Privacy policy

1. WHO WE ARE

The company SOFYAN LIMITED (hereinafter 'Sofyan' or the 'Company'), with registered office in Amathus Avenue 42, 4532 Agios Tychonas, Limassol, Cyprus, Registration Number: HE 445193, in its capacity as data controller with regard to personal data collected on the adult website Skokka.com (hereinafter also referred to as the 'Website'), 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.

Before using the Website, please read this Privacy Policy carefully. The Company recommends to regularly check this policy to get the latest version.
In the event of significant changes, the Company will inform the user also via e-mail with reasonable notice.

2. WHICH PERSONAL DATA MAY BE COLLECTED

The following categories of personal data relating to you, which you voluntarily provide, may be collected by the Company in the performance of its activities (the term 'Personal data' shall mean all the categories listed below, jointly considered):

Contact details: information about your name, surname, telephone number, email address;
Payment data: information about the purchase you have made and the payment (e.g. credit/debit card number);
Other personal data: information about your gender, age, photograph(s), as well as other data you may provide spontaneously while browsing the Website;
Special categories of personal data: information that may be related to your lifestyle and sexual behavior;
Use of the website: IP address, User Agent and information acquired via cookies (see our Cookie Policy which regulates the details).

3. HOW WE COLLECT YOUR PERSONAL DATA

The Company collects and processes your Personal Data in the following circumstances:

If you register to the Website in order to use all of its functions;
If you publish an advertisement on the Website or reply to an advertisement.

If you provide Personal Data on behalf of someone else, you must first ensure they have read this Privacy Policy.
The Company recommends you to keep your Personal Data up to date. If there are any changes, 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 USED FOR

The Company may process your Personal Data for one or more of the following purposes, in accordance with the legal basis:

Purposes strictly related to accessing and browsing the Website, including registration to the Website.
The Company may process your Contact details and Other personal data to allow you to access, browse or register to the Website.
Legal basis for processing: performance of a contract.
Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the Company from giving you access to the Website and/or to allow you to register.
Publication of and possible response to advertisements.
The Company may process your Contact details (in particular, your email) to allow you to publish or reply to an advertisement.
Legal basis for processing: performance of a contract.
Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the Company from letting you publish or reply to an advertisement.

The Company may also process for the same purpose your photograph, as well as Special categories of personal data.
Legal basis for processing: consent, that 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 provide consent will not prevent you from publishing or replying to an advertisement. Consent may be withdrawn at any time by sending an email at the following address privacy.uk@skokka.com. Any withdrawal will not affect the processing carried out before such withdrawal.
Fulfillment of orders formulated through the Website and activities related to 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 fulfilment of the legal obligations connected to such contract.
The provision of such data is mandatory to process your order; otherwise we will not be able to process it.
Marketing purposes to meet your needs or to inform you of promotions.
The Company may process your Personal Data for marketing and advertising purposes, to inform you of promotional sales initiatives via automated contact methods (email, SMS and 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 limits of such consent declaration.
Legal basis for processing: consent. The consent is optional. Failure to provide consent will not have any contractual consequences.
Consent may be withdrawn at any time by sending an email at the following address privacy.uk@skokka.com or via this link.
Market and statistical research to improve the service.
The Company may process your Contact details to analyze and improve its services for a better customer satisfaction.
Legal basis for processing: legitimate interest of the Company in verifying and improving its services.
Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the Company from carrying out market and statistical researches to improve its services.

However, you may object, at any time, to the processing of your Contact details for the above purpose. The request for objection can be made by sending an email at the following address privacy.uk@skokka.com.
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 its rights or act or even claim anything against you or any third party.
Legal basis for processing: legitimate interest of the Company to defend its rights in court.
Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the Company from defending its rights.
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 fulfill the obligations which it is subject to.
Legal bases for processing: legal obligation.
Providing your Personal Data for such purpose is mandatory; failure thereof would prevent the Company from complying with specific legal obligations.
In no case, we do collect, store, or transfer data from your card. The payment operations are carried out entirely through the secure server of the payment gateway(s) and/or payment processor(s). SOFYAN LIMITED will not sell, purchase, provide, exchange or in any other manner disclose Account or Transaction data, or personal information of or about a Cardholder to anyone, except, its Acquirer, Card networks/associations or in response to valid government demands.

5. HOW WE KEEP YOUR PERSONAL DATA SAFE

The Company uses a wide range of security measures to improve protection and maintain the security, 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 may be accessed and used based on our standards and our security policies (or equivalent standards for our suppliers).

6. HOW LONG DO WE STORE YOUR INFORMATION FOR

The Company will keep your Personal Data only for the time necessary to achieve the purposes for which they were collected or for any other related and lawful purpose.
Therefore, if Personal Data is processed for two different purposes, we will store such Personal Data until the processing purpose with the longest term ends; however, we will no longer process Personal Data for the purpose for which the retention period has expired.
When your Personal Data are no longer required, or when there is no longer any legal basis for storing them, they will be irreversibly anonymized or securely destroyed.

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

Purposes strictly related to accessing and browsing the Website, including 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 and in any case no later than 2 years after your last access to the Website. We keep the last 2 years worth of server log files.
Publication of and possible reply to advertisements: Personal Data being processed for such purpose will be stored by the Company no later than 1 year after the publication of the advertisement.
Fulfillment of orders formulated through the Website and activities related to order management: Personal Data processed to fulfill any contractual obligation may be stored for the entire duration of the contract, and following termination of the contractual relationship no later than the next 10 years.
Marketing to meet your needs or to inform you of promotions: Personal Data being processed for such purpose will be stored by the Company for 2 years from the date of their collection for this purpose (except in the event that you previously withdrew your consent).
Market and statistical research in order to improve the service: Personal Data being processed for such purpose will be stored by the Company for 2 years from their collection.
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: Personal Data being processed for such purpose will be stored by the Company for the time strictly necessary to achieve such purpose.
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: 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

Without prejudice to communications made in compliance with legal obligations, your Personal Data may be accessed by Company’s duly authorised 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@skokka.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 Company, in its capacity as data controller, are the following:
SOFYAN LIMITED
registered office in Amathus Avenue 42, 4532 Agios Tychonas, Limassol, Cyprus, Registration Number: HE 445193
Email address: privacy.uk@skokka.com

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

On certain conditions, you are entitled to request:

access to your Personal Data;
a copy of the Personal Data you have provided (so-called data portability);
rectification of Personal Data in our possession;
erasure of any Personal Data for which the Company no longer has a legal ground for processing;
withdrawal of consent, where the processing is based on consent;
restriction on the way the Company processes your Personal Data, to the extent permitted by current legislation.

Right to object: In addition to the above rights, you have the right to object at any time, for reasons related to your particular situation, to the processing of Personal Data concerning you carried out by the Company for the pursuit of its legitimate interest.

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

The exercising of the above rights is subject to certain exceptions that are intended to safeguard the public interest (e.g. the prevention or identification of crimes) and 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: June 2020