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PRIVACY POLICY

Effective: September 6, 2022

1. OVERVIEW

Wolkin, Inc. a company incorporated under the Laws of Delaware and addressed at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex (hereinafter “we”, “us”, or “our”) respect your privacy and are committed to protecting the Personal Data (as defined herein) we hold about you. If you have questions, comments, or concerns about this privacy notice (“Privacy Notice”) or our processing of Personal Data, please see the bottom of this Privacy Notice for information about how to contact us. We are the data controller of the personal data collected, and is responsible for the processing of your Personal Data.

VibeMate is a browser that provides you with a better experience to use Lovense products. This Privacy Notice explains our practices with respect to Personal Data we collect, store and process about you. This includes information we collect through, or in association with, your use of the VibeMate browser, various Lovense applications or products, including but not limited to Lovense Cam Extension, Lovense Browser, our services that we may offer from time to time via our website, or otherwise through your interactions with us (the website, our social media pages, our Lovense application, software and services, collectively the “Services”).

Please review the following to understand how we process and safeguard Personal Data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing Personal Data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

2. PERSONAL DATA WE COLLECT

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Data. To the extent this data is stored or associated with Personal Data, it will be treated as Personal Data; otherwise, the data is not subject to this Privacy Notice.

a. What Your Personal Data We Collect

The types of Personal Data we collect about you depends on your interactions with us and your use of the Services. Generally, we collect the below categories of Personal Data related to the Services from our users:

Identifiers such as a real name, alias, postal address, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information. Note: While we do not collect biometric information, if you choose to authenticate yourself through certain service providers we use, they may collect biometric information subject to their privacy policies, but we are never provided with access to that information. You explicitly agree that we collect gender information of your live streaming, which will be used to categorize your account and the content that you share so it is easier for site users to find.
Internet or other electronic network activity information, including, but not limited to, user content, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Data collected by Lovense related software and shared with this website with the data subject’s license.

We will not collect additional categories of Personal Data other than those categories listed above. If we intend to collect additional categories of Personal Data, we will provide you with a new notice at or before the time of collection. You can manage the above information in the following ways:

b. How We Use Your Personal Data

We strive to ensure that the content can be enjoyed by everyone, and to keep the content appropriate, tasteful and lawful. To do that, we collect and process your Personal Data for the following business and commercial purposes:

Developing, improving, operating, providing, predicting, or performing, including maintaining or servicing accounts, enhancing the Services and your experience with them, providing customer service, processing or fulfilling transactions, verifying your identity, and processing payments.
Communicating with you by email and text about the Services, verifying your identity, responding to support inquiries or, sharing information about the Services.
Auditing related to a current interaction with the user and concurrent transactions.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of the Services owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Services owned, manufactured, manufactured for, or controlled by us.
Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
Enforcing our Terms of Service，End User License Agreement and other usage policies.
As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will not use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.

c. How We Obtain Your Personal Data

We collect your Personal Data from the following categories of sources:

Directly from you. When you provide it to us directly to open an account and use the Services, or when you update the information in your account (see the Accessing, Modifying, Rectifying and Correcting Collected Personal Data section below for more information).
Automatically or indirectly from you. For example, through and as a result of your use of and access to the Services. We also collect IP addresses and browser types from the devices you use. This includes information we collect through, or in association with your use of the VibeMate browser, various Lovense applications, products, and software, including but not limited to Lovense Cam Extension, Lovense Browser, our services that we may offer from time to time via our website, or otherwise through your interactions with us (the Lovense applications, products, the website, our social media pages, our Lovense application, software, and services, (collectively the “Services”). We also collect IP addresses and browser types from the devices you use.
From our service providers.

d. Legal Bases for Processing

We process Personal Data for, or based on, one or more of the following legal bases:

Performance of a Contract. By using the Services, you have contracted with us through the Terms of Service,End User License Agreement or others listed in our Services, and we will process certain Personal Data to perform under that contract.
Legitimate Interests. We may process Personal Data for our legitimate interests, including complying with any applicable law, rule or regulation, investigation or remedy; enforcing our Terms of Service, End User License Agreement or other contracts binding with you for your using our Service; protecting our, our users' or others' rights, property and safety; and detecting and resolving any fraud or security concerns.
Compliance with Legal Obligations and Protection of Individuals. We may process Personal Data to comply with our legal obligations, including as required by valid legal process, governmental request, and to protect those individuals who use our Services and others.

e. Who We Share Your Personal Data With

We share Personal Data with the following categories of third parties:

Our service providers.
Our affiliated entities.
Government agencies or regulators when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.

f. Personal Data We Share

We may share with the following categories of third parties the following categories of Personal Data for a business purpose:

Identifiers (e.g. name, address, email address, IP address): Service providers.
Identifiers (e.g. account name, gender): Other users of the Services.
Personal information categories listed in the California Customer Records statute (e.g. bank account numbers): Service providers.
Audio, electronic, visual, thermal, olfactory, or similar information (e.g. content you create): Service providers, Other users of the Services.

g. Automated individual decision making

In order to secure transactions made on our websites / applications / devices and protect them against fraud and embezzlement, we use a solution developed by a third-party provider.

The fraud detection solution is based in particular on the following methods: simple comparisons, association rules, clustering, prediction and detection of outliers using intelligent agents, data fusion techniques and various data mining techniques.

This fraud detection method can be completely automated or can involve human intervention in which the final decision is made by a person. In all cases, we take all reasonable precautions and guarantees to limit access to your Personal Data.

Due to automatic fraud detection, (i) there may be a delay in processing your order / request while we are reviewing your transaction; and (ii) you may find yourself excluded from benefiting from a service or access to the service may be limited if a risk of fraud is detected. You have the right to access the information on which our decision is based. See the “Your Rights and Choices” section below.

h. Profiling

When we send or display personalized communications or content, we may use certain techniques known as “profiling” (defined as any form of automated processing of Personal Data consisting of using this Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict elements concerning the personal preferences, interests, financial situation, behavior, location, health, reliability, or movements of this natural person). This means that we may collect Personal Data about you in the different scenarios mentioned in the table above.

Based on this analysis, we send or display communications and / or content tailored to your interests / needs.

You have the right in certain circumstances to object to the use of your data for "profiling" purposes. See the “Your Rights and Choices” section below.

3. YOUR RIGHTS REGARDING PERSONAL DATA

You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you.

Your rights vary depending on the laws that apply to you, but may include:

The right to know whether, and for what purposes, we process your Personal Data;
The right to be informed about the Personal Data we collect and/or process about you;
The right to learn the source of Personal Data about you we process;
The right to access, modify, and correct Personal Data about you (see the “Accessing, Modifying, Rectifying, and Correcting Collected Personal Data” section below for more information);
The right to know with whom we have shared your Personal Data with, for what purposes, and what Personal Data has been shared (including whether Personal Data was disclosed to third parties for their own direct marketing purposes);
The right to withdraw your consent, where processing of Personal Data is based on your consent; and
The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

a. Accessing, Modifying, Rectifying, and Correcting Collected Personal Data

We strive to maintain the accuracy of any Personal Data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us. Any updates or corrections to your information may be made through your account settings.

If you wish to access, review, or make any changes to Personal Data you have provided to us through the Services, please contact us at the information provided at the end of this Privacy Notice. We reserve the right to deny access as permitted or required by applicable law.

Your rights	What it means
The right to be informed	You have the right to obtain clear, transparent, understandable and easily accessible information on how we use your Personal Data and on your rights, including a Personal Data breach that results in, or is likely to result in, significant harm to an affected individual or is, or is likely to be, of a significant scale. This is the reason why we are providing you with the information in this Privacy Notice.
The right of access	You have the right to access the Personal Data we hold about you (subject to certain restrictions). We may require payment of a reasonable fee taking into account the administrative costs incurred in providing the information which the written estimate of fee will be provided. Any request to access that is for information that cannot be found, trivial or that is otherwise frivolous or vexatious will not be addressed. To exercise your right of access, please contact us using the contact details below.
The right to rectification	You have the right to demand that your Personal Data be rectified if they are inaccurate or out of date and / or completed if they are incomplete. To exercise your right to rectification, please contact us at the contact details below. If you have an account, it may be easier to modify your own data via the "My Account" function.
The right to erasure / right to be forgotten	In certain cases, you have the right to obtain the erasure or deletion of your Personal Data. This is not an absolute right, as we may be required to keep your Personal Data for legal or legitimate reasons. If you would like us to erase your data, please contact us using the contact details below.
The right to oppose commercial prospecting, including profiling	You can unsubscribe or oppose the receipt of our commercial prospecting messages at any time. Simply click on the "unsubscribe" link in any email or communication we send you. You can also contact us using the contact details below. If you wish to object to profiling, please contact us using the contact details below.
The right to withdraw consent at any time for data processing based on consent	You can withdraw your consent to the processing of your data if this processing is based on consent. The withdrawal of this consent does not affect the lawfulness of the processing based on the consent made before the withdrawal thereof. We invite you to consult the table inserted in the section " PERSONAL DATA WE COLLECT", and in particular subsection d “Legal Bases for Processing” to find out if our processing is based on consent. If you wish to withdraw your consent, please contact us using the contact details below.
The right to object to data processing based on legitimate interest	You can object to the processing of your data at any time when the processing is based on legitimate interest. We invite you to consult the table inserted in the section " PERSONAL DATA WE COLLECT", and in particular subsection d “Legal Bases for Processing” to find out whether our processing is based on legitimate interest. If you wish to exercise your right to object, please contact us at the contact details below.
The right to lodge a complaint with a supervisory authority	You have the right to lodge a complaint and lodge a complaint with the data protection authority of your country to challenge Wolkin's practices in terms of protection of Personal Data and respect for privacy. We invite you to contact us at the contact details below before submitting any complaint to the competent data protection authority.
The right to data portability	You have the right to move, copy or transmit the data concerning you from our database to another. This only applies to the data you have provided, where the processing is based on your consent or on a contract and is carried out using automated processes. We invite you to consult the table inserted in the section " PERSONAL DATA WE COLLECT", and in particular subsection d “Legal Bases for Processing” to find out whether our processing is based on a contract or on consent. For more information, please contact us using the contact details below.
The right to restriction of processing	You have the right to request the limitation of the processing that we carry out on the data concerning you. This right means that the processing of data concerning you which we carry out is limited, so that we can keep this data, but not use or process it. This right applies in specific circumstances provided for by the General Data Protection Regulations, namely: the accuracy of the Personal Data is contested by the data subject (i.e. you), for a period allowing the controller to verify the accuracy of the Personal Data; the processing is unlawful and the data subject (i.e. you) opposes their erasure and instead demands that their use be restricted; the controller (i.e. VibeMate) no longer needs the Personal Data for the purposes of the processing but these are still necessary for the data subject to the establishment, exercise or defense of legal rights; the data subject (i.e. you) has objected to the processing based on the legitimate interests pursued by the controller during the verification as to whether the legitimate reasons pursued by the controller prevail on those of the person concerned. If you wish to obtain restriction of processing, please contact us at the contact details below.
The right to deactivate cookies	You have the right to deactivate Cookies. Internet browser settings are usually set to accept cookies by default, but you can easily change this by changing your browser settings. Many cookies are used to improve the ergonomics and operation of websites / applications, therefore disabling cookies may prevent you from using certain parts of this site, as explained in the corresponding cookie table. If you wish to restrict or block all cookies that are placed by our websites / applications (which may prevent you from using certain parts of the site), or by other websites / applications, you can do so by going to in your browser settings. The Help function of your browser tells you what to do. For more information, you can consult the following link: https://www.aboutcookies.org/

4. YOUR CHOICES

You have choices about certain information we collect about you, how we communicate with you, and how we process certain Personal Data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.

a. Communications Opt-Out. You may opt out of receiving email communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Notice, or by changing your notification preferences in account setting. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email. Note, that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).

b. Location Information. If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.

c. Cookies and Web Tracking. Consult our Cookie Notice for more information about how to control and/or opt out of certain web tracking technologies.

5. PROTECTING PERSONAL DATA

We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of Personal Data. Those safeguards include: (i) the encryption of Personal Data where we deem appropriate; (ii) taking steps to ensure Personal Data is backed up and remains available in the event of a security incident; (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards; and (iv) permitting only the authorised personnel to access the Personal Data on a need to know basis.

However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

If we have reason to believe that there is a breach affecting Personal Data in our possession or under our control has occurred, we will conduct, in a reasonable and expeditious manner, an assessment of whether the breach of Personal Data will result in significant harm to you and if so, we will notify you.

6. RETENTION OF PERSONAL DATA.

We keep your Personal Data only as long as necessary to fulfill the purpose for which we hold the data, in order to meet your needs or to fulfill our legal obligations.

To establish the retention period of your data, we apply the following criteria:

If you buy products and services, we keep your Personal Data for the duration of our contractual relationship;
If you participate in a promotional offer, we keep your Personal Data for the duration of the relevant promotional offer;
If you contact us in connection with a request, we keep your Personal Data for as long as necessary to process your request;
If you create an account, we keep your Personal Data until you ask us to delete it or after a period of inactivity (no active interaction with brands) defined in accordance with the regulations. and instructions at the local level;
If you have consented to receive commercial prospecting messages, we keep your Personal Data until you unsubscribe or until you ask us to delete them or at the end of a period inactivity (no active interaction with brands) defined in accordance with local regulations and instructions;
If cookies are placed on your computer/MT, we only keep your data for as long as necessary to fulfill its purpose (e.g. for the duration of a session for shopping cart cookies or session ID cookies.) and for any period defined in accordance with local regulations and instructions.

We may retain certain Personal Data in order to fulfill our legal or regulatory obligations, and in order to enable us to exercise our rights (e.g, file an appeal in any court) or for statistical or historical purposes.

When we no longer need to use your Personal Data, we erase it from our systems and files or anonymize it so that it no longer identifies you.

7. OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES.

a. Payment Information. Payments on this website (if there is any) are processed by our third party payment providers. For example, when you make a payment that is processed by a payment provider, you will provide that third party with your credit card number, credit card expiration date, and security code, which they process and store subject to their privacy policy and terms of service. We do not receive your full credit card number, credit card expiration date, or the security code. Instead, the payment provider provides us with a “token” that represents your account, your card’s expiration date, card type and the first two and last four digits of your card number. If you are required to provide your name and email address to the payment provider, then they also provide us with that information.

b. Collection of Personal Data from Children. Our Services are not intended for anyone under 18. Anyone under 18 years of age is not permitted to use the Services, and we do not knowingly collect information from children under the age of 18. By using the Services, you represent that you are 18 years of age or older.

c. Third-Party Websites and Services. As a convenience, we may reference or provide links to third- party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business (including, but not limited to, our service providers). When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies for such third-party services for information about how they collect, use, and process Personal Data.

d. Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third- party acquirers and may be among those assets transferred.

e. Do Not Track. We currently do not use any cross-site tracking technologies and do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms. Note, however, that you may find information about how to block or reject certain tracking technologies in our Cookie Notice.

f. International Use. Your Personal Data may be stored, processed, transferred into or out of the United States. By your use of the Services, you acknowledge that we will transfer your data to, and store your Personal Data in, the above countries, which the protection of such Personal Data given is of a standard comparable to the protection under the applicable personal data protection laws of your country. Such Personal Data may also become accessible as permitted by law in the above countries, including to law enforcement and/or national security authorities in those countries.

8. MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Notice, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.

9. APPLICABILITY OF THIS PRIVACY NOTICE

This Privacy Notice is subject to the Terms of Service，End User License Agreement or the contracts that govern your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services. This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

10. ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this Privacy Notice and/or how we process Personal Data, please contact us at [email protected]. In addition, we have appointed a data protection officer (“DPO”) who is responsible for, among other things, responding to questions, requests, and concerns in relation to this Privacy Notice and our use of Personal Data. You may contact the DPO as follows: Data Protection Officer [email protected]