Privacy Notice

Introduction

Nektun Limited, with registered offices located at Kallitheas 27, Flat/Office 001, 2313 Nicosia, Cyprus, referred to as “we,“ “us,“ or “our,“ operates www.sex.com website (hereinafter the “Website“) and its associated services (collectively referred to as the “Services“). This privacy notice (the “Privacy Notice”) explains our practices regarding the collection, use, and disclosure of information that we receive through our Services and/or Website as data controllers.

Your access to and use of the Services signifies your acknowledgment to our Privacy Notice and its terms. We are committed to respecting your privacy and safeguarding your personal data.

For questions about our privacy practices, please contact us (you will find our contact details at the end of this Privacy Notice).

Scope

This Privacy Notice applies to personal information we collect through our Services, encompassing:

Information collected on our Website and email communications related to the Website (e.g. when you create an account via our Website).
Information gathered through our mobile applications providing non-browser-based interaction.
Data collected when you interact with our ads and cookies on third-party websites that link to our Website and/or this Privacy Notice.

Information We collect and how We collect it

We gather various types of information, including information that may personally identify you. We collect this information:

Directly from you when you provide it (e.g. your name, email, address, pictures, etc when registering an account via our Website).
Automatically as you navigate through the Website (even if you don’t have an account on our Website). This may include usage details, confirmation that you are of age to access the content of our Website, IP addresses, content you may upload on our Website, and information collected through cookies and tracking technologies.
Payment information when you are using payment methods to access to our paid Services (e.g. payment card holder, account details, etc). Please note that your credit card number is encrypted and we do not have access to this information.

Information You Provide to Us

The information we collect on or through our Services may include:

Personal details such as your name, email address, postal address, and phone number.
Details of transactions you carry out through our Services and of the fulfillment of your orders.
Your search queries on the Website.
Information you provide for a specific purpose, such as entering a contest or survey.

User Contributions

You may also provide information for publication or display on public areas of the Website or transmitted to other users of the Website or third parties. This is done at your own risk, and we cannot control the actions of third parties with whom you may choose to share your information.

Automated Technologies and Tracking

As you interact with our Website, we may automatically collect data about your equipment, browsing actions, and patterns. This includes:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection may include cookies, flash cookies, or web beacons.

Please read our Cookie Policy to know more about the use of cookies on our Website.

Use of Your Information

We use information collected about you or provided by you, including personal data, to:

Present our Website and its contents to you.
Provide you with information, products, or services you request.
Fulfill the purposes for which you provided the information.
Notify you about changes to our Website or any products or services.
Allow you to participate in interactive features on our Website.
For the management of our Services and your account.
For statistics and data analytics (statistics about users interactions on our Website, etc).
For security reasons (to protect our Website against any malicious attacks, intellectual property infringements, fraud and illegal activities and to protect your personal data).
In any other way, we may describe when you provide the information.
For any other purpose with your consent.

Legal Bases

Under data protection laws, we must have some sort of justification in order to process your personal data:

Contract Performance: We process personal data to deliver services or products you’ve requested and to operate our Website in line with our terms and any contracts with you.
Legal Obligations: We process personal data, including identifiers, to fulfill legal or regulatory obligations, such as identity verification.
Consent-Based Processing: We handle sensitive data (e.g. sexual preferences) based on your explicit consent.
Legitimate Interests: For customization of advertising, marketing, and analytics, we process personal data guided by our legitimate interests.

Disclosure of Your Information

We may disclose personal information:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business.
To any third party in order to fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including responding to any government or regulatory request.
To enforce or apply our terms of use and other agreements.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers, or others.

Transfer of personal data outside the EEA (European Economic Area)

During the course of operation and exploitation of the Website and provision of Services, your personal information may be transferred outside of the EEA to third party data processors, located in the United States and other countries, for the purposes specified in this Privacy Notice.

Should such personal data transfer take place, we would only transfer it to a country providing an equivalent level of data protection in comparison with the European Union.

For example, some countries are considered as having a similar data protection legislation than in European countries (such ‘adequacy decisions’ are taken by the European Commission) or Standard Contractual Clauses drafted and approved by the European Commission (here) can be used to apply similar obligations on the company located outside of the EEA to process the personal data in a secure way.

Your information may be transferred to another entity of our group (i.e. as a result of reorganization, restructuring, etc.) or third party (i.e. as a result of sale, merger and/or acquisition, etc.) if part or whole of the business (or related assets) is either directly or indirectly transferred or falling under the control of the new owner.

Your Rights and Choices

Under data protection legislation and subject to our own rights and obligations, you have the following rights:

Right of Access: You have the right to request access to your personal data from us, free of charge, and to obtain a copy in an accessible format.
Right of rectification: you have the right to ask us to rectify personal data that you consider to be inaccurate. You also have the right to ask us to complete your information.
Right of erasure: You have the right to ask us to delete your personal data in certain circumstances.
Right to processing restriction: you have the right to ask us to restrict the processing of your personal data in certain circumstances.
Right to object to the processing: you have the right to object to the processing of your personal data in certain circumstances.
Right to data portability: you have the right to ask us to return your data to you in an easily transferable format or, if technology permits, to transfer it directly to another service provider.

You may also have rights under the California Consumer Privacy Act (“CCPA”).

The CCPA affords you specific rights regarding your personal data, including:

Right to Information: You are entitled to ask us to reveal certain details about how we have processed your personal data in the last 12 months. This includes providing you with the exact nature of the personal data we have handled.
Right to Erasure: You can request the elimination of your personal data that we have collected and maintained. This request is subject to certain conditions as outlined in the CCPA.
Right Against Discrimination: In exercising any of your CCPA rights, rest assured we will maintain fair treatment and not impose any form of discrimination.

To exercise any of these rights, simply send us an email with a proof of your identity to the following address: legal@sex.com .

We will then do everything in our power to do what is necessary as soon as possible.

We do not sell, trade, or exchange your personal information with anyone for money.

Complaint to the supervisory authority

If you remain unsatisfied with our response, you may file a complaint with the Data Protection Authority, whose contact details are as follows:

Commissioner for Personal Data Protection (Cyprus)

15, Kypranoros Street
1061 Nicosia
P.O. Box. 23378

1682 Nicosia

Tel. +357 22 818 456

Fax +357 22 304 565

Email: commissioner@dataprotection.gov.cy

Website: http://www.dataprotection.gov.cy/

Data Security

We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

How long do We retain your personal data?

We are committed to retaining your personal data only for as long as it is necessary for the purposes for which it was collected. This means we keep your information just long enough to fulfill our obligations to you, adhere to legal and regulatory requirements, and for our legitimate business purposes.

The exact retention period for your data depends on the nature of the data and the reasons for which we are processing it. For instance, certain types of data may be kept for longer due to specific legal or regulatory obligations, such as financial records. Conversely, data that is no longer needed for its original purpose, or for legal or business reasons, is securely disposed of or anonymized.

We regularly review our data retention policies to ensure they align with current legal requirements and best practices. In cases where you have an account with us, your personal data will generally be retained until you choose to close your account, unless there is a specific legal reason for us to keep the information for a longer period. After the closure of your account, or at the end of the necessary retention period, your data will be either completely deleted or anonymized, so it can no longer be linked to you.

What is our policy on data concerning minors?

Our Website and services is absolutely not targeted to minors due to the content that is displayed and which may not be suited to them. If you learn that a minor or child has accessed provided us with their personal data without your (parental) consent, please contact us at the following address: legal@sex.com.

We will take all steps in our power to refrain as much as possible minors from accessing adult content on our Website.

Changes to Our Privacy Notice

If we change this Privacy Notice, you will be notified through our Website or by message. We recommend that you check this page regularly. The date of last update of this document is shown at the bottom of this document.

What to do in case of dispute?

Long trials do not benefit anyone. In the event of a dispute between us, we commit to give priority to dialogue and openness in the search for an amicable solution. You can also contact your local Data Protection Authority if you remain unsatisfied with our response regarding the processing of your personal data.

Contact Information

For questions or comments about this Privacy Notice and our privacy practices, contact us at: legal@sex.com

Last update : 19 December 2023