issues, handle appealsSupport communications, account, relevant records
Analytics and improvementUnderstand usage, fix failures, improve the productUsage analytics, device
Legal complianceMeet legal obligations, respond to lawful requests, keep required records, establish or defend legal claimsAny category, as necessary and proportionate
Section 9

AI and automated systems

Automated systems help us operate at scale. Where a decision could significantly affect a member, a person is involved.

Decisions with a significant effect — for example permanent account removal, or refusal of eligibility — are made or confirmed by a trained person, and members are given a route to appeal. Where a decision is made solely by automated means and produces legal or similarly significant effects, the rights under UK/EU GDPR Article 22 apply and members may request human review.

  • Image moderation

    Uploaded images are analysed for prohibited content — including nudity, sexual content and content involving minors — using [AI MODERATION PROVIDER]. Matches are blocked or queued for human review.

  • Text moderation

    Posts, profile fields and messages are analysed for prohibited content and risk patterns such as sexual solicitation, grooming behaviour, threats, scams and off-platform migration pressure.

  • Fraud and risk detection

    Signals from devices, sessions and behaviour are used to detect fake accounts, ban evasion and automated abuse.

  • Age assurance

    Automated age estimation may be used as described in Section 5, with human review and an appeal route where a result is contested.

  • Recommendations

    [CONFIRM whether any recommendation or ranking system operates, and whether teen accounts are excluded from profiling-based recommendation]

[CONFIRM BEFORE PUBLISHING] which decisions, if any, are currently made solely by automated means without human involvement, and confirm the appeal mechanism actually exists for each.[ATTORNEY REVIEW REQUIRED] — assess Article 22 applicability and any transparency obligations under the EU AI Act and the DSA in relation to moderation and recommender systems.
Section 10

Teen member data

Teen MyLOL is designed to a higher privacy standard than the adult community. This section describes those differences.

  • No teen/adult crossover

    Teen accounts and adult accounts cannot discover, search, view, message or share groups with each other. Teen personal information is not made available to adult community members through the product.

  • Search-engine indexing

    Teen profiles and teen content are not indexed by public search engines. — [CONFIRM BEFORE PUBLISHING; verify robots directives and any public endpoint]

  • Location

    No precise location collection, no location-based discovery, no distance sorting and no live location sharing for teen members. Approximate region derived from IP is used for security and eligibility only.

  • Profiling and advertising

    [CONFIRM BEFORE PUBLISHING whether teen accounts are excluded from all advertising and from profiling-based recommendation. Do not publish an exclusion that is not implemented.]

  • Privacy defaults

    [CONFIRM the default audience for teen profiles, albums and posts, and the default messaging permissions. Children's Code expectations point to high-privacy defaults; the published policy must describe the shipped defaults.]

  • Data minimisation

    Contact details, school names and other identifying information are not permitted in teen profile fields and are removed when detected.

  • Parental involvement

    Where a country requires verifiable parental consent, that is obtained through a separate process. Payment by a parent is not treated as parental consent.

For teen members: Short version: adults can't reach you, you're not on Google, we don't track where you are, and we keep as little about you as we can while still running the service.

[ATTORNEY REVIEW REQUIRED] — complete a Children's Code conformance assessment and a DPIA covering teen processing before publication.[COUNTRY LEGAL REVIEW REQUIRED] — parental-consent mechanics and any additional youth-privacy requirements per market.
Section 11

Parent and guardian rights

Where the law gives a parent or guardian rights over a child's personal information, we will honour them. Depending on the country and the age of the member, those rights may include being informed about processing, accessing certain information, requesting correction, requesting deletion, and withdrawing a consent previously given.

Exercising these rights requires verification of both the requester's identity and their relationship to the member. We may decline or limit a request where doing so is necessary to protect the member — for example where disclosure could expose a young person to harm — or where the member's own rights, or the privacy of third parties in a conversation, would be affected.

MyLOL does not offer a parental dashboard, does not provide access to a member's private messages on request, and does not permit a parent to control another person's account settings remotely. A parent may always raise a safety concern with us at [SAFETY EMAIL].

[ATTORNEY REVIEW REQUIRED] — confirm per market when a parent's access or deletion request must be honoured, when it may be refused in the child's interests, and the required identity/relationship verification standard.
Section 12

How we share information

We do not operate the Service alone. The categories below describe who receives personal information and why. This is a category list; the specific vendors must be named before publication.

Recipient categoryNamed vendorWhat they receiveRole
Cloud hosting and storage[CLOUD HOST]All Service data, as hostedProcessor
Age and identity verification[AGE ASSURANCE PROVIDER]Verification data per Section 5[PROCESSOR / CONTROLLER — CONFIRM]
Payment processing[PAYMENT PROCESSOR]Payment and subscription data; card details are handled by the processor[PROCESSOR / CONTROLLER — CONFIRM]
Email and notifications[EMAIL PROVIDER]Email address, message content sent to youProcessor
AI and content moderation[AI MODERATION PROVIDER]Content submitted for analysisProcessor
Analytics[ANALYTICS PROVIDER]Usage and device dataProcessor
Customer support tooling[SUPPORT PROVIDER]Support communications and account contextProcessor
Professional advisersLegal, accounting and insurance advisersAs necessary for the advice soughtController
AuthoritiesLaw enforcement, regulators, courts, and child-safety reporting bodiesAs legally required or permitted — see Section 19Controller
Corporate transactionsA buyer or successor in a merger, acquisition or asset saleMember data as part of the business, subject to this policy and notice where requiredController

Because these vendors process personal information on our behalf, we do not and cannot claim that MyLOL "does not share your data". What we can say is that we use vendors under written terms that limit them to processing on our instructions.

[CONFIRM BEFORE PUBLISHING] the complete vendor list, each vendor's role, the safeguards in place, and that a written processing agreement exists with each processor.
Section 13

Selling and targeted advertising

MyLOL's business model is subscription-based rather than advertising-first. Whether MyLOL "sells" or "shares" personal information as those terms are defined under US state privacy laws, and whether any targeted advertising or cross-context behavioural advertising occurs, must be determined against actual data flows and vendor contracts. [CONFIRM BEFORE PUBLISHING]

No claim that MyLOL does not sell personal information, and no claim that MyLOL does not engage in targeted advertising, may be published until each has been verified operationally and legally. [CONFIRM BEFORE PUBLISHING]

Where a right to opt out of sale, sharing or targeted advertising applies, the mechanism will be described here and made available in account settings. [CONFIRM MECHANISM]

[ATTORNEY REVIEW REQUIRED] — assess statutory definitions of "sale" and "share" (including analytics and advertising identifiers) under applicable US state laws, and any prohibition on targeted advertising to known minors.
Section 14

Data retention

We keep personal information only as long as necessary for the purposes described in this policy, or as required by law. No period below has been invented — each must be supplied and justified.

Retention schedule
CategoryRetention periodRationale
Active account data[DATA RETENTION PERIOD]For the life of the account
Deleted accounts[DATA RETENTION PERIOD]Grace period for recovery, then deletion or anonymisation — [CONFIRM GRACE PERIOD]
Messages[DATA RETENTION PERIOD]Service delivery; safety investigation
Content (profiles, posts, media)[DATA RETENTION PERIOD]Service delivery
Moderation evidence[DATA RETENTION PERIOD]Enforcement consistency, appeals, legal claims
Reports[DATA RETENTION PERIOD]Investigation, repeat-offender detection, appeals
Security and access logs[DATA RETENTION PERIOD]Security, fraud prevention, incident investigation
Verification outcome records[DATA RETENTION PERIOD]Evidence that eligibility was checked
Raw biometric material and ID documents[DATA RETENTION PERIOD] — should be the shortest period in this table; confirm whether MyLOL holds any at allMinimisation; statutory biometric retention-schedule requirements
Billing and transaction records[DATA RETENTION PERIOD]Tax, accounting and audit obligations
Enforcement records for removed accounts[DATA RETENTION PERIOD]Prevent ban evasion; child-safety obligations
Support communications[DATA RETENTION PERIOD]Service history and dispute handling
[ATTORNEY REVIEW REQUIRED] — confirm each period against statutory minimums (tax, accounting), statutory maximums (biometric retention schedules), preservation obligations in child-safety matters, and the data-minimisation principle.
Section 15

Data security

We use technical and organisational measures appropriate to the sensitivity of the information we hold. These include encryption of data in transit and at rest, access controls limiting personnel access to what their role requires, logging and monitoring of access to sensitive systems, staff training, vendor due diligence and an incident-response process. [CONFIRM each measure listed is actually in place; remove any that is not.]

No system is completely secure. We do not promise that personal information will never be accessed without authorisation. Where a breach occurs and notification is required, we will notify affected members and the relevant supervisory authority within the timeframes the law requires.

We do not publish details of our security architecture, monitoring thresholds or fraud-detection logic.

[ATTORNEY REVIEW REQUIRED] — confirm breach-notification obligations and timelines per market, and that an incident-response plan is documented and tested.
Section 16

International transfers

Personal information may be processed in [PROCESSING COUNTRIES], including by the vendors listed in Section 12 who operate in [VENDOR PROCESSING COUNTRIES].

Where information is transferred out of the UK, the EEA or another jurisdiction that restricts transfers, we rely on [INTERNATIONAL TRANSFER MECHANISM] — for example an adequacy decision, the UK International Data Transfer Agreement or Addendum, or EU Standard Contractual Clauses with a transfer risk assessment as required.

A copy of the safeguards applied to a particular transfer can be requested at [PRIVACY EMAIL].

[ATTORNEY REVIEW REQUIRED] — map every transfer, identify the mechanism for each, and complete transfer risk assessments where required. Canadian, Australian and other national transfer requirements must be assessed separately. [COUNTRY LEGAL REVIEW REQUIRED]
Section 17

Your rights

Which rights you have depends on where you live. We will tell you which apply to you when you contact us, and we do not discriminate against members for exercising a right.

To exercise a right, contact [PRIVACY EMAIL]. We will verify your identity before acting. We respond within the timeframe the applicable law requires — [CONFIRM STANDARD RESPONSE TIME].

  • Access

    Ask what personal information we hold about you and receive a copy.

  • Correction

    Ask us to correct information that is inaccurate or incomplete.

  • Deletion

    Ask us to delete your personal information, subject to the exceptions in Section 18.

  • Portability

    Receive certain information in a portable format, or ask us to transmit it, where the right applies.

  • Objection

    Object to processing based on legitimate interests, including profiling, where the right applies.

  • Restriction

    Ask us to limit processing in certain circumstances.

  • Withdraw consent

    Where processing is based on consent, withdraw it at any time. Withdrawal does not affect processing already carried out.

  • Appeal

    Ask us to reconsider a decision on your request, where an appeal right applies in your jurisdiction.

  • Complain to a regulator

    Lodge a complaint with your supervisory authority — for example the ICO in the UK, your Member State authority (such as the CNIL in France) in the EEA, the OPC in Canada, or the OAIC in Australia.

[COUNTRY LEGAL REVIEW REQUIRED] — confirm the full rights set, verification standards, response deadlines and any appeal obligations per market.
Section 18

Account deletion

You can request deletion of your account from account settings or by contacting [PRIVACY EMAIL]. [CONFIRM the in-product deletion path exists.]

After deletion, some information may remain, and we want to be straightforward about why: messages you sent may remain visible to their recipients as part of their own conversation history [CONFIRM]; moderation and enforcement records may be retained to prevent ban evasion and to comply with child-safety obligations; billing records are retained for tax and accounting purposes; security logs are retained for their defined period; and information may be preserved where we are legally required to do so or where it is needed to establish or defend legal claims.

Where information is retained, it is limited to what is necessary for that specific purpose, and is deleted or anonymised at the end of the applicable retention period in Section 14.

[CONFIRM BEFORE PUBLISHING] the actual deletion behaviour — what is deleted immediately, what is retained, what is anonymised, and whether a recovery grace period exists.
Section 19

Children under 13

MyLOL is not directed to children under 13 and we do not knowingly permit them to register.

Where a registration attempt indicates the person is under 13, the registration is refused. Where we learn that an existing account belongs to a person under 13, we restrict the account and take steps to remove it. [CONFIRM the exact operational sequence, including what happens to information already collected during a refused registration, whether any record is retained to prevent immediate re-registration, and the timing of deletion. Do not state that information is deleted immediately unless that is both implemented and legally correct — a limited record may be required or permitted to prevent repeat attempts.]

A parent or guardian who believes a child under 13 has provided personal information to MyLOL should contact [PRIVACY EMAIL].

[ATTORNEY REVIEW REQUIRED] — confirm the handling of information collected from attempted under-13 registrations under COPPA and current FTC amendments, including permissible retention to prevent re-registration, and equivalent requirements in other markets.
Section 20

Cookies and similar technologies

We use cookies and similar technologies for authentication, security, preferences and analytics. Details of each cookie, its purpose and its duration are set out in our Cookie Policy at /legal/cookies.

Where consent is required for non-essential cookies, we obtain it through our consent tool and you can change your choices at any time. [CONFIRM the consent mechanism deployed, and the approach taken for teen accounts.]

[ATTORNEY REVIEW REQUIRED] — PECR and ePrivacy consent requirements, and Children's Code expectations regarding analytics on teen accounts.
Section 21

Law enforcement and legal requests

We disclose personal information to law enforcement, regulators or courts where we are legally required to do so, or where disclosure is otherwise permitted by law and necessary — for example to prevent or investigate serious harm.

We assess each request against applicable law and our own standards before responding, and we require valid legal process where the law requires it. In an emergency involving a risk of death or serious physical harm, we may disclose limited information without full legal process where the law permits.

Where we are legally obliged to report suspected child sexual exploitation, we do so through the appropriate reporting body and preserve relevant records. [ATTORNEY REVIEW REQUIRED — confirm the reporting body and obligations per jurisdiction.]

Where we are permitted to notify a member of a request, we may do so; where we are prohibited from notifying, we will not. [CONFIRM notification policy.]

Section 22

Changes to this policy

We update this policy when our practices or the law change. The effective date appears at the top.

Where a change is material, we will provide notice before it takes effect — by email, in-product notice, or both — and, where the law requires consent for the change, we will obtain it. [CONFIRM the notice period and mechanism, and note that Children's Code expectations may require a teen-appropriate explanation of material changes.]

Previous versions are available on request at [PRIVACY EMAIL]. [CONFIRM whether a version archive is maintained.]

Section 23

Contact us

Privacy contact: [PRIVACY EMAIL]

Postal address: [REGISTERED ADDRESS]

Data Protection Officer: [DPO IF APPLICABLE]

EU representative: [EU REPRESENTATIVE IF REQUIRED]

UK representative: [UK REPRESENTATIVE IF REQUIRED]

Safety concerns: [SAFETY EMAIL] · Parent support: [PARENT SUPPORT EMAIL]

Internal — not for publication

Vendor information checklist

MyLOL must complete one row per vendor before this policy can be published. A vendor cannot be described in the policy until every column is answered.

Columns required for every vendor

  • Vendor / placeholder
  • Service
  • Personal data received
  • Processor or controller
  • Processing locations
  • Transfer mechanism
  • Retention by vendor
  • Sub-processors
  • DPA signed
  • Security certifications
  • [LEGAL ENTITY NAME] — controller record: registered details, company number, group companies
  • [CLOUD HOST] — hosting and storage; hosting regions; backup locations and retention
  • [AGE ASSURANCE PROVIDER] — age estimation, liveness, document verification; whether any biometric template is created; what MyLOL receives; vendor retention
  • [PAYMENT PROCESSOR] — card handling; whether MyLOL ever receives card data; PCI scope
  • [EMAIL PROVIDER] — transactional and notification email
  • [ANALYTICS PROVIDER] — configuration, IP handling, whether teen accounts are excluded
  • [AI MODERATION PROVIDER] — image and text moderation; whether content is used for vendor model training (must be contractually prohibited — confirm)
  • [SUPPORT PROVIDER] — ticketing and support tooling
  • [CONSENT MANAGEMENT PLATFORM] — cookie consent
  • [ANY CSAM DETECTION / HASH-MATCHING PROVIDER] — if used; legal basis and reporting integration
Internal — not for publication

Jurisdictional legal-review checklist

Mentioning a law is not compliance with it. Each item below requires a determination by counsel qualified in that jurisdiction before MyLOL offers the Service there.

United States

  • COPPA and current FTC amendments — including the treatment of information collected from attempted under-13 registrations, verifiable parental consent methods, retention limits and the safe-harbour landscape.
  • State comprehensive privacy laws in each state of operation — notice content, opt-out rights, sensitive-data rules, and any prohibition on targeted advertising or sale involving known minors.
  • Biometric privacy laws (including Illinois BIPA, Texas CUBI, Washington My Health My Data) — written notice, written release, published retention schedule, and whether any element of age assurance falls in scope.
  • State age-appropriate design and youth online safety laws, and their current litigation status.
  • Subscription/auto-renewal requirements (including federal negative-option rules and state ARLs) — disclosure, consent and cancellation mechanics.

United Kingdom

  • UK GDPR and the Data Protection Act 2018, as amended by the Data (Use and Access) Act — confirm which changes are in force and their effect on this policy.
  • ICO Age Appropriate Design Code (Children's Code) — a documented conformance assessment covering defaults, profiling, geolocation, transparency for children and DPIA.
  • PECR — cookies and electronic marketing.
  • Online Safety Act interfaces where they affect privacy, including age assurance duties and any Ofcom guidance applicable to the Service.
  • ICO position on age assurance and biometric age estimation.

EU / EEA

  • GDPR — lawful bases, Article 9 conditions for any biometric processing, Article 8 child consent age per Member State and the mechanics of verifying parental authorisation.
  • DSA obligations where applicable — statements of reasons, internal complaint handling, minor-protection provisions and the prohibition on advertising based on profiling of minors.
  • ePrivacy / national cookie rules.
  • EDPB guidance relevant to children's data and age assurance.

France

  • CNIL guidance on minors' data and consent.
  • French requirements applicable to users under 15, including parental authorisation.
  • Any French-specific age-verification requirements applicable to the Service.

Canada

  • PIPEDA and applicable provincial privacy laws (including Quebec Law 25 requirements on consent, defaults and privacy impact assessments).
  • Current OPC guidance on age assurance and children's privacy.
  • Breach reporting obligations.

Australia

  • Privacy Act obligations as applicable to the Service, including any Children's Online Privacy Code developments.
  • Online Safety Act and social-media minimum-age requirements affecting certain under-16 accounts — including whether MyLOL may offer Teen MyLOL in Australia at all, and to which ages.
  • eSafety Commissioner expectations and any applicable industry codes.

All other markets

  • [COUNTRY LEGAL REVIEW REQUIRED] — no market may be launched on the assumption that this policy is adequate there. Each requires its own review of minimum age, parental consent, age assurance, biometric rules, transfer restrictions and subscription law.

Privacy questions

Write to us and we will tell you which rights apply where you live, and how to use them.

[PRIVACY EMAIL]

This draft contains placeholders in square brackets. Every one must be resolved, and every legal flag cleared by counsel, before this page is published as MyLOL's Privacy Policy.