Privacy Policy

PURSUANT TO THE ARTCLE 13 OF REGULATION (EU) 679/2016 ("GDPR")

1. WHO WE ARE

The company Softell Ltd, with registered office in 42a Riverside workshops, Pipe House Wharf, Morfa Road, The Strand, SA1 2EN, Swansea, UK, in its capacity as data controller with regard to personal data collected on the adult website www.sduko.com, pays the utmost attention to the security and confidentiality of personal data in the performance of its activities.

The Company reserves the right to periodically update the current policy even considering any changes in the applicable law and/or provisions of the Data Protection Authority and/or of the European Data Protection Board.

Substantial changes and updates to the current policy will be brought to the interested parties’ attention by updating the Privacy Policy link in the Site footer.

In the event of any changes, the Company will inform the user via e-mail with a reasonable notice.

2. WHICH PERSONAL DATA MAY BE COLLECTED

The following categories of private data concerning you, which you voluntarily provide, could also be collected by the corporate within the performance of its activities (the term 'Personal data' shall mean all the categories listed down, to be jointly considered):

  1. Contact Details: including Information about your name, surname, telephone number, email address;
  2. Payment Data: information about the acquisition you've got made and therefore the payment (e.g. credit/debit card number);
  3. Other Personal Data: information about your gender, age, photograph(s), also as other data you'll provide spontaneously while browsing the Website;
  4. Special Categories of private Data: information which will be associated with your lifestyle and sexual behavior;
  5. Use of the Website: IP Address, User Agent and knowledge acquired via cookies (see our Cookie Policy which regulates the details).

3. HOW WE COLLECT YOUR PERSONAL DATA

The Company shall collect and process all your Personal Data in the following situations:

  1. If you register to the web site so as to use all of its functions;
  2. If an advertisement is published on the Website or you reply to an advertisement.
  3. If you have provided Personal Data on behalf of someone else, you must first ensure that the Privacy Policy has been read beforehand.
  4. The Company recommends everyone to keep your Personal Data updated. In case of any changes prior to updation, please inform us.

Please note that when you contact any user through the Website using the Contact details provided by the latter, the Company is not responsible for how said user manages and processes Personal Data you provided. The contacted user will in fact act as autonomous data controller.

4. WHAT PURPOSES CAN YOUR PERSONAL DATA BE SERVED

The Company may process your Personal Data for the following purposes, as per the legal basis:

(a)Purposes strictly associated with accessing and browsing the web site , including registration to the web site.

The Company may process Contact details and other personal data to allow access to browse/register to the Website.

Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the corporate from supplying you with access to the web site and/or to permit you to register.

(b)Publication of advertisements and its possible responses.

The corporate may process your Contact details (in particular, your email) to permit you to publish or reply to a billboard.

Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the corporate from letting you publish or reply to a billboard.

The Company can also process for an equivalent purpose your photograph, also as Special categories of private data.

Legal basis for processing consent which will be asked to you both for the possible processing of your photograph and/or for the possible processing of your Special categories of personal data.

Failure to supply consent won't prevent you from publishing or replying to a billboard . Consent may be withdrawn at any time by sending an email at the following address privacy.uk@sduko.com. Any withdrawal won't affect the processing administered before such withdrawal.

(c)Fulfillment of orders formulated through the web site and activities associated with the management of orders.

The Company may process your Contact details and Payment Data to process your order.

Legal basis for processing: performance of a contract and fulfillment of the legal obligations connected to such contract.

The supply of such data is mandatory to process your order; otherwise we'll not be ready to process it.

(d)Marketing activities to meet needs or to inform of promotions.

The company may process the Personal Data for marketing and advertising purposes, to make sure you know of promotional sales activities via automated contact methods such as email, SMS, other mass communication tools, etc. and traditional contact methods (e.g. by telephone), or for market and statistical research, if you give us your consent and within the bounds of such consent declaration.

Legal basis for processing: consent. The consent is optional. Failure to supply consent won't have any contractual consequences. Consent may be withdrawn at any time by sending an email at the following address privacy.uk@sduko.com or via this link.

(e)Market and statistical research to improve the service.

The corporate may process your Contact details to research and improve its services for a far better customer satisfaction.

Legal basis for processing: legitimate interest of the corporate in verifying and improving its services.

Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the corporate from completing market and statistical researches to enhance its services.

(f)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.

Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the Company from defending its rights.

(g)Purposes concerning obligations provided for by laws, regulations and European legislation, by provisions / requests for authorities entitled to try to do so by law and/or by supervisory and control bodies.

The corporate may process your Personal Data to satisfy the obligations which it's subject to.

Legal basis for processing: : legal obligation.

Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the corporate from complying with specific legal obligations.

HOW YOUR PERSONAL DATA IS SAFE WITH US

The Company uses a good range of security measures to enhance protection and maintain the safety , integrity and accessibility of your Personal Data.

All your Personal Data are stored on our secure servers (or on secure paper copies or other durable storage means) or on those of our suppliers, and should be accessed and used supported our standards and our security policies (or equivalent standards for our suppliers).

HOW LONG can We STORE YOUR INFORMATION FOR

The Company will store your Personal Data until and unless the purposes for which they were collected or for any other related and lawful purpose is met.

Therefore, if Personal Data is processed for 2 different purposes, we'll store such Personal Data until the processing purpose with the longest term ends; however, we'll not process Personal Data for the aim that the retention period has expired.

When your Personal Data are not any longer required, or when there's not any legal basis for storing them, they're going to be irreversibly anonymized or securely destroyed.

The retention periods concerning the various purposes described above are indicated as follows:

(a)Purposes strictly related to accessing, browsing and registration to the Website: Personal Data being processed for such purpose will be stored by the Company for the time strictly necessary to provide you access to the Website.

(b)Publication of and possible reply to advertisements: Personal Data being processed for such purpose are going to be stored by the corporate no later than 1 year after the publication of the advertisement.

(c)Fulfillment of orders formulated through the web site and activities associated with order management: Personal Data processed to satisfy any contractual obligation could also be stored for the whole duration of the contract, and following termination of the contractual relationship no later than subsequent 10 years.

(d)Marketing to satisfy your needs or to tell you of promotions: Personal Data being processed for such purpose are going to be stored by the corporate for two years from the date of their collection for this purpose (except within the event that you simply previously withdrew your consent).

(e)Market and statistical research so as to enhance the service: Personal Data being processed for such purpose are going to be stored by the corporate for two years from their collection.

(f)Defend a right within the course of judicial, administrative or extra-judicial proceedings and within the context of disputes arising in reference to the services offered: Personal Data being processed for such purpose are going to be stored by the corporate for the time strictly necessary to realize such purpose.

(g)Purposes concerning obligations provided for by laws, regulations and European legislation, by provisions / requests for authorities entitled to try to to so by law and/or by supervisory and control bodies: Personal Data being processed for such purposes are going to be stored by the corporate for the time strictly necessary to realize such purposes.

7. WHO WE CAN SHARE YOUR PERSONAL DATA WITH

Without prejudice to communications made in compliance with legal obligations, your Personal Data may be accessed by Company’s duly authorized employees and by external suppliers appointed, where necessary, as data processors, including all IT suppliers involved in the provision of the services offered by the Website (including but not limited to those who provide payment gateways for orders placed through the Website, etc.). Please contact us at the following email address: privacy.uk@sduko.com if you wish to see the list of data processor and other entities we share data with.

8. CONTACTS

The contact details for the corporate, in its capacity as data controller, are the following:

Softell Ltd

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

Email address: privacy.uk@sduko.com

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

On certain conditions, you're entitled to request:

  1. Access to your Personal Data;
  2. a replica of the private Data you've got provided (so-called data portability);
  3. Rectification of private Data in our possession;
  4. Erasure of any Personal Data that the corporate not features a legal ground for processing
  5. Withdrawal of consent, where the processing is predicated on consent;
  6. Restriction on the way the corporate processes your Personal Data, to the extent permitted by current legislation.

Right to object: additionally to the above rights, you've got the proper to object at any time, for reasons associated with your particular situation, to the processing of private Data concerning you administered by the corporate for the pursuit of its legitimate interest.

The request for objection should be addressed to the following email: privacy.uk@sduko.com.

The exercising of the above rights is subject to certain exceptions that are intended to safeguard the general public interest (e.g. the prevention or identification of crimes) and therefore the Company’s interests. Should you wish to exercise any of the above rights, we will check that you are entitled to do so and will usually reply within one month.

If you wish, you can file a complaint with the Supervisory Authority which is responsible for the protection of personal data or refer the matter to the appropriate courts.

Last update date: April 2021