Privacy Policy

1. WHO WE ARE

The organization ONLINEUK LTD. is the only organization (the "Company" or "ONLINEUK") which has a registered office in the UK and is capable of controlling data in relation to the Personal Data collected by the adult site Sduko.com (the "Website") which also protects the confidentiality and security of the Personal Data while doing any sort of business activity.

The Company will have every right to modify the present policy about the use of the Site occasionally or in terms of any changes in the law and/or the regulations of the Data Protection Authorities and/or the European Data Protection Board.

When we make a change to the Privacy Policy link in the Site Footer, we will provide notice to Users of any significant changes or updates to the present policy.

You should take time to read the Privacy Policy before you start using the Website. As for us, we will continue to update and regulate the policy, keeping only the latest version for you.

2. WHICH PERSONAL DATA MAY BE COLLECTED

Personal data is any information relating to a person from which that person can be identified. The following types of personal data about you, voluntarily submitted, may be collected by the Company in the course of its activity (the term "Personal Data" does not need distinguishing between different forms of it as altogether referred to below):

• Contact data: information about your name, surname, phone number, email address, and I.D. document;
• Payment data: information about the purchase(s) you made;
• Other personal data: information about your gender, age, photo(s), as well as any other information you may progressively provide while using the Site;
• Special categories of personal data: information possibly related to your lifestyle and sexual behaviour;
• Use of the Site: IP address, user agent software, and information obtained through the use of cookies (see our Cookie Policy, which governs the details).

We also collect, use, and share aggregated data like statistical or demographic data, for example, which is not Personal Data as it does not directly (or indirectly) identify you.

3. HOW WE COLLECT YOUR PERSONAL DATA

For instance, we may compile users' usage data to determine the percentage of users that access a given Site feature in order to study general patterns in how users are utilizing our Site to help improve the Site and our service delivery. The Company will collect and process your Personal Data in the following situations:

• If you visit and navigate the Site;
• If you register for the Site in order to access all of its features;
• If you place an advertisement on the Site or respond to an advertisement;
• When working on support requests, and,
• When confirming minimum age requirements.

If you submit Personal Data in relation to someone else, you must first ensure that they have read this Privacy Policy, and you must confirm that they have consented.

We advise you to keep your Personal Data current and to inform us of any changes. Please note, in the event that you reach out to a User of the Site, using the contact details provided by the latter, we shall not be responsible for the processing undertaken by that User; the contacted user will be acting as an independent data controller.

4. WHAT PURPOSES CAN YOUR PERSONAL DATA BE USED FOR

The processing of Personal Data is carried out for the following purposes and is legitimised by the legal bases contained in the Data Protection Legislation, as detailed below:

1. Operational management and purposes strictly related to accessing, browsing, and registering on the Site.
   The Company may collect and process Personal and Contact Data, Other Personal Data, and Usage Data to allow you to access, browse, and register with the Site, and also when carrying out support communication with requesting users.
   Legal basis for processing: performance of a contract to which you are a party or of pre-contractual measures taken at your request. Providing your Personal Data for such purpose is mandatory to allow the Company to respond to your request; failure thereof would prevent the Company from processing the request.
2. Publication of and possible response to advertisements.
   The Company may process Contact details, in particular your email address, so as to enable you to publish or reply to an advertisement. Legal basis for processing: performance of a contract to which you are a party or of pre-contractual measures taken at your request. Providing your Personal Data for such purpose is mandatory, failing which would prevent the Company's ability to let you publish or reply to an advertisement.
3. Age Verification
   The Company may process your Personal Data and Contact details, and verify that you meet the minimum age requirements, through external providers, either wholly automated, through a service from third parties, or through manual verification if it is not possible to verify automatically. The Company may also process Special Categories of data and, in particular, process biometric data for the sole purpose of verifying the minimum age requirements.
   Legal basis of the processing: consent. You may provide consent for the processing of Personal Data and Contact data. Consent also applies to processing special categories of data, including biometric data. However, the data is provided on an optional basis. Not providing such data would, however, mean that you cannot use some parts of the site, for example, you can't post an advertisement. You can withdraw your consent at any time, with effect for subsequent processing, by sending an email to [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 details to process your order. Legal basis for processing: performance of a contract and to fulfil the legal obligations associated with the contract. The provision of the data is mandatory to process your order; if you do not provide the data, we will not be able to process the order.
5. Marketing purposes to meet your needs or to inform you of promotions.
   The Company may process your Data for marketing and advertising purposes, to advise you of promotional sales initiatives via automated methods of contact (email, SMS and other mass communication tools, etc.) and traditional methods of contact (e.g. telephone), or for market and statistical research purposes, if you consent and only to the extent to such consent.
   Legal basis for processing: consent. The consent is not mandatory; failure to provide consent shall not have contractual consequences. You can withdraw your consent at any time by writing to [email protected].
6. Market and statistical research to improve the service.
   The Company may process your Contact details to be able to analyze and improve its services to better serve you. Legal basis for processing: legitimate interest of the Company, in verifying and improving its services. Even so, you can object at any time to the processing of your Contact details for the above purpose. You may request to object by sending an email to [email protected].
7. Defend a right in the course of judicial, administrative, or extra-judicial proceedings and in the context of disputes arising in connection with the services offered.
   The Company may process your Personal Data to defend the Company's rights, or take action, or even bring a legal claim against you or another third party. Legal basis for processing: legitimate interest of the Company to defend its rights in a court of law. You are entitled to object on grounds relating to your particular situation at any time to the processing of Personal Data concerning you carried out by the Controller as part of the Controller's legitimate interests. Providing your Personal Data for this purpose is mandatory, because if you do not provide it, the Company will be unable to defend its own rights. Providing your Data for such purpose is an obligation; otherwise, the Company would not be able to defend its own 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 to comply with requests from Judicial Authorities and/or Supervisory Authorities, or to comply with its legal obligations.
   Legal bases for processing:
   legal obligation. Providing your Personal Data for such purpose is mandatory; otherwise, the Company would not be able to comply with legal obligations.

5. HOW WE KEEP YOUR PERSONAL DATA SAFE

The Company applies numerous safety procedures to help secure and protect the safety, integrity, and availability of your Personal Data.

All of your Personal Data is stored on our secured servers (or securely stored paper copies or equivalent durable means) or that of our suppliers and can only be accessed and used in accordance with our requirements and security policies (or equivalent by our suppliers).

6. HOW LONG DO WE STORE YOUR INFORMATION FOR

The Company will keep your Data only as long as it is necessary to achieve the purposes for which it was collected or any other purpose related to that purpose that is lawful.
As such, if Personal Data is processed for two purposes, we will retain that Personal Data till the processing purpose with the longest duration ceases; however, we will no longer process your Personal Data for purposes where the retention period has expired.
We limit access to Personal Data to persons who need to know to utilize the Personal Data for relevant purposes.
When Personal Data is no longer required or there is no legal basis for retaining personal data anymore, it will be securely destroyed or irreversibly anonymized.

Retention periods relating to the different purposes described above are indicated as follows:

1. Purposes strictly related to accessing and browsing the Site, including registration to the Site and requests for support: Personal Data being processed about this purpose will be retained by the Company for the time strictly necessary to provide you access to the Site and in any case lasting no longer than 2 years from your last access to the Site. We retain the last 2 years of server log files.
2. Publication of and possible reply to advertisements: Personal Data being processed in relation to this purpose will be retained by the Company for no longer than 1 year after the advertisement was published.
3. Verification of minimum age requirements: the Personal Data being processed relating to this purpose will be retained for 1 year after the account has been deleted.
4. Fulfilments of orders formulated through the Site and activities relating to order management: Personal Data being processed to fulfill any contractual obligation can be retained for the entire duration of the contract, and then after the termination of the contractual relationship for no longer than the next 10 years.
5. Marketing to cater to the needs or to notify you of promotions: Personal Data that is processed for such purpose will be retained by the Company for 2 years from us collect it for this purpose (unless you have withdrawn your consent prior to that point).
6. Market and statistical research for the purpose of improving the service: Personal Data being processed for such purposes will be retained by the Company for 2 years from the collection time.
7. Defend a right in the course of judicial, administrative, or extra-judicial proceedings and with respect to disputes that may arise in relation to the services provided: Personal Data processed for this purpose shall be retained by the Company for the time that is strictly necessary to fulfill this purpose.
8. Purposes related to obligations set out by laws, regulations, and legislation, by provisions/requests of authorities entitled to do so by law, and/or supervisory and control authorities: Personal Data processed for these purposes will be retained by us for the length of time that is strictly necessary to fulfill these purposes.

7. WHO WE CAN SHARE YOUR PERSONAL DATA WITH

Your Data may be accessed by authorized employees and outside suppliers (data processors), meaning as per our instructions for the provision of services (if any), all IT suppliers essential for providing the services provided the Site, (including but not limited to providing payment gateways for orders placed via the Site etc. looking at age verifier/impostor etc). If you wish to see the list of data processors and other parties with whom we have shared data, please email [email protected]

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

When performing processing operations, your Data may be transferred outside of the UK and the European Economic Area (hereafter "Non-European Countries"). In these cases, where the non-European Countries to which your Personal Data could be transferred are not regarded by the European Commission as adequate, and the cases for exemption under Article 49 of the UK GDPR do not apply, the Company will implement appropriate safeguards by applicable law, in particular Article 46 of the UK GDPR. You have the right to request information as to the appropriate safeguards in place for the transfer of Personal Data, along with means of obtaining a copy of that Personal Data or information on where it has been made publicly accessible.

9. CONTACTS

If you have any queries about the company’s privacy policy, which includes any requests to exercise your legal rights (paragraph 10), the contact details for the Company, in its capacity as data controller, are the following:

ONLINEUK LTD
with registered office at 42a Morfa Road, Swansea, SA1 2EN, UK.
Registration Number: 14338624
Email address: [email protected]

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

You have the right to:

• Obtain confirmation as to whether Personal Data concerning you exists, obtain access to your Personal Data, and obtain a copy of it (commonly referred to as a “subject access request”);
• Where processing is carried out by automated means on the basis of consent or contract, obtain your Personal Data in a structured, commonly used and machine-readable format or request its transmission to another controller without hindrance (Right of portability);
• Obtain the rectification of Personal Data that we process, which is inaccurate or obtain the completion of incomplete Personal Data (Right of rectification), we may need to verify the accuracy of the new data you have provided to us;
• Obtain the erasure of Personal Data that we process if any of the grounds in Article 17 of the UK GDPR apply (Right to erasure);
• Request to limit the processing to specific Personal Data only, if one of the grounds set out in Article 18 of the UK GDPR exists (Right to restrict processing);
• Object in whole or in part to the processing of Personal Data about you (so-called Right of Objection); and
• Object to the processing of your Personal Data for direct marketing purposes.

Requests to exercise the above right should be sent to: [email protected]

You can exercise these rights for free and are not required to follow any formalities. If you choose to exercise any of the above rights, it is our responsibility to make sure that you can exercise them, and we will respond to you, in most cases, within one month.

NORMALLY NO CHARGE

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in those cases.

WHAT WE MAY NEED FROM YOU

Please note that we may need to ask you for information in order to verify your identity and to help us confirm that you have the right to access your Personal Data (or to exercise any of your other rights). This is purely to ensure the security of your Personal Data, and that no Personal Data is disclosed to any person not entitled to receive it. We may also need to request further information to assist you with your request, in which case we will contact you.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. In certain cases, it could take us longer than one month if your request is complex or you have submitted a number of requests. In this case, we will notify you and keep you updated.

11. COMPLAINTS

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