Welcome to Sofia Gray, the largest used panties marketplace! Privacy Policy

Users' privacy and data protection rights are critically important to us and we recognize the importance of protecting the personal information we collect about you.

Please read Sofia Gray‘s privacy policy carefully before browsing www.sofiagray.com or using our services as it describes how JOA Enterprise Ltd, an UK company with head office at 152 - 160 City Road, London, EC1V 2NX, collects, uses, stores and discloses data on our Website and any apps, applications, features or online services that are owned or controlled by us.

Terms and Conditions are provided in a separate page of our Website. You can read our Terms and Conditions which govern your use of our Website and Service here. The capitalized terms used within this page have the same meanings as those mentioned in the “Definition” section of Terms and Conditions page, unless otherwise mentioned in this Privacy Policy.

By choosing to use our Website and Service, we consider it to be your freely given agreement on our policy, stated within this page.

Applicability

This Privacy Policy explains how we process our users' personal information, where Sofia Gray is the Data Controller.

Our Website may contain information about or links to other websites that are outside our custody and/or control. We have no control over, and assume no responsibility for the Content, Privacy policies or practices of any Third-Party Websites, products or services. Please note that this Privacy Policy applies only to Sofia Gray. Thus, we urge our users to carefully read and review the privacy policies of each of those websites to get an understanding of how your information is being used and shared by those Third-Party Websites.

Information we collect

We collect and use your personal information only according to Applicable Laws. We do not want nor is our intention to solicit and knowingly collect personal information of individuals under the legal age as set in their place of residence. The Website, Service and Content are not intended for children or adolescents under the legal age If you are below the legal age, you are forbidden to use the Website and the Service.

This section describes the purposes for which personal information are collected by Sofia Gray:

Cookies

We may automatically collect technical information when you visit our Website or use our Service. We may use these technologies to analyze how you use our services, to improve how our website works, to save your log-in information for future sessions, and to serve you with advertisements that may interest you.

The technology used to collect information automatically from our users include cookies. Cookies are small text files, containing small amounts of information, that are served by our platform and stored on your device (computer, mobile device, or other devices) to uniquely identifying your browser when you visit our Website.

Our Website uses cookies dropped by us or third parties for a variety of purposes. Cookies can be recognized by the website that downloaded them or other websites that use the same cookies. This helps websites know if the browsing device has visited them before.

This information may include, among other information, the browser and operating system you are using, IP address or other unique device identifier, the URL or advertisement that referred you to our services, search terms and areas within our platform that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, and other information commonly shared when browsers communicate with websites.

Cookies are used to provide, improve, protect and promote our Services. For example, cookies help us with things like remembering your username for your next visit so you can log in faster, understanding how you are interacting with our services (e.g., the pages you view, the links you click and other actions you take on our Service), to enhance your navigation through the Website, and allowing us or our business partners to track your usage of the Service over time to improve them based on that information. Cookies can also help ensure adds you see online are more relevant to you and your interests.

The use of cookies does not involve personal data request and, in most cases, does not identify the users personally.

We use this personal information to support our legitimate interests in maintaining and improving our services, understanding how our services are used, optimizing our marketing and advertising services, customer service and support, and protecting and securing our visitors, our clients, ourselves and our Services.

Buyer user account

When you sign up to our Services or sign into your account to use the Service, we will collect your personal information such as nickname, email address and account password, messages with Sellers and membership order history. Although not required, you may choose to add a profile picture where you can show as little or as much as you want from you, or not at all.

You may choose not to share with us the above personal information, which is just fine with us. If you decide not to provide us the nickname, email address and a selected personal password, we will not be able to create your account on our Website.

We use this personal information as necessary for the performance of our Service or to take steps prior to providing our Services. We are collecting and using your profile picture based on your active consent. By expressing your consent, you agree that we may collect, use, disclose, process and transfer your personal information, in accordance with this Privacy Policy.

Seller user account

When you sign up to our Services or sign into your account to use the Service, we will collect your personal information such as email address and account password, shop name and your brief description, sex, ethnicity, size, age category, country and profile photos where you can show as little or as much as you want from you, or not at all. You may choose to answer to questions in the Interview Section, but it's up to you what questions you answer and how. Same, you may choose to add photos of yourself in the Private Gallery Section showing as little or as much as you want from yourself. When adding products to your store, we will collect the product picture, product name, product description & keywords, product color, product scent and product price. We will also collect messages with Buyers and membership order history.

You may choose not to share with us the above personal information, which is just fine with us. If you decide not to provide us this information, we won't be able to create your account or provide you access to our Service. Not providing details about your products will result in our impossibility to upload details about your product on the Website or promote it. By choosing not to provide details about yourself, like private photo gallery or answering interview questions, will not attract Buyers' high interest in your profile and products and your sales will be disappointingly low for you.

We use this personal information as necessary for the performance of our Service or to take steps prior to providing our Services. We are collecting and using your profile picture/s, interview questionnaire, private gallery photos and products' information based on your active consent. By expressing your consent, you agree that we may collect, use, disclose, process and transfer your personal information, in accordance with this Privacy Policy.

Payments

When you purchase membership/s to our Services, we will collect payment information such as membership plan, payed amount, and other related payment information. We use third parties to process subscription payments. We will never collect, store or archive your credit card details.

You may choose not to reveal your credit card details to our third-party payment processors or share with us the above information. If you decide this, you will not be able to buy the membership for your account.

We use this personal information as necessary for the performance of our Service or to take steps prior to providing our Services.

Support Services

When you write to our support team, we will collect personal information such as your nickname or name, email address, subject, message and any other necessary details to provide you with a swift solution to your request.

You may choose not to share with us description details of your issue, or any of the above personal information, but for such case we will not be able to solve your request or come up with a solution to your problem.

We use this personal information as necessary for the performance of our Service or to take steps prior to providing our Services and to support our legitimate interests in maintaining and improving our services, understanding how our services are used and optimizing our customer service and support.

How we use collected information

We use your personal information for various purposes, including, but not limited to:

  • Provide, update and improve your access to our Website and Services;
  • Maintain, improve, customize and protect our Website's features and functionalities;
  • Billing and processing payments for our Services;
  • Measure traffic, analyze and monitor usage, trends and other activities;
  • Provide security and monitoring, and address technical issues and bugs;
  • Provide customer service and support, respond to your requests, questions or comments;
  • Respond to your requests, questions or comments;
  • Send you Service-related communication messages, such as messages received from Buyers/Sellers;
  • Enforce legal agreements, including our Terms and Conditions and Privacy Policy.

How long we keep collected information

Your personal information will only be processed to the extent necessary and stored for no longer than is necessary. We will keep your personal information as long as you are our client and you have an active account on the Website. We may store some data in an aggregated form so that it cannot reasonably be manipulated to identify users.

Users can request to have their accounts removed from our platform and to stop using our Services permanently.

Support messages will be kept for a period of (3 months).

Under certain circumstance, we may retain your personal information for a longer time, even after you have opted out, if retention is necessary to comply with legal obligations, regulatory requirements, or to prevent fraud or abuse.

How we protect information

The security of your personal information is a top priority to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information from loss, misuse, and unauthorized access or disclosure. We limit access to personal information to employees, contractors and affiliated organizations who we believe reasonably need to retrieve that information to provide our Services. Considering the current state of technology, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect your personal information.

No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. While we use reasonable efforts to protect your personal information against the unauthorized access, use, alteration or destruction, we cannot guarantee its absolute security.

How we share information

Sofia Gray will not rent or sell your personal information to anyone. We may employ and share your personal information to third-party companies and individuals to help us operate our business, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights. Our users should know that these third parties have access to personal information to help us and them perform the Services. However, they are subject to strict contractual confidentiality obligations equivalent as it would receive under European data privacy laws and are required not to disclose or use the information for any purpose other than providing our Services.

We may transfer personal information to them, to the extent that this is necessary, to the following categories of recipients: contract partners, subcontractors, IT service providers, software or hardware vendors, payment providers, market research companies, public authorities, court or arbitral tribunals, as well as competent authorities to investigate criminal offenses. We may also disclose personal information in response to a subpoena, court order or other governmental request.

These third parties can be within European Union and/or European Economic Area. If they are located outside the European Union and the European Economic Area, including countries that are not recognized as providing an adequate level of protection, the transfer of personal information shall be made only if adequate safeguards are in place, in accordance with Applicable Law. For that, we rely on several safeguards, such as standard contractual clauses issued by the European Commission. Upon request, you can receive from us a list of third parties from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of personal information.

You may decide to use third parties' solutions in connection to our Services. For this case, we will share or disclose your personal information to your chosen third parties' solutions. Please note that we are not responsible for the privacy and security practices of the selected third parties' solutions.

The Seller profile you create on our Website will be publicly visible to any user.

Children's and adolescent's information

Our Website, Service and Content are not intended for children or adolescents under the legal age. You must have reached the legal age as set in your place of residence to use the Website and the Service. We do not want nor is our intention to solicit and knowingly collect personal information for this type of audience.

If you are under the legal age, you are not allowed to register for an account and use Services or send any personal information about yourself to us. In the event that we confirm that we have collected personal information from a child or adolescent under the legal age, we will delete that information as soon as possible. If you believe that we might have any information from or about a child or adolescent under the legal age, please contact us immediately at [email protected]

Your rights towards collected information

Considering your place of residence, under the Applicable Law, you may have certain rights in respect to the personal information we hold about you, including:

Your rights under General Data Protection Regulation (GDPR) in place in EEA

Right of access: You have the right to obtain confirmation as to whether your personal information is processed by us, as well as information on the specific nature of the processing.

Right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

Right to erasure (right to be forgotten): You have the right to request the erasure of your personal information, under certain conditions.

Right to restriction of processing: You have the right to request the restriction of processing your personal information, under certain conditions.

Right to data portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit them to another controller, under certain conditions.

Right to object: You have the right to object to processing your personal information by us, under certain conditions.

Right to oppose to receiving marketing messages: You have the right to oppose the processing of your personal information with the purpose of sending marketing and promotion messages.

Withdrawal of consent: As far as we are processing your personal information based on your consent, you may at any time revoke or change your consent, free of charge, without affecting the consent-based processing of your personal information before its withdrawal. The personal information collected on your consent will be kept until its withdrawal.

Right to lodge a complaint with a Supervisory Authority: If you believe that your data protection and privacy rights have been infringed by us in any way, you may contact the relevant Data Protection Supervisory Authority in your place of residence. In UK, the Supervisory Authority is the Information Commissioner's Office and it can be reached at https://ico.org.uk/make-a-complaint/

Your rights under California Consumer Privacy Act (CCPA) in place in California

Right of access: You have the right to request access to and/or a copy of your personal information we hold on you.

Right to opt-out: You have the right, at any time, to direct a business that sells personal information about you to third parties not to sell your personal information. We do not engage, nor we will engage in selling your personal information.

Right to erasure (right to be forgotten): You have the right to request the erasure of your personal information, under certain conditions.

Right to equal services and prices: You have the right to not be discriminate because you have exercised any of your rights under CCPA, including, but not limited to denying good or services, charging different prices or rates, providing a different level or quality of goods or services. We will never discriminate against you for the exercise of your rights.

Right to oppose to receiving marketing messages: You have the right to oppose the processing of your personal information with the purpose of sending marketing and promotion messages.

Your rights under Personal Information Protection and Electronic Documents Act (PIPEDA) in place in Canada

Right of access: You have the right to obtain confirmation from us as to whether we keep, use and disclose your personal information.

Right to correct the data: You have the right to challenge the accuracy and completeness of the personal information we hold on you, and to have the information amended. Where appropriate, you also have the right to have the amended information sent on to any third parties to whom we may have disclosed the original information.

Withdrawal of consent and opt-out from use or disclosure of data: You may at any time revoke or change your consent, free of charge, without affecting the consent-based processing of your personal information before its withdrawal. You may also opt-out from any use of your personal data or from transfer or disclosure of your personal data to any their parties. This apply under certain conditions.

Right to lodge a complaint with a Supervisory Authority: If you believe that your data protection and privacy rights have been infringed by us in any way, you may contact the relevant Data Protection Supervisory Authority in your place of residence. In Canada, the Supervisory Authority is the Office of the Privacy Commissioner of Canada and it can be reached at https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/file-a-complaint-about-a-business/

Your rights under Privacy Act in place in Australia

Right of access: You have the right to obtain confirmation from us as to whether we keep, use and disclose your personal information, and why. This apply under certain conditions.

Right to correct your information: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

Right to use a pseudonym: You have the option of not identifying yourself, or of using a pseudonym in certain circumstances.

Right to oppose to receiving marketing messages: You have the right to oppose the processing of your personal information with the purpose of sending marketing and promotion messages.

Right to lodge a complaint with a Supervisory Authority: If you believe that your data protection and privacy rights have been infringed by us in any way, you may contact the relevant Data Protection Supervisory Authority in your place of residence. In Australia, the Supervisory Authority is the Office of the Australian Information Commissioner and it can be reached at https://www.oaic.gov.au/privacy/privacy-complaints/

Changes to Privacy Policy terms

Users can always review the most current version of the Privacy Policy posted on this page. We solely have the right, at our own discretion, to change, replace or update any part of these Privacy Policy. It is the responsibility of users to periodically check our Privacy Policy for amendments. Any changes to this policy will be effective upon posting on the Website, except the changes where your consent is expressly needed, which case the changes will apply from the date of your consent.

We may also notify you by email, at our discretion, with a service-related message.

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, the information we hold on you, or you would like to exercise one of your above data protection rights, you can contact us free of charge at [email protected] We will respond to your request as soon as possible, but not later than 30 days.

JOA Enterprise LTD
152 - 160 City Road, London, EC1V 2NX