Privacy Policy
Disclaimer: The content on this website is intended for entertainment and informational purposes only. While every effort is made to ensure accuracy, no guarantee is provided that all information is current or complete. All videos, photos, and live-stream materials are owned by Sovanna Kim Entertainment Inc. and are for viewing by consenting adults. Visitors are responsible for complying with all applicable laws and age requirements in their region.
Last Updated: October 17, 2025
Introduction
Welcome to Sovanna Kim Entertainment’s Privacy Policy.
Your privacy matters to us. We are committed to safeguarding your personal data and ensuring that your experience on our website remains safe, transparent, and secure.
This policy explains how Sovanna Kim Entertainment Inc. collects, uses, and protects your personal information when you access our site, purchase content, subscribe to updates, or interact with our live streams. It also explains your rights under applicable privacy laws and how you can contact us with any concerns.
We encourage you to read this policy carefully to understand how your data is handled and what choices you have regarding its use.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
- Important Information and Who We Are
- The Data We Collect About You
- How Is Your Personal Data Collected
- How We Use Your Personal Data
- Disclosures of Your Personal Data
- International Transfers
- Data Security
- Data Retention
- Your EEA/UK Legal Rights
- Your California Privacy Rights
- Your Nevada Privacy Rights
- Your Canadian Privacy Rights
- Do Not Track Policy
- Glossary
1. Important Information and Who We Are
Purpose of This Privacy Policy
Privacy Policy
Last Updated: October 17, 2025
Welcome to Sovanna Kim Entertainment Inc. (“we,” “us,” or “our”).
We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your personal information when you visit www.sovannakimvideos.com, make a purchase, or interact with our live streaming and digital content.
By using our website, you agree to the terms outlined below. If you have any questions, please contact us at privacy@sovannakimvideos.com.
1. Important Information and Who We Are
This Privacy Policy provides information about how we collect and process your personal data when you:
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Visit our website;
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Purchase memberships, individual digital content, or merchandise;
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Interact with us through messaging, email, or live streams.
Our site is not intended for minors or anyone under the age of 18, and we do not knowingly collect data from individuals under that age.
Data Controller:
Sovanna Kim Entertainment Inc.
777 Dunsmuir Street, 17th Floor, Vancouver, BC, Canada
Email: privacy@sovannakimvideos.com
If you are located in the European Economic Area (EEA) or United Kingdom (UK), you have the right to contact your local supervisory authority. However, we encourage you to contact us first so we can address your concerns directly.
2. The Data We Collect
We may collect and process the following types of personal data:
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Identity Data: username, display name, or similar identifier.
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Contact Data: email address and any details you choose to share when communicating with us.
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Payment Data: we do not store payment card or banking details. Payments are securely processed through PayPal or E-Transfer according to their privacy policies.
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Transaction Data: information about your purchases or services you’ve used.
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Technical Data: IP address, browser type, and device information used to access our site.
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Usage Data: interactions with our website, including pages viewed, videos accessed, and content purchased.
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Marketing Preferences: choices you make about receiving updates or promotions.
We may use aggregated and anonymized data for analytical or statistical purposes, but such data does not personally identify you.
3. How We Collect Your Data
We collect personal data through:
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Direct Interactions: when you register, make a purchase, or contact us.
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Automated Interactions: through cookies and analytics that track activity to improve site experience.
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Third-Party Services: such as PayPal or our hosting provider, which may collect limited data necessary to process transactions or provide service.
4. How We Use Your Personal Data
We use your personal data to:
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Provide access to purchased digital content or memberships;
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Process payments and send confirmations;
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Improve website performance and user experience;
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Communicate updates, offers, or support information;
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Comply with applicable laws and prevent fraudulent activity.
We will only use your data for legitimate business purposes or when you give consent. You may withdraw consent at any time by emailing privacy@sovannakimvideos.com.
5. Data Security
We use industry-standard security measures (encryption, access restrictions, firewalls) to protect your data from unauthorized access, loss, or misuse. Only staff or contractors who need the information for business operations can access it, under strict confidentiality.
If a data breach occurs, we will notify you and the relevant authorities as required by law.
6. Data Retention
We retain personal data only for as long as necessary to fulfill the purpose it was collected for, including compliance with tax or legal obligations.
Basic contact and transaction data are stored for up to seven (7) years unless you request deletion sooner and applicable laws permit it.
7. Your Rights
Depending on your location, you may have the right to:
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Access, correct, or delete your personal data;
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Withdraw consent for data processing;
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Request that we provide a copy of your data;
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Object to certain uses of your data, including direct marketing.
To exercise these rights, email privacy@sovannakimvideos.com.
8. Cookies
We use cookies to enhance your browsing experience. Cookies help remember your preferences and improve site performance.
You can adjust your browser settings to refuse some or all cookies, though parts of the site may not function properly if you do.
For details, see our Cookie Policy (you can link to your cookie section or page).
9. Payments
Payments are accepted via PayPal, Cash, and E-Transfer.
All PayPal transactions are subject to PayPal’s Privacy Policy: https://www.paypal.com/ca/webapps/mpp/ua/privacy-full.
We do not collect or store your full financial details — only transaction records confirming that payment was made.
10. International Data Transfers
Our servers and third-party services may process data outside of Canada. We ensure that these partners provide equivalent data protection standards to those required under Canadian privacy law (PIPEDA).
11. Contact
If you have any questions, privacy concerns, or requests regarding your data, please contact:
Sovanna Kim Entertainment Inc.
Email: privacy@sovannakimvideos.com
Address: 777 Dunsmuir Street, 17th Floor, Vancouver, BC, V7Y 1K4
12. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or new technologies. Updates will be posted on this page with a new “Last Updated” date.
Controller
Sovanna Kim Entertainment Inc. is the controller and responsible for your personal data (collectively referred to as “Sovanna Kim Entertainment,” “we,” “us,” or “our” in this Privacy Policy).
We have appointed a Data Privacy Manager to oversee questions regarding this Privacy Policy and how your personal information is handled.
If you have any questions, concerns, or requests related to your personal data — including exercising your privacy rights under Canadian, UK, or EU law — please contact our Data Privacy Manager using the information below:
Data Privacy Manager:
Sovanna Kim Entertainment Inc.
📍 Address: 777 Dunsmuir Street, 17th Floor, Vancouver, BC, V7Y 1K4
📧 Email: privacy@sovannakimvideos.com
We take privacy seriously and aim to respond to all inquiries within 30 days.
Controller
Contacting Us About This Policy
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Privacy Manager using the details below:
Full legal name of entity: Sovanna Kim Entertainment Inc.
Email address: privacy@sovannakimvideos.com
Postal address: 777 Dunsmuir Street, 17th Floor, Vancouver, BC, V7Y 1K4, Canada
We value your trust and take all privacy matters seriously. If you have concerns or wish to exercise your privacy rights, please reach out to us first — we’ll do our best to resolve your issue quickly and respectfully.
If you are based in the United Kingdom (UK), you have the right to file a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.
If you are located in the European Economic Area (EEA), you may contact your local data protection authority — a full list is available at https://ec.europa.eu.
If you live outside the EEA or the UK, we will apply your rights under the privacy laws applicable in your country or region.
However, before contacting a supervisory authority, we kindly ask that you reach out to us first so we can resolve your concern directly and as quickly as possible.
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
Keeping This Policy Up to Date
We review our Privacy Policy regularly to ensure it remains accurate and reflects our current practices and legal obligations.
This version was last updated on October 17, 2025.
It’s important that the personal information we hold about you is accurate and current. Please let us know if your details change during your relationship with us so we can keep your account and preferences up to date.
You can contact us anytime at privacy@sovannakimvideos.com to update your information or ask questions about this policy.
Third-Party Privacy
Third-Party Privacy
Our website may include links, plug-ins, or embedded content from third-party websites, social platforms, or services (such as PayPal, Twitter, or content-hosting networks).
Clicking on these links or interacting with external plug-ins may allow third parties to collect or share information about you.
Please note that we do not control these third-party websites or services and are not responsible for how they handle your personal data. Their privacy practices may differ from ours.
When you leave www.sovannakimvideos.com, we encourage you to review the privacy policy and terms of use of any website or platform you visit to understand how your information may be collected or used.
2. The Data We Collect About You
The Data We Collect About You
“Personal data” (also known as “personal information”) means any information that can identify you as an individual — directly or indirectly. It does not include data where your identity has been removed or anonymized.
We collect and use different types of personal data to provide our services, manage memberships, and improve your experience. This information may include:
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Identity Data: such as your username, display name, or similar identifier.
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Contact Data: such as your email address or communication preferences.
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Financial Data: limited payment details processed securely through PayPal or your chosen E-Transfer provider. We do not store your full payment information. For more details, please review the privacy policies of your payment provider directly.
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Transaction Data: details of your purchases, subscriptions, or content orders made through our website.
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Technical Data: such as your IP address, device type, browser version, operating system, time zone, and other technical details that help us maintain website functionality and security.
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Profile Data: information related to your account preferences, purchase history, and activity, including your interests or feedback (when shared voluntarily).
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Usage Data: information about how you interact with our website — including pages viewed, videos accessed, time spent, and actions taken (such as clicks or downloads).
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Marketing and Communications Data: your choices about receiving emails, offers, or updates from us.
We may also collect and use Aggregated Data (such as visitor statistics or traffic analytics) to understand how users interact with our site. Aggregated Data does not identify you personally. However, if we combine it with other data that could identify you, we treat it as personal data and protect it accordingly.
We do not collect any Special Categories of Personal Data, such as information about your race, religion, sexual orientation, health, or political opinions. We also do not collect information about criminal records or similar sensitive matters.
If You Fail to Provide Personal Data
If You Fail to Provide Personal Data
In some cases, we may need certain personal data to deliver the services or products you request — for example, to create your account, process your payment, or provide access to your purchased content.
If you choose not to provide the information we request (or if you withdraw your consent for us to use it), we may not be able to fulfill your order or grant access to certain features of the website.
If this happens, we’ll always let you know at the time so you can decide how you’d like to proceed.
We’ll never request unnecessary personal data or use it for unrelated purposes without your knowledge and consent.
3. How Is Your Personal Data Collected?
How We Collect Your Personal Data
We collect personal data in several ways to help us provide content, process payments, and maintain a safe and enjoyable experience for our visitors.
1. Direct Interactions
You may share personal information with us directly when you:
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Create an account or profile on our website;
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Purchase memberships, digital content, or model products;
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Subscribe to our updates or mailing list;
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Request customer support or send us feedback;
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Participate in surveys, promotions, or giveaways.
In these cases, we may collect Identity, Contact, and Payment Data to fulfill your requests or deliver the services you have chosen.
2. Automated Technologies or Interactions
When you interact with www.sovannakimvideos.com, we automatically collect certain Technical and Usage Data to help us understand how visitors use our site and to keep it secure.
This may include information about your device, IP address, browser type, and activity such as pages viewed and time spent on the site.
We use technologies like cookies, analytics tools, and server logs to collect this data.
You can manage or disable cookies at any time in your browser settings. For more details, please see our Cookie Policy.
3. Third-Party or Publicly Available Sources
We may receive limited personal data about you from the following trusted third parties:
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Analytics providers (such as Google Analytics) to help us understand website performance and visitor engagement;
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Payment processors such as PayPal, which may provide confirmation of successful transactions — please review their own privacy policies for details;
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Email or hosting providers that help us deliver updates, communications, and customer support.
All third-party partners are carefully selected and required to protect your data according to their own legal and privacy obligations.
4. How We Use Your Personal Data
When and Why We Use Your Personal Data
We will only use your personal data when the law allows us to do so and when it’s necessary to provide you with a safe, high-quality experience.
Most commonly, we use your information in the following circumstances:
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To perform a contract with you: for example, when you purchase digital content, join a membership, or subscribe to a service we offer.
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When it’s in our legitimate interests: such as improving our website, managing customer relationships, and ensuring platform security — provided that your privacy rights do not override those interests.
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When we need to comply with legal obligations: including record-keeping, fraud prevention, and tax or regulatory requirements.
In some cases, we may also rely on your consent — for example, when you choose to receive marketing updates or newsletters from us. You can withdraw your consent at any time by contacting privacy@sovannakimvideos.com.
We do not send third-party marketing messages or share your data with advertisers. Any promotional emails or messages you receive come directly from Sovanna Kim Entertainment Inc. and are fully optional.
Purposes for Which We Will Use Your Personal Data
Purposes for Which We Will Use Your Personal Data
We’ve outlined below how and why we use your personal data, along with the legal basis that allows us to do so.
In some cases, we may rely on more than one lawful ground depending on the activity.
If you’d like more details about a specific use, please contact us at privacy@sovannakimvideos.com.
1) To register you as a new customer or member
Type of data: Identity, Contact
Lawful basis for processing:
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Performance of a contract with you (for example, when you sign up for an account or membership).
2) To process and deliver your purchases or subscriptions
Type of data: Identity, Contact, Financial, Transaction, Marketing and Communications
Lawful basis for processing:
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Performance of a contract with you (to fulfill your purchase or service request).
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Necessary for our legitimate interests (to manage payments and prevent fraud).
3) To manage our relationship with you
(including updates about your account, terms, or privacy policy)
Type of data: Identity, Contact, Transaction, Marketing and Communications
Lawful basis for processing:
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Performance of a contract with you.
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Necessary to comply with a legal obligation.
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Necessary for our legitimate interests (to maintain accurate records and provide a smooth user experience).
4) To allow you to participate in surveys, contests, or promotions
Type of data: Identity, Contact, Usage, Transaction, Marketing and Communications
Lawful basis for processing:
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Performance of a contract with you.
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Necessary for our legitimate interests (to engage with our audience and improve our content and services).
5) To operate and protect our business and website
(including troubleshooting, security, data analysis, and hosting)
Type of data: Identity, Contact, Technical
Lawful basis for processing:
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Necessary to comply with a legal obligation.
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Necessary for our legitimate interests (to run a reliable and secure platform, prevent misuse, and maintain IT systems).
6) To deliver personalized website content and improve relevance
Type of data: Identity, Contact, Transaction, Profile, Usage, Marketing and Communications, Technical
Lawful basis for processing:
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Necessary for our legitimate interests (to understand how users interact with our content, enhance user experience, and guide our marketing).
7) To use data analytics and improve performance
Type of data: Identity, Technical, Usage
Lawful basis for processing:
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Necessary for our legitimate interests (to refine our content, measure engagement, and optimize website performance).
8) To suggest or recommend content or products that may interest you
Type of data: Identity, Contact, Transaction, Profile, Usage, Marketing and Communications, Technical
Lawful basis for processing:
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Necessary for our legitimate interests (to promote our work and expand our community).
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Consent (if you’ve opted in to receive marketing or updates).
Marketing
Marketing
We respect your right to control how your personal data is used for marketing and communication purposes.
Our goal is to make it easy for you to choose what type of updates or promotions you want to receive — or to opt out entirely at any time.
We’ve built the following simple controls so you have full say over how we contact you and what information you receive from us.
Promotional Offers From Us
Promotional Offers From Us
We may use limited personal data (such as your name, email, or general engagement information) to send you personalized updates, including:
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Notifications about new content releases, live streams, or appearances;
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Early access or special offers for members;
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News about upcoming events, tours, or collaborations.
You’ll only receive these communications if you’ve subscribed or interacted with our content in a way that reasonably suggests interest.
Third-Party Marketing
Third-Party Marketing
We do not sell or share your personal data with third-party advertisers.
Any marketing you receive comes directly from Sovanna Kim Entertainment Inc. and reflects our own activities — not external companies or unrelated brands.
If we ever collaborate with partners (for example, for a joint event or giveaway), we will ask for your clear consent before sharing your contact information.
Opting Out
Opting Out
You can unsubscribe or change your preferences at any time by:
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Clicking the “Unsubscribe” link in any of our marketing emails, or
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Contacting us directly at privacy@sovannakimvideos.com.
Opting out of marketing messages won’t affect service-related emails — for example, confirmations for purchases, memberships, or important policy updates.
Cookies
Cookies
Cookies are small files that websites place on your computer or device to store information about your activity and preferences. We use cookies to help our website function properly, remember your settings, and understand how visitors use our content.
You can control or delete cookies through your browser settings. Please note that disabling cookies may affect certain website features or limit access to member areas.
Types of Cookies We Use
1. Strictly Necessary Cookies
These cookies are essential for our website to work correctly — for example, to keep you logged in, process payments securely, or manage access to restricted content.
Without these cookies, the site may not function properly.
2. Performance and Analytics Cookies
We use tools such as Google Analytics to understand how visitors use our website, which pages are most popular, and where we can improve.
These cookies collect data anonymously and help us enhance your overall experience.
3. Functionality Cookies
These cookies help personalize your experience by remembering your preferences — for instance, your selected language or viewing options.
4. Marketing and Customization Cookies
These cookies allow us to offer you content and updates that are more relevant to your interests.
We do not use third-party advertising cookies, and your data is never sold or shared with external advertisers.
Your Cookie Choices
When you first visit www.sovannakimvideos.com, you may see a cookie notice or consent banner.
You can accept all cookies, choose only the essential ones, or adjust your preferences at any time.
Most web browsers also let you:
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Block or delete cookies,
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Receive alerts before a cookie is stored, and
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Review which cookies your device currently holds.
For instructions, visit your browser’s help page (e.g., Chrome, Safari, Firefox, Edge).
More Information
For details about how we use data collected through cookies, please refer to the Privacy Policy.
You can also contact us at privacy@sovannakimvideos.com with any questions or concerns about cookies or online tracking.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosure of Your Personal Data
We may share your personal data with the parties set out below for the purposes stated in the table (Purposes for which we will use your personal data) above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We are based in <COUNTRY NAME>, but our servers are located in <SERVER LOCATION>. We may process, store, and transfer personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed.
Unless you are located in the EEA or the UK, by submitting your personal data or engaging with the website or our application, you consent to this transfer, storing, or processing.
If you reside in the EEA or the UK, your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that the recipient third party agrees to contractual clauses.
Please contact us at <SUPPORT EMAIL> if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your EEA/UK legal rights below for further information.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your EEA/UK Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal data. To learn more about your California privacy rights, visit CCPA.
California’s “Shine the Light” law (Civil Code Section 1798.83) permits our users who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make that request, please send an email to <SUPPORT EMAIL>.
Further, if you are a California resident and would like to opt out from the disclosure of your personal data to any third party for direct marketing purposes, please send an email to <SUPPORT EMAIL>. If you opt out from permitting your personal data to be shared, you may still receive selected offers directly from us in accordance with California law.
11. Your Nevada Privacy Rights
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: <SUPPORT EMAIL>. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
12. Your Canada Privacy Rights
We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act.
We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes.
Residents of Canada are notified that the personal data they provide to us is stored in our databases outside of Canada, including in <SERVER LOCATION>, and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.
You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions.
You have the right to complain about our personal data handling practices.
If you need to contact us about your personal data or believe that we have violated your privacy rights, please contact us at <SUPPORT EMAIL>. You may visit www.priv.gc.ca for more information about your privacy rights.
13. Do Not Track Policy
Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.
14. Glossary
Lawful Basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Parties
External Third Parties
- Compliance with Laws. We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to that information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data about how you interact with the Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use Google Analytics to help us understand how our customers use the website (you can read more about how Google uses your personal data here: https://www.google.com/intl/en/policies/privacy/). You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Cookie Policy
Last Modified: January 31, 2023
Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize the device when it visits websites or uses online services. The website you visit may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically use some cookies that are strictly necessary to provide the services you request or enable communications, we request your consent for all our other cookie uses.
Types of Cookies We Use
We may use the following types of cookies:
- Strictly necessary cookies. Our website requires the use of these cookies to properly operate or provide necessary functions relating to the services you request. They include, for example, cookies enabling you to securely log into our website, use a shopping cart, or purchase products or a VIP membership. You can set your browser to block or alert you about these cookies, but some parts of our website may not work then.
- Analytical/performance cookies. These cookies allow us and our third-party service providers to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve how our website works by, for example, ensuring that users can easily find what they need on our website. These cookies generate aggregate statistics that are not associated with an individualized profile. If you do not allow these cookies, we will not know when you have visited our website.
- Functionality cookies. These cookies enable helpful but non-essential website functions that improve your website experience. By recognizing you when you return to our website, they may, for example, allow us to personalize our content for you, greet you by name, or remember your preferences (for example, your choice of language or region). These cookies may enable visitor identification over time, but not across different websites. If you do not allow these cookies, some or all our website’s functionalities may not function properly.
- Advertising, tracking, or targeting cookies. These cookies enable different advertising related functions. They may allow us to record information about your visit to our website, such as pages visited, links followed, and videos viewed so we can make our website and the advertising displayed on it more relevant to your interests. These cookies may enable visitor identification over time, but not across different websites.
- Third-party cookies. Our website may contain helpful but non-essential features or plug-ins enabling third-party services that use cookies, such as social network connectors, advertising networks, or web traffic analysis services. These cookies may enable visitor identification across websites and over time. We do not control the third party’s use of those cookies. Please review each party’s cookie disclosure before consenting to this use category.
Our Privacy Policy describes our practices for any personal data that our first-party cookies collect, store, or use.
Except for strictly necessary cookies, all first-party cookies set by this site will expire no later than two years after your last website visit. Third-party cookie expiration periods are set by their respective owners.
Cross-Border Data Transfers
The cookies we use may process, store, or transfer personal data in and to a country outside your own, with privacy laws that provide different, possibly lower, protections. You consent to this transfer, storing, or processing when you consent to our cookie use. Our servers are located in the Netherlands. Please review the third-party cookie provider’s policy to learn more about its location.
Your Cookie Choices
You consent to our use of cookies when you continue using our site.
Most web browsers allow you to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation.
Changes to Our Cookies
We will post any changes to the way we use cookies on this page and indicate on our website that we updated this cookie notice. If the changes materially alter how we use cookies, we will post a notice on our website and request your consent for the materially different use. Please check back frequently to see any updates or changes to our cookie use notice.
Contact Information
Please submit any questions, comments, or requests regarding this cookie use notice using the process described in our Privacy Policy, located at <WEBSITE DOMAIN>.