Version: May 9, 2021
Sarah Ashley PTY LTD is a Company registered in Australia with Australian Company Number ABN 90 605 418 022. For the purpose of the General Data Protection Regulation (“GDPR”), we are the data controller. Our data protection officer can be contacted at firstname.lastname@example.org.
SARAH ASHLEY collects, uses and discloses Customer Data (as defined below) in order to provide you with a safe, smooth, efficient and customised experience. The collection, use and disclosure of Customer Data enables SARAH ASHLEY to provide services and products that are most likely to meet your needs and requirements.
At any time you have the right to object to our processing of Customer Data about you in order to send you promotions, special offers, marketing messages, including where we build profiles for such purposes and we will stop processing the Customer Data for that purpose.
You also have the right to object to our processing of Customer Data about you and we will consider your request in other circumstances as detailed below by submitting an email to email@example.com referencing: Data Subject Rights.
What information do we collect about you?
We collect information when you purchase products on our website or mobile application, such as your contact details and credit card information. In addition, we collect device and technical information from you when you use our website or mobile application.
How will we use the information about you?
We use your information to maintain our website and mobile application, and to tailor our products and services to your preferences to provide the best service possible. In addition, we use your information to market our products and services to you, and those of our group companies, partners and agents (with your consent where required by applicable law).
Who do we share your information with?
We share your data with our third party service providers to the extent necessary for them to provide their services such as payment processors. We use these third parties services solely to process or store your information for the purposes described in this policy. We also share your information government bodies as required by law.
Where do we process your information?
Our servers are located in Australia.
How long do we keep hold of your information?
We retain your information for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of SARAH ASHLEY, or as required by relevant laws. Other than data related to your purchases which we keep for seven years in case of a dispute, we will endeavour to delete data within 30 days of a request for deletion or contact you if it will take longer.
How can I exercise my rights over my information?
You may have rights to access and correct, receive a copy of, or delete, your data or restrict or object to our processing of, your data.
If you have any concerns or complaints, please contact us
How will we notify you of changes?
By using the
1. The Information We Collect
Information You Provide
In accordance with current GDPR legislation SARAH ASHLEY collects a variety of information that you provide directly to us, including personal information that may be contained in any videos, comments, or other submission you upload or post to the Services. “Personal Information” is any information or an opinion that reasonably identifies you, whether the information or opinion is true or not and whether the information is recorded in a material form or not. Personal Information can be used to contact you online or offline. SARAH ASHLEY may collect Personal Information from you in the context of:
- Account registration and administration of your SARAH ASHLEY account;
- Uploads or posts to the Services;
- Contest registration and prize acceptance;
- Customer support and technical assistance;
- Processing your order for products or services offered by SARAH ASHLEY;
- Registration for your SARAH ASHLEY products; SKY RIGGER
- Newsletter subscriptions;
- Access to SARAH ASHLEY products or services on social networks or third party services; or
- Services provided online, by way of your mobile device or the SARAH ASHLEY software; and
- Other uses of the Services where Personal Information is requested for use and/or participation.
The specific types of Personal Information collected will depend upon the Services you use, how you use them, and what you choose to provide and may include your full name, email address, phone number, home address, mobile phone number, credit card information, shipping address, gender, birth date, and postcode. Our mobile applications and services may request access to your Wi-Fi network and access to your photos and videos to enable you to download photos and videos to your mobile device or computer or upload photos and videos to your SARAH ASHLEY account or social media accounts. Those who win a prize in our contests may be required to provide their Tax information and any other identification for tax purposes, which will only be used for prize fulfilment purposes. SARAH ASHLEY does not adopt government identifiers to identify you on its systems.
SARAH ASHLEY may also ask for “non-Personal Information,” i.e., information that cannot be used to identify or contact you. When you shop through our web store, we may collect data such as the purchases you have made, items in your shopping cart, and how often you make purchases. We also collect information you choose to include in your SARAH ASHLEY account, including, but not limited to, videos and photos, interests and preferences, location, videos and photos that you have favoured.
2. Automatically Collected Information
When you use our websites (including our web store), in accordance with current GDPR legislation we may collect and analyse certain information about your computer or mobile device, such as your browser type, browser language, operating system, error logs, and other similar information.
• Information from Other Sources
Personal Information will generally be collected from you in accordance with current GDPR legislation in the ways described above. There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you, including as described below. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
3. Cookies and Similar Technologies
Please see our Cookies Policy.
4. Uses of Information
SARAH ASHLEY collects information for the purpose of being able to use it in accordance with current GDPR legislation, in the ways set out below.
SARAH ASHLEY may use non-Personal Information to improve performance of our Services, to understand how anonymous users interact with our website after seeing SARAH ASHLEY advertisements, to identify and retarget advertisements to past website visitors, and to optimize the performance of our advertising campaigns.
SARAH ASHLEY may use both non-Personal Information and Personal Information to enable the purchase and fulfilment of SARAH ASHLEY products and services, and to improve the overall SARAH ASHLEY customer and product experience.
SARAH ASHLEY may also use Personal Information in providing the Services, including but not limited to:
- Orders – If you place an order, we will use your name and email address to send you an order confirmation email, a shipping confirmation email, and customer satisfaction emails. If you do not wish to participate in customer satisfaction emails, you may opt-out of such emails upon receipt by clicking “Unsubscribe” link contained in the email. Customer Service – Based upon the Personal Information you provide us at the time of SARAH ASHLEY account registration or purchase, we will send you a confirmation email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your SARAH ASHLEY account. We will communicate with you by email or telephone, in accordance with your preferences.
- Newsletters, Special Offers and Updates – We will occasionally send you information on products, services, special promotions, contests, events, and opportunities to interact with SARAH ASHLEY and our community. You can sign up to receive these emails from us on our newsletter sign up page and/or during checkout while purchasing a product. Out of respect for your privacy, we present the option NOT to receive these types of communications. Please see “Your Choices” section below for more details on how to unsubscribe or opt-out of communications from SARAH ASHLEY.
- Service-Related Announcements – We will send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your SARAH ASHLEY account.
- Service Improvement –We will use information which as such does not allow us to identify you to understand how users interact with our Services and advertisements, provide tailored content and advertising, improve the overall SARAH ASHLEY customer and product experience, and perform research and analytics.
- Order-Related Communications – If you place an order, we will use your name and email address to send you an order confirmation email, a shipping confirmation email, and – with your prior opt-in only – customer satisfaction emails. If you do not wish to participate in customer satisfaction emails any longer, you may opt out of such emails upon receipt by clicking “Unsubscribe” link contained in the email.
5. Sharing and Disclosure of Information
SARAH ASHLEY does NOT share, sell, rent or trade otherwise disseminate your Personal Information to third parties, unless required by law, unless required for the purpose of your contract or unless you have given us express consent to do so.
6. Your Choices
SARAH ASHLEY provides you with a number of choices with respect to the information we collect and use as discussed throughout this Policy. Some of your choices include:
- Marketing Communications. If you purchase a product but do not wish to receive any additional marketing material from us, you can indicate your preference on our order form by leaving the “Opt-In” checkbox blank. If you have opted-in, but no longer wish to receive our newsletter and promotional emails, you may opt out of receiving them by following the instructions included in each newsletter or email or by contacting customer support at www.sarahashley.net.au.
- SARAH ASHLEY Personalization Services. As discussed in depth in Section 5, SARAH ASHLEY may use the information we have collected from and about you to personalize your SARAH ASHLEY experience. If you do not want SARAH ASHLEY to provide such personalized services, you may opt out through your SARAH ASHLEY account settings by disabling the Personalization tab.
- Do Not Track (“DNT”). DNT is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the Network Advertising Initiative and the Digital Advertising Alliance opt-out links above. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
SARAH ASHLEY provides you with a number of choices with respect to the information we collect and use as discussed throughout this Policy. Some of your choices include:
8. Customer Testimonials
At times, we may post customer testimonials on our website which may contain Personal Information. We will obtain your consent via email and/or opt-in methods prior to posting your name, city, or stated activity/interest along with any testimonial.
9. User-Generated Content
You may be able to disclose information about yourself in the course of contributing user-generated content on publicly available areas of the Services. This includes, but is not limited to: your uploaded photos or videos, full name, email address, phone number, address, interests and content that you have favoured. Your photo or video files may also contain your narrations and captions, if you have chosen to manually associate this data with your video. Your content will also be shared with users of other social media services to which you have chosen to share, consistent with your privacy settings on those services. Such information is unencrypted, public information, may be accessed or recorded by us, and there is no expectation of privacy or confidentiality in such information. Any information, including your Personal Information you submit in the course of such activities can be read, collected, or used by other users.
10. Third Party Service Providers
We use other third party service providers to offer or facilitate services on our behalf, such as a shipping company to fulfil orders, a credit card processing company to bill you for goods and services, and an email service provider to send out emails on our behalf. When you order products from SARAH ASHLEY, we will share your Personal Information as necessary for such third party services providers to provide the applicable service to us or on our behalf. These third parties are prohibited from using your Personal Information for promotional purposes.
11. Business Transactions
Information that we collect, including your Personal Information and non-Personal Information, is considered a business asset. As a result, if we go out of business, enter bankruptcy, or if we are acquired as a result of a transaction such as a merger, acquisition or sale of some or all of our assets, your information may be disclosed or transferred to a third party acquirer in connection with the transaction.
12. Legal Compliance
In some circumstances the law may permit or require us to use or disclose Personal Information (for instance, where you would reasonably expect us to and the purpose is related to the purpose of collection). For example, we may access and disclose your Personal Information when we believe in good faith that such disclosure is necessary to: (a) enforce legal rights and comply with the law; (b) comply with an order from a government entity or other competent authority, (c) prevent or address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage; (d) protect our rights, prevent fraud and/or comply with judicial proceeding, court order, or legal process served on SARAH ASHLEY.
13. Other Disclosures of Non-Personal Information
14. Accessing / Correcting / Updating or Removing Information
SARAH ASHLEY users may modify or remove any of their Personal Information collected by SARAH ASHLEY at any time to correct or change any information by filling out our contact form located at http://seaulcer.com/contact.
SARAH ASHLEY will respond to a request for access within a reasonable period. We may charge you a fee for processing the request, but not for making the request for access.
SARAH ASHLEY may decline a request for access to Personal Information in circumstances prescribed by the applicable privacy legislation, and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
If upon receiving access to your Personal Information, or at any other time, you believe the Personal Information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your Personal Information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.
15. Third Party Website Links and Features
Facebook Connect: Our website also uses Facebook Connect, offered by Facebook, Inc. This functionality enables you to use your Facebook account to log into your SARAH ASHLEY account on our website and other websites without additional registration.
Sign In with Google: Our website also uses Sign In with Google, offered by Google, Inc. This functionality enables you to use your Google + account to log into your SARAH ASHLEY account on our website and other websites without additional registration.
16. Children’s Privacy
SARAH ASHLEY ’s Services are intended for Adult audiences and not for children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18 and if we become aware of such collection, we will take reasonable steps to delete any such information as soon as practicable.
17. International Users
19. How we Protect Your Personal Information
The security of your Personal Information is important to us. We have implemented reasonable administrative, technical, and physical security measures to protect against the unauthorized access, interference destruction or alteration of your information. Despite our best efforts, however, no security measures are completely impenetrable.
20. SARAH ASHLEY International Compliance
SARAH ASHLEY cares deeply about online privacy. For users located in Australia wishing to make a complaint about a breach of the Privacy Act 1988 (Cth) or Australian Privacy Principles, please contact us by using our contact details set out below and we will take reasonable steps to investigate the complaint and respond to you within a reasonable period. If you are not happy with our response, you may complain directly to the Australian Privacy Commissioner. For more information about privacy in general, you can visit the Australian Privacy Commissioner’s website at www.oaic.gov.au.
21. SARAH ASHLEY Contact Info:
What are cookies?
Cookies are text files containing small amounts of information which are automatically downloaded to your computer or device when you visit a website. Cookies send data back to the originating website on each subsequent visit, or shares data with another website that recognizes that cookie.
Cookies are useful because they allow a website to recognize a user’s device. They do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.
Cookies do not typically identify you as an individual, just the device you are using. For further information on cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit http://www.allaboutcookies.org.
Types of cookies we use
There are four different types of cookies we use:
- Functionality cookies. These cookies allow our Services to remember choices you make, such as: remembering your username, preferences and settings; remembering if you’ve filled in a survey or taken part in a poll or contest or otherwise reacted to something on through the Services, so you’re not asked to do it again; remembering if you’ve used any of our Services before; restricting the number of time you are shown a particular advertisement; remembering your location; and enabling social media components like Facebook or Twitter. The aim of these cookies is to provide you with a more personal experience so that you don’t have to reset your preferences each time you use our Services. [We also use functionality cookies to enable you to provide enhanced services such as enabling you to view a video through the Services. As described below, you may disable any of these functional cookies; but if you do so, then various functions of our Services may be unavailable to you or may not work the way you want them to.
- Analytical/Customization cookies. These cookies collect information about how visitors use and interact with our Services, for instance which pages they go to most often. These cookies also enable us to personalize content and remember your preferences (e.g., your choice of language, country, or region). These cookies helps us improve the way our websites work and provide a better, personalized user experience.
- Advertising cookies. These cookies record your visit to our websites, the pages you have visited, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a website. We (and third-party advertising platforms or networks) may use this information to make our websites, content, and advertisements displayed on them more relevant to your interests (this is sometimes called “behavioural” or “targeted” advertising). These types of cookies are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaigns.
- Apple Safari: http://support.apple.com/kb/PH5042
- GoogleChrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
- Microsoft Internet Explorer: http://windows.microsoft.com/en-US/windows7/How-to-manage-cookies-in-Internet-Explorer-9
- Mozilla Firefox: http://support.mozilla.org/en-US/kb/Cookies
- Essential cookies. These are cookies that are required for the operation of our Services (e.g., to enable you to log-in to secure areas of our websites or use a shopping cart). These cookies are necessary for the Services to operate properly. Without these cookies, services that you have asked for cannot be provided. We want you to understand these essential cookies, and why we use them, but we don’t need to get your consent to use them on our Services as we use these cookies only to provide you with services that you have requested.
To find out more about interest-based ads and your choices, visit these sites: Digital Advertising Alliance, the Network Advertising Initiative, and the Interactive Advertising Bureau (IAB) Europe.
Some of the cookies we commonly use are listed in our cookies chart. This list is not exhaustive, but it is intended to illustrate primary reasons for certain types of cookies set by SARAH ASHLEY and third parties on our websites. Third parties may also set certain cookies on your device when you use our Services. In some cases, the third party has been hired to provide certain services on SARAH ASHLEY ‘s behalf (e.g., website analytics). In other cases, our websites contain content or ads from third parties (e.g., videos, news content, or ads delivered by other ad networks). When your browser connects to those third parties’ web servers to retrieve content, those third parties may set and use their own cookies on your device.
How long do cookies stay on my device?
Some cookies operate from the time you visit a SARAH ASHLEY website or to the end of that particular web-browsing session. These cookies expire and are automatically deleted when you close your internet browser. These cookies are called “session” cookies.
Some cookies will stay on your device between browsing sessions — they do not expire when you close your browser. These cookies are called “persistent” cookies. The length of time a persistent cookie stays on your device varies from cookie to cookie.
Third party cookies
We used trusted partners like and Google AdWords to help us service advertising, Infusionsoft to help us personalize your shopping experience on our web store and analytics companies like Google Analytics (see below), We also pull through content from social networks into our own pages, such as embedded Twitter feeds. The social networks, such as Facebook, Twitter, YouTube, Tumblr, Pinterest and Google Plus may themselves also put cookies on your machine. For example, our website also utilizes the Facebook Like button functionality to share content. If a user clicks the Like button and logs into Facebook via our website, Facebook will leave a cookie on the users’ computer. This is the same process as if the user logs into Facebook directly, or clicks Like on any other website.
We also use Google Analytics on our Services to help us analyse how our Services are used. Google Analytics uses performance cookies to track visitor interactions. For example, by using cookies, Google can tell us which pages our users view, which are most popular, what time of day our websites are visited, whether visitors have been to our websites before, what website referred the visitor to our websites, and other similar information. All of this information is anonymised.
We have little control over these ‘third party’ cookies, so we suggest that you check the respective privacy policies for these external services to help you understand what data these organisations hold about you and what they do with it.
Google AdWords: https://support.google.com/adwords/answer/2549116?hl=en
Google Analytics: http://www.google.com/analytics/learn/privacy.html.
Google Tag Manager: https://www.google.com/analytics/tag-manager/faq/
Our use of Web Beacons
We may also use electronic images known as web beacons on our Services – sometimes called “clear GIFs”, “single-pixel GIFs”, or “web bugs”. Web beacons are used to deliver cookies on our Services, count clicks/users/visitors, and deliver co-branded content or services. We may include web beacons in our promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon.
SARAH ASHLEY Services may also contain web beacons from third parties to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other website operations. These web beacons may allow the third parties to set or read cookies on your device.
How to control which cookies are set
There are a number of ways you can manage what Analytics/Customization, Functionality and Advertising cookies are set on you devices. Essential cookies, however, cannot be disabled. If you do not allow certain cookies to be installed, the website may not be accessible to you and/or the performance, features, or services of the website may be compromised.
2. Disabling most targeting or behaviour advertising cookies
If you would like to disable advertising cookies, which remember your browsing habits and try and display relevant advertising when you use our Services, you can visit http://www.youronlinechoices.com. If you choose to turn off these cookies you will still see advertising on the internet but it may not be tailored to your interests. It does not mean that you won’t be served any advertisements whilst you are online. Whilst many companies involved in using advertising cookies and serving online behavioural advertising appear at the above link, not all do. Therefore, even if you choose to turn off cookies used by all of the companies listed, you may still receive some advertising cookies and some tailored advertisements from other companies.
You can also manage this type of cookie in the privacy settings on the web browser you are using. Please see below for more information.
2. Browser Controls
You can disable and/or delete all types of cookies by using your browser settings. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others’ websites. The following links provide information on how to modify the cookies settings on some popular browsers:
Cookies that have been set in the past
If you have recently disabled one or more cookies, we will stop using the disabled cookies to collect any further information. However, we may still use information collected from such cookies prior to your “disable” preference being set.
Do Not Track Signals
There is no uniform or consistent standard or definition for responding to, processing, or communicating Do Not Track signals. At this time the SARAH ASHLEY Services do not function differently based a user’s Do Not Track signal. For more information on Do Not Track signals, see All About Do Not Track.
WHY WE ARE THE BEST IN THE INDUSTRY
With 350+ models in QLD alone and 7+ years in the industry, this makes us Australia’s largest and most popular adult entertainment agency. And we’re only getting started, boys!