PRIVACY POLICY

Last Updated April 2019

Neottolemo LDA (the “Site”, "we" or "us") is committed to protecting your privacy. Where we hold data from which you can be personally identified (Personal Information) we will only collect, use, disclose and store such Personal Information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and this Privacy Policy. 

Neottolemo LDA is located at Rua Dr. Brito Camar, n. 20, 1 Andar, Freguesia da Sè, 9000-039 Funchal, Madeira, Portugal for the purposes of any questions or requests with respect to your Personal Information, our use of it and this Privacy Policy.

 

This Privacy Policy together with the Terms of Use at https://au.skokka.com/terms_of_use/ and any other documents referred to in it set out the basis on which we will hold and process your Personal Information.  By using this Site or our Services you consent to the collection, use and disclosure of Personal Information on the terms outlined in this Privacy Policy.

Please note that when you contact any Offeror Users (as described in the Terms of Use), using the contact information set out in any material uploaded by the Offeror Users to the Site, we are not responsible for that data or how Offeror Users choose to process any Personal Information transferred to them. We are in no way able to control or be responsible for your Personal Information in their hands.

What Information We Collect

We collect information as submitted to us by (1) Offeror Users who wish to place advertisements or create profiles on the Site; and (2) Recipient Users who wish to browse the Site and contact an Offeror User.

In respect of Offeror Users, the legal basis for the collection of Personal Information by us is that it is necessary in order to perform a contact between the Site and the Offeror User. In respect of Recipient Users, the legal basis for the collection of data is the consent of the Recipient User. Furthermore, the Site has a legitimate interest in collecting and processing data, having due regard to the rights and freedoms of the data subjects, including for the purposes of business administration and fraud prevention and compliance.

How We Collect and Use Information

  • Log Files.
    Any time you visit the Site, we gather certain information about your use of our website (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, track visitor movement in the aggregate, and gather broad demographic information for aggregate use. We do not link any of the information in our log files to any other information that would enable us to determine your actual identity. This means that a user's session will be tracked, but the user will be anonymous. We do not share your log files externally.
  • Cookies.
    We use "cookies" to keep track of some types of information while you are visiting our website or using our services. Cookies are very small files placed on your computer, and they allow us to count the number of visitors to our website and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track use so that we can continue to develop and improve our service offering.
  • Session and Persistent Cookies.
    Session cookies are temporary and will be erased after you close your browser. Persistent cookies remain on your hard drive unless you manually delete them or until expiration after a set period of time. The primary purposes of persistent cookies are to make logging in to your account an easier process and for performance analytics by us or a trusted partner. First and third party cookies may be session or persistent.
  • First Party Cookies.
    First party cookies are placed by us on your computer for a variety of purposes including website functionality, tracking length of visitor stay and number of unique visitors to the website, and evaluating the popularity of specific site offerings.

    SKOKKA.com first party cookies include: PHPSESSID Session Cookie; Last_Vhost last city visited; adult_cookie over age consent; Logged_cookie when you do log in; privacy_cookie agreed cookies on website.
  • Web Beacons.
    "Web beacons" (also known as "clear gifs" and "pixel tags") are small transparent graphic images that are often used in conjunction with cookies in order to further personalize our website for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behaviour of our customers. We do not link the web beacons to any information that would enable us to determine the actual identity of any individual.
  • Third Party Cookies.
    We only use third-party Statistic cookies. Any information that these third parties collect via cookies and beacons is anonymous and does not enable them to determine your actual identity.

    SKOKKA.com third party cookies include Google Analytics and Hotjar
  • Your Cookie Choices.
    You may choose to accept or reject cookies by changing your internet browser setting. However, we rely on cookies for the proper operation of our website and if your browser is set to reject all cookies, the website will not function properly. Users who refuse cookies assume all responsibility for any resulting loss of functionality. Click the "help" menu in your browser's toolbar for information on how to change your settings. For additional information about managing cookies, please visit https://www.allaboutcookies.org/. Keep in mind that cookies are unique to each computer. In order to opt-out of data collection by the use of cookies on any of your other devices, you will be required to repeat this process on each device.

Other Information We Collect

  • E-mails and Telephone Calls.
    We require an e-mail address from you when you register for our services.

Sensitive Information

We may also collect Sensitive Information (as that term is defined in the Privacy Act 1988 (Cth) including information about a User’s sexual orientation or practices.  Sensitive information is collected on the basis that it is reasonably necessary for our functions or activities.  Sensitive Information will only be used or disclosed for a purpose directly related to the purpose for which it was collected.  You consent to the collection and use of Sensitive Information on this basis.

Mobile Device Additional Terms

  • Mobile Device.
    If you use a mobile device to access our site or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system and version information, and IP address.
  • Geo-Location Information.
    We do not ask you for, access or track any location-based information from your mobile device at any time while downloading or using our Mobile Apps or services.

Disclosure of Your Personal Information to Third Parties

  • By using our Site or services, you acknowledge and consent to us disclosing your Personal Information in the circumstances outlined below.
  • Disclosure By Law.
    You acknowledge and agree that we may disclose information you provide if required to do so by law, or if we, in our sole discretion, believe that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law); (2) protect or defend our, or a third party's, rights or property; or (3) protect someone's health or safety, such as when harm or violence against any person (including you) is threatened.
  • Disclosure to Protect Abuse Victims.
    Notwithstanding any other provision of this privacy statement or our Terms and Conditions of Service, we reserve the right, but have no obligation, to disclose any information that you submit to the services, if in our sole opinion, we suspect or have reason to suspect, that the information involves a party who may be the victim of abuse in any form. Abuse may include, without limitation, trafficking or coercion. Information may be disclosed to authorities that we, in our sole discretion, deem appropriate to handle such disclosure. Appropriate authorities may include, without limitation, law enforcement agencies, child protection agencies, or court officials.
  • Information Transferred As a Result of Sale of Business.
    As we develop our business, we may buy or sell assets and, depending on the transaction, your Personal Information may be one of the transferred assets. In the event that we are acquired by another company, your Personal Information may be part of the assets transferred to the acquiring party. If this occurs, you will be notified if there are any material changes to the way your Personal Information is collected or used.
  • Information Transferred Overseas.
    By using our services and expressly assenting to this Privacy Policy, you have consented to the overseas transfer of your Personal Information solely for the purpose of providing you the services for which you have registered or to which you have subscribed. This includes the provision of your Personal Information to related bodies corporate, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 50 of the Corporations Act 2001 (Cth).  We take all reasonable steps to ensure that all overseas recipients will not hold, use or disclose your Personal Information inconsistently with the Australian Privacy Principles.

We will only share your information with third parties in the ways defined in this privacy statement.

Age Restrictions

This is an adult services site as set out in the Terms of Use.

Security

We have extensive security measures in place to protect the loss, misuse and alteration of the information stored in our database. These measures include the use of Secure Socket Layer (SSL) and/or strong encryption (3DES) technology during credit card transactions and administrative access to site data, as well as other proprietary security measures which are applied to all repositories and transfers of user information. We will exercise reasonable care in providing secure transmission of information between your computer and our servers, but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot ensure or warrant the security of any information transmitted to us over the Internet and hence accept no liability for any unintentional disclosure.

Links to or Access from Other Sites

We are not responsible for the privacy practices or the content of other websites that may be linked to this site or of any third party advertisers including those of Offeror Users.

Choice/Opt-Out

We generally retain your Personal Information only for so long as is necessary for the purpose for which it is used, or required by law.

Access to Personal Information

The Australian Privacy Principles gives you the right to access information held about you. Your right of access can be exercised in accordance with the Australian Privacy Principles. We will respond to all access requests within 30 days. If access is denied, we will provide you with reasons for this decision. Please use the contact details below.Access may be denied under the Australian Privacy Principles in certain prescribed circumstances, including:

  • where providing access will pose an unreasonable impact on the privacy of another individual;

  • where your request for access is frivolous or vexatious; or

  • where providing access would be unlawful, pose a threat to the life or health of an individual, may prejudice an investigation of possible unlawful activity, or may prejudice the enforcement of laws.

If access is provided to you as the result of a request, you may be charged a fee for costs incurred in providing access to that information. We will discuss this fee with you before collating the personal information you have requested.

Please use the contact details below for all access requests.

Quality and correction of Personal Information

We take reasonable steps to ensure the personal information we collect, store and disclose from you is accurate, up-to-date and complete.

If you believe that personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading and where reasonable and practical, we will correct it and will advise any third parties to whom we may have previously disclosed that information of the correction.

Contacting the Website

If you have any questions about this privacy statement, the practices of this site, or your dealings with the Site, you can contact: privacy.au@skokka.com

Dispute Resolution

Any changes we may make to our Privacy Policy in the future will be posted on this page. Your continued use of any section of our website following posting of the updated privacy policy will constitute your acceptance of the privacy policy as amended.