Privacy Policy

Pursuant to the Article13 of Regulation (EU) 679/2016 ("GDPR")

1. WHO WE ARE

The company Softell Ltd with 42a Riverside workshops, Pipe House Wharf, Morfa Road, The Strand, SA1 2EN, Swansea, UK, Registration Number: 01726537 (hereinafter "Softell Ltd" or the "Company") acting as data controller in relation to Personal Data collected on the adult website Oklute.com (hereinafter also referred to as the "Website"), pays the utmost attention to the security and confidentiality of the Personal Data in performing the activities it carries out.

We may occasionally revise, add to, or update this privacy policy (including by potential amendments to the Data Protection Act 2018 and the UK GDPR (together the "Data Protection Legislation") and actions of the Information Commissioner's Office ("ICO"). We will highlight substantial changes and updates to the privacy policy by bringing it to the attention of any interested parties by making any updates to the link of the privacy policy in the footer of the Site."

We encourage you to read this policy regularly so that you are aware of the latest version and that you are always informed of how we are processing your Personal Data.

In the event there are changes affecting significant rights as a registered User of the Site, we will provide you with notice of such changes by e-mail.

2. WHICH PERSONAL DATA MAY BE COLLECTED

Personal data means any information about a person from which that person can be identified. The Company may collect the following categories of personal data about you (the "Personal Data" includes all of the below categories, collectively) in carrying out its activities, which are:

• Contact information: information about your first name, last name, phone number, email address, and I.D. document;
• Payment information: information related to the purchases you have made;
• Other personal information: information about your gender, age, photos, as well as other information you may voluntarily provide as you browse the Site;
• Special categories of personal information: information that may be related to your lifestyle and sexual activity;
• Use of the Site: your IP address, user agent software, and information gathered by cookies (details are described in our Cookie Policy).

We may also collect, use, and share aggregated data such as statistical or demographic data, which is not Personal Data if affected individuals cannot be identified directly (or indirectly). For example, we may aggregate usage data from users to calculate the percentage of individuals using a particular feature of the Site to analyse general patterns indicating how other users are using our Site to help improve the Site and our service offering.

3. HOW WE COLLECT YOUR PERSONAL DATA

The Company will collect and process your Data in the following situations:

• If you visit and browse the Site;
• If you register for the Site to use all of its functionalities;
• If you post an advertisement on the Site or respond to an advertisement,
• When responding to support requests, and
• When verifying the minimum age.
• If you provide Personal Data on behalf of another Party, you must first ensure that the other Party has read this Privacy Policy and consented to Personal Data usage.
• We expect you to keep your Data up to date and to inform us when information changes.

If you contact a User of the Site, using the contact information provided by that User, we will not be responsible for the processing undertaken by that User - you are actually carrying out an action that uses an autonomous data controller.

4. WHAT PURPOSES CAN YOUR PERSONAL DATA BE USED FOR

The processing of Personal Data will be performed for the following purposes, which are legitimised by the legal bases laid out in the Data Protection Legislation, as described below:

1. Operations management and purposes strictly related to accessing, browsing, and registering on the Site.
   The Company may process your Personal and Contact Data, Other Person Data, and Site Usage Data in order to allow you to access, browse, and register with the Site, as well as when communicating with requesting users in a support role.
   Legal basis for processing: performance of a contract to which you are a party or pre-contractual measures taken at your request.
   Providing your Personal Data for such purposes is required for your requests to be processed; without it, the Company would not be able to process the requests.
2. Publication of and potential response to advertisements.
   The Company may process your Contact details, in particular your email, in order to allow you to publish or respond to an advertisement.
   Legal basis for processing: performance of a contract to which you are a party or pre-contractual measures taken at your request.
   Providing your Data for such purposes is required; without it, the Company would not be able to let you publish or respond to an advertisement.
   
   The Company may also process, for that same purpose, your photograph, and Special Categories of personal data, to publish or reply to an advertisement.
   Legal basis for the processing: consent, which will be asked from you for both the possible processing of your photograph and/or for the possible processing of your Special Categories of personal data.
   
   Not providing consent will not prevent you from publishing or replying to an advertisement. Consent can be withdrawn at any time by sending an email to the following email address: [email protected].
3. Age Verification
   The Company may also, thanks to external providers, process your Personal Data and Contact details and proceed to verify the minimum age, either in an automated manner, through a service of external providers, or in a manual form, should automated verification be impossible. In this regard, we may also process Special Categories of data, in particular, biometric data, for the sole purpose of verifying minimum age.
   
   Legal basis of the processing: consent. Consent may be given for the processing of Personal Data and Contact details, as well as for Special Categories of data, including biometric data.
   Initially supplied voluntarily, the provision of such data will mean you cannot use some of the functionality of the site (e.g., posting an advertisement, etc. ). You can withdraw consent at any time, with effect on any further processing by emailing [email protected].
4. Fulfilment of orders formulated through the Site and activities related to the management of orders.
   The Company may process your Contact details and Payment data for the purpose of accepting your order.
   Legal basis for processing: performance of a contract and fulfilment of any legal obligations about such contract.
   The provision of such data is necessary to process your order; without such data, we will not process your order.
5. Marketing purposes to meet your needs or to inform you of promotions.
   The Company may process your Information for marketing and advertising, to inform you of promotional sales initiatives by automated means (by email, SMS, and other mass communication means, etc.) and by manual means (e.g., telephone), or for market and statistical research, with your consent and within the bounds of your consent declaration. Legal basis for processing: Consent. Consent is voluntary. There will be no contractual consequences for you if you do not provide consent.
   Consent may be withdrawn at any time by emailing the address [email protected].
6. Market and statistical research to improve the service.
   Legitimate interests of the Company in having the confirmation and enhancements of its services.
   You are required to provide your Personal Data for this purpose, as the Company cannot complete its market and statistical research without to assistance in improving its services.
   However, you can object at any time to the processing of your Contact details for the above purpose. An objection can be requested by sending an email to the following email address: [email protected].
7. Defend a right in the course of judicial, administrative, or extra-judicial proceedings and the context of disputes arising in connection with the services offered.
   The Company may process your Personal Data in order to protect its rights or exercise any claims against you or any third party.
   Legal basis for processing: legitimate interests of the Company to protect its rights through judicial procedures.
   You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data concerning you by the Controller, if the processing is for the purposes of legitimate interests pursued by the Company.
   Provision of your Personal Data for this purpose is mandatory; failure to do so would render it impossible for the Company to protect its rights.
   
8. Purposes relating to obligations provided for by laws, regulations, and European legislation, by provisions/requests for authorities entitled to do so by law, and/or by supervisory and control bodies. The Company may process your Personal Data in response to requests from Judicial Authorities and/or Supervisory Authorities, or to fulfil a legal obligation.
   Legal bases for processing: legal obligation.
   Providing your Personal Data for these purposes is mandatory; if you do not, the Company cannot comply with any particular legal obligations.
   

5. HOW WE KEEP YOUR PERSONAL DATA SAFE

The Company applies a range of security features to improve protection and maintain the security, integrity, and accessibility of your Personal Data.

Personal Data is stored on our secure servers (or on secure paper copies or other durable means of storage) or those of our suppliers, and accessed and used according to our standards and our security policy (or likewise standards imposed by our suppliers).

6. HOW LONG DO WE STORE YOUR INFORMATION FOR

The Company will keep your Data only for the time needed to accomplish the purposes for which it was collected or for any other related and lawful purpose.

So if Personal Data is being processed for 2 different purposes, we will keep such Personal Data until the end of the processing purpose with the longest duration; however, we will no longer process any Personal Data for the processing purpose with an expired retention period.

We limit access to your Personal Data only to those who need to use it for relevant purposes.

When your Personal Data is no longer required, or when there is no longer a lawful basis for storing such Personal Data, it will be irreversibly anonymized or securely destroyed.

The retention period for the purposes above is outlined as follows:

1. Purposes strictly related to accessing and browsing the Site, which includes registration to the Site and support requests: Personal Data that is being processed for such purposes will be kept by the Company for the only time strictly necessary to provide the access to the Site, and in any case no longer than 2 years after your last access to the Site. We will maintain the last 2 worth of server log files.
2. Publication or potential response to ads: The Personal Data processed for this purpose will be kept by the Company for a maximum of 1 year following the publication of the ad.
3. Verification of the minimum age: the Personal Data processed for this purpose will be kept for 1 year from the end of the account.
4. Fulfilling orders made through the Site and order management related activities: Personal Data processed to meet any contractual obligation may be kept during the entire time of the contract, and following the end of the contract no longer than the next 10 years.
5. Marketing direction of your needs or knowledge of promotions: The Personal Data processed for this purpose will be kept by the Company for 2 years from the date of its collection for that purpose (unless you withdraw your consent earlier).
6. Market and statistics research to improve the service: The Personal Data processed for this purpose will be kept by the Company for 2 years from its collection.
7. Defend a right in the course of judicial, administrative, or extra-judicial proceedings which may have as its subject matter disputes arising in connection with the services offered: The personal data being processed for such purpose will be stored by the Company for the time strictly necessary to achieve such purpose.
8. Purposes relating to obligations imposed by laws, regulations, and legislation, modifications/requests from authorities entitled to do so by law, and/or authorities with a supervisory and control purpose: The personal data being processed for such purposes will be stored by the Company for the time strictly necessary to achieve such purposes.

7. WHO WE CAN SHARE YOUR PERSONAL DATA WITH

Your Personal Data may be seen by duly authorised employees and external suppliers providing support for the provision of the Services (designated as data processors), all IT suppliers providing the services offered (for example, but not limited to, providers of payment gateways supporting orders placed via the Site, providers of age checks, etc.). If you would like to see the data processors and other entities we share your data with, please contact us at the following email address: [email protected].

8. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA OR TO INTERNATIONAL ORGANISATIONS

In the event of processing operations, your Personal Data may be transferred outside of the UK and the European Economic Area (Non-European Countries). In such cases, based on the non-European countries to which your Personal Data may be transferred not being considered adequate by the European Commission, and the exemptions outlined in Article 49 of the UK GDPR not applying, the Company will put in place adequate safeguards designed to protect your Personal Data in accordance with applicable law and, in particular, Article 46 of the UK GDPR. You have the right to obtain information about the safeguards put in place for the transfer of Personal Data and the means of obtaining a copy of such Personal Data or the place where those data have been made available.

9. Contacts

If you have any questions in relation to this privacy policy, including to exercise your enforcement rights at law (paragraph 10), the contact details for the Company, in its role as data controller, are:

SOFTELL LIMITED
42a Riverside workshops
Pipe House Wharf
Morfa Road
The Strand
SA1 2EN
Swansea
UK

Registration Number: 01726537

Email address: [email protected]

YOUR PERSONAL DATA PROTECTION RIGHTS AND YOUR RIGHT TO LODGE A COMPLAINT BEFORE THE SUPERVISORY AUTHORITIES

You have the right to:

• Feel free to exercise any of these rights regarding your Personal Data as set out in Articles 15 - 22 of the UK GDPR.
• Obtain confirmation as to whether or not Personal Data concerning you exists, obtain access to your Personal Data, and obtain a copy of it (sometimes referred to as "subject access request");
• In a case where you have provided your Personal Data and processing was undertaken by automated means based on consent or contract, you have the right to obtain your Personal Data in a structured, commonly used and machine-readable format or request that we transmit your Personal Data to another controller in an obstructed manner (Right of portability);
• Obtain the rectification of Personal Data processed by us that is incorrect or the completion of incomplete Personal Data (Right of rectification), although we may be required to verify the accuracy of the new data you provide to us;
• Obtain the erasure of Personal Data processed by us if any of the grounds in Article 17 of the UK GDPR apply (Right to erasure);
• Withdraw your consent to the processing at any time if the processing is on the basis of consent, without affecting the lawfulness of the corresponding processing until the time of withdrawal (Article 7(3) of the UK GDPR - Right to withdraw consent);
• Request to limit the processing to just certain Personal Data, if one of the conditions in Article 18 of the UK GDPR exists (Right to restrict processing);
• Object, in full or in part, to the processing of Personal Data related to you (so-called Right of Objection); and
• Object to the processing of your Personal Data for direct marketing purposes.

Requests to exercise the above rights should be sent to the following address: [email protected]

The exercise of these rights is at no cost and is informal. If you exercise any of the above Rights, it is the responsibility of the Company to establish that you have the right to exercise a right and respond, usually within one month.

NO FEE USUALLY REQUIRED

You typically do not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge you a reasonable fee if your request is unfounded, repetitive, excessive. We may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

If we need to request specific information from you in order to verify your identity and establish your right to access your Personal Data (or to exercise any of your other rights), this is for your security to ensure that Personal Data is not released to anyone who is not entitled to it. We may also need to contact you to ask you for additional information about your request to assist us in responding to you more quickly.

TIME LIMIT TO RESPOND

We will make every effort to respond to all legitimate requests within one month. If your request is particularly complex or if you have made several requests, it may take us longer than a month to respond. In that case, we will notify you and keep you updated.

COMPLAINTS

If you think that the processing of your Personal Data is in breach of the Data Protection Legislation, you have the right to complain to the ICO, the UK's data protection regulator ico.org.uk, or to take legal action. However, we would appreciate the opportunity to resolve your concerns before you approach the ICO or take legal action, so please contact us in the first instance.

Last update date: April 2020