Privacy Policy

Effective Date: January 1st, 2024

OnlyFeet ("OnlyFeet" or "We") respects your privacy and is committed to protecting it through our compliance with the practices described in this privacy policy.

This policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit www.onlyfeetclub.com (our "Website"), including any data you may provide when you sign up, buy or sell products and services, post content, or use the interactive services. This policy applies to the personal data collected through our Website, regardless of the country where you are located.

This Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, plug-ins, services, social networks, or applications, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Continuing to engage with our Website after any such revisions indicates that you accept and consent to them, so please check the policy periodically for updates.

1. Data We May Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Depending on whether you are a seller or a buyer, we collect and use different types of data from and about you that we have grouped together as follows:

• Identity Data includes legal name, username or similar identifier, social security number, government-issued photo identification, date of birth, gender, ethnicity, foot size, signed written consents, selfie photo, and voice and image (in any content that you upload or transmit).
• Contact Data includes postal address, email address, and telephone numbers.
• Location Data includes your city and state/province as voluntarily disclosed by you.
• Financial Data includes bank or other payment account and payment card details. We store only limited, if any, Financial Data. Otherwise, our payment processor stores all Financial Data, and we encourage you to review their privacy policy and contact them directly for responses to your questions.
• Transaction Data includes details about payments to and from you and other details of products and services you have bought from us or any seller through our Website or tips that you have paid to any seller through our Website.
• Technical Data includes internet protocol (IP) address, ISP name, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
• Device Data includes the type of mobile device ("Device") you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and IP address.
• Content Data includes photos, videos, audio (for example, music and other sounds), data, text (such as comments and hashtags), metadata, images, interactive features, emojis, GIFs, memes, and any other material you create, perform, or upload on or through our Website and information about the content you create, perform, or upload. Please remember that Content Data that you post or perform may reveal personal data about yourself as well, including identifying information about yourself depicted in any Content Data.
• Profile Data includes your username and password, including password hints and other information for authentication and account access, purchases made by you, your interests, preferences, feedback, and survey responses. Some information you choose to give us may be considered "special" or "sensitive" in certain jurisdictions, for example, your sex life and sexual orientation. By choosing to submit special or sensitive information, you consent to our processing of that information.
• Usage Data includes information about how you use our Website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used under this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless you voluntarily provide it. Nor do we collect any information about criminal convictions and offenses.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

2. How We Collect Data About You

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by email. This includes information you provide when you sign up; buy products or services; create a profile; interact with sellers or buyers through our Website; request marketing to be sent to you; enter a competition, promotion, or survey; or give us feedback or contact us. We may also ask you for information when you report a problem with our Website.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical and Device Data about your equipment, browsing actions, and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and Automatic Data Collection Technologies). We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please note that we do not recognize or respond to any do not track signals (DNT).
• Third parties or publicly available sources. We will receive personal data about you if you visit other websites employing our cookies or from third parties including, for example, business partners (including affiliates in any affiliate marketing program); subcontractors in technical, payment, delivery, and identity and age verification services; advertising networks; analytics providers; and search information providers. We do not collect or store your payment card details. That information is provided directly to our third-party payment processors whose use of your personal data is governed by their privacy policy. These third-party payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.
• User contributions. You also may provide Content Data for us to publish or display ("post") on public Website areas or transmit to other website users or third parties. You submit Content Data for posting and transmission to others at your own risk. Although you may set certain privacy settings for Content Data by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Website users with whom you choose to share your Content Data. Therefore, we cannot and do not guarantee that unauthorized persons will not view your Content Data.

Cookies and Automatic Data Collection Technologies

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Website may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

Our Website pages may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

3. How We Use Your Personal Data

We use your personal data to provide you with products, offer you services, communicate with you, deliver marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

• Identify you as a visitor, buyer, or seller on our Website.
• Present our Website and provide you with the information, products, services, and support that you request from us.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
• Verify your identity and age if you post content on or through our Website.
• Collect and pay money owed to you if you are a seller.
• Collect and recover money owed to us.
• Review content before publication to ensure that it is not illegal and does not otherwise violate credit card association standards.
• Monitor compliance with the Website’s legal documents or for quality assurance purposes.
• Audit related to a current interaction with the user and concurrent transactions.
• Comply with credit card association rules and standards.
• Comply with applicable law.
• Respond to your inquiries related to support or other requests.
• Fulfill the purposes for which you provided the data or that were described when it was collected.
• Deliver targeted advertising, newsletters, and other information.
• Promote your content or profile.
• Promote our Website.
• Use data analytics to improve our Website, product, services, marketing, customer relationships, and experiences.
• Notify you about changes to our Website, products, or services.
• Enable or allow you to participate in our Website's interactive, social media, or other similar features.
• Ensure that we present our Website content in the most effective manner for you and for your computer or device.
• Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• Improve our Website, products or services, marketing, or customer relationships and experiences.
• Protect our Website, employees, or operations.
• Assist law enforcement and respond to subpoenas
• Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

We may also use personal data to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your data in this way, please adjust your user preferences in your account profile or email us at privacy@onlyfeetclub.com. For more information, see Your Personal Data Use Choices.

We may use personal data to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may use nonpersonal data for any business purpose.

4. Disclosure Of Your Personal Data

We may share your personal data with:

• Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
• Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business. Examples include analytics and search engine providers that assist us with Website improvement and optimization, payment processing providers that assist us in processing payments, vendors that specialize in the validation of government identification to verify your identity and age, email delivery providers, hosting service providers, customer service providers, and marketing efforts. We may allow selected third parties to use tracking technology on our Website, which will enable them to collect data about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use Google Analytics to help us understand how our customers use our Website (you can read more about how Google uses your personal data here: https://policies.google.com/privacy). You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
• To fulfill the purpose for which you provide it.
• For any other purposes that we disclose when you provide the data.
• With your consent.

We may also disclose your personal data to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of that business or assets.
• To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
• 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 Service or Seller Agreement and other agreements.
• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for cybersecurity, fraud protection, and credit risk reduction purposes.

We may share nonpersonal data without restriction.

5. Consent to Personal Data Transfer

We are based in the European Union. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. If you are located outside the European Union, your personal data may at times be accessible by persons who are located worldwide including in countries that the European Commission or other geopolitical regions have not determined to provide the same adequate level of data protection in your country, province territory, or geopolitical region.

By submitting your personal data or engaging with our Website, you consent to this transfer, storing, or processing, including the transfer of your data across international boundaries to jurisdictions anywhere in the world as permitted by applicable law.

6. Your Personal Data Use Choices

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your data:

• Promotional Offers from OnlyFeet. If you do not wish to have your Contact Data used by OnlyFeet to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (e.g., the registration form) or by sending us an email stating your request to privacy@onlyfeetclub.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to OnlyFeet as a result of a purchase, service experience, or other transactions.
• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookies and Automatic Data Collection Technologies.

We do not control third parties' collection or use of your information to serve interest-based advertising. But these third parties may provide you with ways to choose not to have your information collected or used in this way.

Our Website may, from time to time, have links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

7. Accessing and Correcting Your Personal Data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes. You have the right to request access to and to correct the personal data that we hold about you.

You can access, review, and change your personal data by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of (if allowed by the law of your jurisdiction) your personal data, you may also send us an email at privacy@onlyfeetclub.com to request access to, correct, or delete any personal data that you have provided to us. In some circumstances, we cannot delete your personal data except by also deleting your user account. We will not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal data, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous under our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you delete your Content Data from the Website, copies of your Content Data may remain viewable in cached and archived pages or because other Website users might have copied or stored them. Our Terms-of-Service Agreement governs proper access and use of information provided on our Website, including Content Data.

8. Data Security

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers employing security protections. We encrypt any payment transactions using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

9. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use that anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

10. Withdrawing Your Consent

Where you have given your consent to the collection, use, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, you may contact us at privacy@onlyfeetclub.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

11. Children's Online Privacy

We do not direct our Website to minors, and we do not knowingly collect personal data from individuals under 18-years old. If we learn we have mistakenly or unintentionally collected or received personal data from an individual under 18-years old, we will delete it. If you believe we mistakenly or unintentionally collected data from or about an individual under 18-years old, please contact us at privacy@onlyfeetclub.com.

12. Do Not Track Policy

Do Not Track ("DNT") is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we give you the ability to opt-out. But our Website does not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information about DNT, visit www.allaboutdnt.com.

13. Legal Basis for Processing

We may process your personal data because you have given us permission to do so (e.g., by sending data through our Website's contact or signup forms), because the processing is in our legitimate interests and it is not overridden by your rights, or because we need to process your personal data to perform a contract with you or comply with the law.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws concerning your personal data. Your rights may include the following:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
• Request restriction of processingyour personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@onlyfeetclub.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will let you know and keep you updated.

14. Changes To Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal data, we will notify you by email to the email address specified in your account or through a notice on our Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

15. Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at privacy@onlyfeetclub.com. We have procedures in place to receive and respond to complaints or inquiries about our handing of personal data, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy, please contact us.