Privacy Policy
**Soleae Feet Inc.**
**Effective date:** [8/1/26]
**Last updated:** [8/1/26]
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> **Draft for legal review.** This document is a starting template prepared from the product description of Soleae Feet. It is not legal advice and has not been reviewed by a lawyer. Because Soleae processes verification documents, precise location, and data that reveals users' sexual preferences, it carries above-average regulatory risk and should be reviewed by privacy counsel before publication. Bracketed fields must be completed or removed.
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## 1. Who we are
Soleae Feet Inc. ("Soleae," "we," "us") is a Delaware corporation operating the Soleae platform at soleaefeet.com and in our mobile applications (together, the "Platform").
Soleae is a two-sided marketplace. **Clients** discover and book sessions. **Solets** are independent providers who offer those sessions and may sell goods through our marketplace. This policy applies to both, and to visitors who browse without an account.
For users in the European Economic Area and the United Kingdom, Soleae Feet Inc. is the **data controller** for the personal data described here. Solets act as independent controllers for personal data they collect outside the Platform.
**Contact:** A1b4@soleaefeet.com · 704-582-4454
[EU representative under GDPR Article 27, if applicable]
[UK representative, if applicable]
[Data Protection Officer contact, if appointed]
## 2. Adults only
The Platform is restricted to people aged 18 or over. We verify age before an account can be used. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we delete the account and its data promptly. To report an underage user, contact A1b4@soleaefeet.com.
## 3. Information we collect
### 3.1 Information you give us
**All accounts**
- Name, email address, phone number, password
- Date of birth
- Profile photo and display name
- Communications you send to our support team
**Identity and age verification**
- Government-issued identification document
- A selfie or short video used to match against your document
- The verification result, and the date it was completed
**Solets additionally provide**
- Service listings, rates, availability, and stated boundaries
- Tax identification information, where we are required to collect and report it
- Payout account details, collected and held by our payment processor
- Listing photographs and descriptions for marketplace goods
**Clients additionally provide**
- Booking requests, preferences, and session notes
- Billing details, collected and held by our payment processor
### 3.2 Information generated by your use of the Platform
- **Location.** With your permission, we collect your device's precise location to show nearby Solets and to calculate distances. You can use approximate location or a manually entered area instead, with reduced accuracy of results.
- **Bookings and sessions.** Times, durations, service types, status, cancellations, and the parties involved.
- **Messages.** Message content and metadata exchanged through in-platform chat.
- **Reviews and ratings** you write or receive.
- **Safety reports and SOS activations**, including any location, time, and account data captured when a safety feature is used.
- **Transactions.** Amounts, currency, dates, and payment status. We do not receive or store full card numbers.
### 3.3 Information collected automatically
- Device identifiers, operating system, app version, browser type, and IP address
- Push notification tokens
- Log data, crash reports, and diagnostic information
- Usage data: pages viewed, features used, searches run, and session timestamps
- Cookies and similar technologies, as described in section 12
### 3.4 Information from third parties
- Verification outcomes from our identity verification provider, [VENDOR NAME]
- Payment and chargeback status from our payment processor
- Fraud, sanctions, and risk signals from screening providers
## 4. Sensitive information
Some of what we handle is treated as sensitive under privacy law, and we want to be explicit about it.
Your bookings, searches, and profile can reveal information about your sexual preferences. Under the GDPR and UK GDPR this is **special category data** (Article 9). Under California and several other US state laws it is **sensitive personal information**. Your government ID, biometric selfie match, and precise location are also treated as sensitive.
We process this data **only where you have given explicit consent**, or where processing is necessary to establish, exercise, or defend legal claims, or for reasons of substantial public interest such as the protection of users. We do not use sensitive information to build advertising profiles, and we do not sell it.
You may withdraw consent at any time by closing your account. Doing so ends your ability to use the Platform, because we cannot operate a verified marketplace without it.
## 5. How we use your information
| Purpose | Examples |
| --- | --- |
| Providing the service | Creating your account, showing listings, taking bookings, delivering chat |
| Verification | Confirming you are 18+ and that your identity is genuine |
| Payments | Processing payments, issuing payouts, handling refunds and disputes |
| Safety and trust | Investigating reports, responding to SOS activations, removing bad actors |
| Fraud prevention | Detecting fake accounts, stolen cards, and coordinated abuse |
| Support | Answering your questions and resolving problems |
| Legal compliance | Tax reporting, responding to lawful requests, record-keeping obligations |
| Service improvement | Understanding which features are used, fixing bugs, measuring performance |
| Communications | Booking confirmations, security alerts, and — with your consent where required — marketing |
We do not use your personal data to train machine learning models for purposes unrelated to operating the Platform, and we do not sell your personal data.
## 6. Legal bases (EEA and UK users)
- **Contract.** Creating your account, matching Clients with Solets, processing bookings and payments.
- **Legal obligation.** Age verification, tax reporting, responding to lawful requests, anti-money-laundering checks.
- **Legitimate interests.** Fraud prevention, platform security, service improvement, and defending legal claims. We balance these against your rights and you may object at any time.
- **Consent.** Precise location, marketing communications, non-essential cookies, and all processing of special category data. You may withdraw consent at any time without affecting processing already carried out.
## 7. What other users can see
**Solet profiles** are visible to signed-in Clients: display name, profile photo, listing photographs, services, rates, general area, availability, ratings, and reviews. Your exact address is never shown. Your verification documents are never shown.
**Client profiles** are visible to a Solet only after a booking request is made, and are limited to display name, profile photo, and review history.
**Reviews** you write are published with your display name.
Your legal name, date of birth, contact details, identification documents, payment information, and precise location are **never** displayed to other users.
## 8. How we share information
We share personal data with:
- **Payment processing.** Segpay [and PayPal, if used] processes payments and payouts. They collect your payment credentials directly and act as independent controllers under their own privacy policies.
- **Identity verification.** [VENDOR NAME] performs document and biometric checks. [Describe their retention: e.g. "They retain your document for [PERIOD] and then delete it."]
- **Cloud infrastructure.** Amazon Web Services hosts our databases, file storage, messaging, and email delivery.
- **Communications.** Google Firebase Cloud Messaging delivers push notifications.
- **Professional advisers.** Lawyers, accountants, and auditors, under confidentiality obligations.
- **Law enforcement and legal process.** Where we are legally required to, or where we believe in good faith that disclosure is necessary to prevent serious harm to any person. We will notify you unless legally prohibited from doing so.
- **Corporate transactions.** In a merger, acquisition, or sale of assets, subject to this policy continuing to apply.
All service providers act as processors on our instructions under written contracts, except where noted above.
**We do not sell your personal data, and we do not share it for cross-context behavioral advertising.**
## 9. International transfers
We are based in the United States. Our infrastructure is hosted on Amazon Web Services in the **Asia Pacific (Mumbai) region**, and support may be provided from other locations. Your personal data will therefore be transferred outside your country of residence, including to the United States and India.
For transfers from the EEA and UK, we rely on the European Commission's **Standard Contractual Clauses** and the UK International Data Transfer Addendum, together with supplementary technical measures including encryption in transit and at rest. You may request a copy of the relevant safeguards by contacting us.
## 10. Retention
| Data | Retention |
| --- | --- |
| Account profile | For the life of your account, then [30] days |
| Verification result (pass/fail, date) | [7] years after account closure, for regulatory proof of age checks |
| Identification documents and selfies | [Deleted immediately after verification / retained for PERIOD] |
| Booking and transaction records | [7] years, for tax, accounting, and dispute purposes |
| Chat messages | [PERIOD] after the related booking, or until account closure |
| Safety reports and SOS records | [PERIOD], or longer where an investigation is open |
| Server and access logs | [90] days |
| Marketing preferences | Until you withdraw consent, plus proof of the withdrawal |
Where we are required to keep records after you close your account, we restrict access to them and use them only for that purpose.
## 11. Your rights
Depending on where you live, you may have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Delete your data
- Restrict or object to certain processing
- Receive your data in a portable format
- Withdraw consent at any time
- Not be discriminated against for exercising these rights
- Lodge a complaint with your data protection authority (in the UK, the Information Commissioner's Office; in the EEA, your national authority)
**California residents** may additionally request disclosure of the categories of personal information collected, used, and disclosed, and may limit the use of sensitive personal information. We do not sell or share personal information as those terms are defined under the CCPA/CPRA.
To exercise any right, email A1b4@soleaefeet.com or use the privacy controls in your account settings. We will verify your identity before acting and respond within the period required by applicable law, ordinarily within 30 days. Using an authorized agent is permitted where the law provides for it.
## 12. Cookies and similar technologies
We use cookies and equivalent mobile identifiers to keep you signed in, remember preferences, secure the Platform against abuse, and understand aggregate usage. Strictly necessary cookies are set without consent. All others are set only where you accept them via our cookie banner, and you can change your choices at any time through [COOKIE SETTINGS LINK]. Most browsers also let you block cookies, though the Platform may not work correctly if you do.
We honor **Global Privacy Control** signals where required by law.
## 13. Security
We protect your data with encryption in transit and at rest, role-based access controls, audit logging, least-privilege access for staff, and regular review of our infrastructure. Verification documents are stored separately from profile data with tightened access.
No system is perfectly secure. If a breach affects your personal data and is likely to result in a risk to your rights, we will notify you and the relevant supervisory authority within the timeframes required by law.
## 14. Automated decision-making
We use automated systems to screen for fraud, detect fake accounts, and flag content for review. These may result in a listing being hidden or an account being suspended. You can request human review of any such decision by contacting A1b4@soleaefeet.com.
## 15. Changes to this policy
We may update this policy. If changes are material, we will notify you by email or through the Platform at least [14] days before they take effect. The date at the top shows when it was last revised.
## 16. Contact us
**Soleae Feet Inc.*
A1b4@soleaefeet.com
704-582-4454
