Hello ! Thank you so much for using Sole Smiling! It means the world to me. Please find our privacy policy and terms below! Email us at info@solesmiling.com for any questions at all . Keep Shining.
(づᵔꈊᵔ)づ
SOLE SMILING LLC
PRIVACY POLICY
Effective date: 1/1/2026
Last updated: 9/26/2026
Privacy Policy URL: https://www.solesmiling.com/privacy
1. WHO WE ARE AND WHAT THIS POLICY COVERS
Sole Smiling LLC ("Sole Smiling," "we," "us," or "our") operates https://www.solesmiling.com and the Sole Smiling applications, widgets, and related features that link to this Policy (the "Services"). We determine the purposes and means of processing personal information for these Services and act as a controller or business where those terms apply.
This Policy covers visitors, account holders, people appearing in or interacting with content, people receiving invitations, and people who contact us about the Services. You do not have to register for this Policy to apply. It covers information processed when you sign up, upload or view media, create boards, connect with people, use Sole Bonds or groups, or otherwise interact with us.
"Personal information" means information that identifies, relates to, describes, or can reasonably be linked with a person or household, as defined by applicable law. Account IDs, device identifiers, and viewing totals linked to a profile can be personal information even if they do not include a person's real name.
This Policy does not govern an unrelated third party's independent services or our employment records. Where a feature needs an additional notice or consent, we will provide it at the appropriate time. Reading or acknowledging this Policy is not blanket consent to optional tracking, advertising, or other processing requiring separate consent.
Our contact information:
Sole Smiling LLC
Connecticut, USA
Privacy contact: info@solesmiling.com | 203 – 400 - 2833
Privacy request form: https://www.solesmiling.com/privacy
Support and accessible formats: info@solesmiling.com
2. INFORMATION YOU PROVIDE
2.1 Account and verification information
When you begin signup or manage an account, we collect information such as your email address, username, account and profile identifiers, authentication information, verification status, and relevant registration or login records. Information submitted during an unsuccessful or incomplete signup can still be personal information, even if a public profile has not yet been created.
Our signup flow identifies required fields. Profile details such as a name, biography, or avatar are optional unless a particular feature clearly says otherwise. Authentication systems process passwords, verification codes, or session credentials to establish access. Do not include a password in a support message or public profile.
Authentication and anti-abuse providers, the information they receive, and relevant retention details: [AUTHENTICATION_AND_ANTIBOT_DETAILS].
Age or eligibility information, if collected, and any verification provider: [AGE_ASSURANCE_DETAILS]. Email verification alone does not establish a person's age or identity.
2.2 Profile and media information
We collect information you choose to add to a profile and content you submit, including usernames, display names, profile pictures, biographies, images, videos, audio, titles, captions, descriptions, boards, and profile boards. We also process information needed to associate content with its uploader and display it, such as media identifiers, upload dates, file types, dimensions, duration, thumbnails, and technical playback information.
Uploaded files may contain information beyond what is immediately visible, such as a face, voice, background location, or embedded metadata. Do not upload information you do not have the right to share. Our treatment of embedded location and other media metadata is: [MEDIA_METADATA_HANDLING].
2.3 Connections, Sole Bonds, groups, and communications
We collect follows, unfollows, likes, memberships, invitations, participation records, and other interactions you initiate. Sole Bond, group, and clan features may involve relationship identifiers, participant-selected nicknames, messages, shared media, membership status, and administrative activity.
When you submit an invitation, we process the contact information you supply, the sender and intended recipient, and invitation status. A person receiving an invitation may not yet be a member. Do not submit contact information for unsolicited bulk messaging or without a lawful basis to contact the person.
We collect the information you send to support, submit in feedback, include in a safety or copyright report, or provide in a privacy request or appeal. This may include account details, the content or conduct at issue, correspondence, and limited identity or authority information needed to address the request.
2.4 Preferences and permissions
We collect relevant account settings, language or feature choices, notification settings, consent selections, opt-outs, and records of agreement to Terms. A browser or operating-system permission does not necessarily authorize every later use of information obtained through that permission.
2.5 Purchases and promotions
Current paid features, payment information, payment providers, and promotional programs, if any: [PAYMENTS_AND_PROMOTIONS_DISCLOSURE]. Before a new paid feature collects information, we will provide the required transaction and privacy disclosures.
3. INFORMATION COLLECTED THROUGH USE OF THE SERVICES
3.1 Technical and device information
When you connect to the Services, our systems and infrastructure providers process technical information needed to receive and respond to the connection. Depending on the feature and configuration, this includes IP address, browser and operating-system information, device or session identifiers, request time, pages or media requested, referring information, error reports, and connection or playback performance.
The enabled technical fields, approximate-location processing, and any device permissions beyond user-selected uploads are described here: [DEVICE_AND_LOCATION_DETAILS]. We distinguish approximate location inferred from a connection from precise location obtained through a device permission. A location visible in an uploaded photograph is also distinct from device GPS collection.
3.2 Media viewing and engagement analytics
When you watch videos or use media features, we process activity such as media and creator identifiers, play starts, counted views, watch duration, repeat plays or loops, playback progress, likes, and relevant timestamps. The applicable collection depends on the player and feature you use, your privacy choices, and legal requirements.
For account holders, viewing activity can be associated with the account or profile. We use cumulative profile-level statistics, including total counted views or videos watched, repeat activity, total watch time, and active viewing periods where recorded. Time can be represented in seconds, minutes, hours, or fractional days. Per-media statistics can also be maintained for a video or image.
Activity can be summarized into cumulative counters instead of retaining a separate permanent database entry for every viewing event. Summarizing records reduces data volume; it does not make a profile-linked total anonymous. A record described internally as "lifetime" means that it accumulates activity over the relevant account history. It does not mean that we may retain identifiable data forever or disregard a valid deletion request.
Different players or technical conditions can produce delayed, estimated, reconciled, or incomplete metrics. Not every counted view represents a different individual. We use the information to understand service use, measure content performance, diagnose playback, and identify artificial activity, subject to the purpose limits and controls described below.
Guest viewing identifiers, persistence, and any later connection of guest activity with an account: [GUEST_ANALYTICS_AND_LINKING_DETAILS]. Guest browsing is not automatically anonymous merely because a visitor has not signed in.
Who can see creator analytics, viewing totals, or viewer identities: [ANALYTICS_VISIBILITY_DETAILS]. Public media counts are different from disclosure of an identifiable person's viewing history.
3.3 Cookies, local storage, pixels, and similar technologies
Cookies and similar technologies can store a session, remember preferences, support security, measure activity, or enable other functions. Local storage, pixels, software development kits, and server-side integrations may process information even if they are not labeled "cookies."
Our actual technologies, providers, purposes, retention periods, and controls are listed in Appendix B. The applicable consent and opt-out rules depend on the technology, purpose, location, and other circumstances. We request consent before non-exempt storage or access where required. We do not treat continued browsing or acceptance of Terms as a substitute for required consent.
4. INFORMATION FROM OTHER SOURCES
We receive information from other users who invite you, connect with you, mention or depict you in content, participate in a shared feature, or report a concern. We also receive information from providers performing functions for us, such as authentication, hosting, media delivery, security, and support.
Additional independent sources, such as a connected social login, advertising partner, data broker, or publicly available database, if used: [ADDITIONAL_DATA_SOURCES].
When we obtain information about someone indirectly, we provide notice when and as required by applicable law, including appropriate notice to invitation recipients. We use the information for the relevant feature or other disclosed lawful purposes, not as unrestricted permission to market to that person.
5. WHY WE USE PERSONAL INFORMATION
We use the information relevant to a function for the following purposes:
(a) Provide requested account functions: create and administer accounts, verify access, maintain sessions, process settings, and respond to account requests.
(b) Operate media and social features: store and deliver uploads, generate playback formats and thumbnails, show profiles and boards, route messages and invitations, and support follows, likes, Bonds, and group participation.
(c) Organize and present content: provide search, selected categories, following views, chronological views, popularity-based lists, and other discovery features described in the interface.
(d) Measure and improve operation: calculate views and watch-time statistics, examine service and content performance, diagnose failures, and improve reliability or usability. Optional tracking and additional personalization remain subject to applicable consent and objection rights.
(e) Protect users and the Services: prevent fraud and unauthorized access, investigate abuse and manipulation, enforce content rules, process safety and intellectual-property reports, and preserve information when legally required.
(f) Communicate: answer support questions, send verification or security notices, provide relevant service updates, and send optional marketing only as described in Section 11 and permitted by your choices and law.
(g) Comply with legal obligations and address claims: process rights requests, satisfy lawful reporting or preservation obligations, maintain necessary records, and establish or defend legal claims.
Advertising, cross-service measurement, sponsored content, and related purposes, if currently used, are specifically disclosed in Section 9. Processing for an unrelated new purpose requires an appropriate notice and legal basis, and consent where required. We do not obtain unlimited rights to use personal information by describing a broad service-improvement purpose.
6. PUBLIC INFORMATION AND RESTRICTED SHARING
6.1 Public areas
Public profiles and public content can be viewed by other users and logged-out visitors. Depending on what you post, this includes your username, avatar, biography, images, videos, audio, titles, and public boards. Public posts may be shown in galleries, discovery results, search, and shared links. Search engines or other people may retain copies beyond our control.
Public engagement counts and any identity-level visibility of likes, follows, or memberships: [PUBLIC_ENGAGEMENT_VISIBILITY].
Whether and how someone can find your profile using your email address, real name, username, or other contact information: [CONTACT_DISCOVERY_DETAILS]. A search match can disclose an association even when the underlying email address is not displayed.
6.2 Bonds, groups, messages, and invitations
The audience for Sole Bond messages, shared Bond media, group and clan content, invitations, membership lists, and any administrator access is: [BOND_AND_GROUP_VISIBILITY_DETAILS]. Linked public profiles or public media remain subject to their public audience.
Recipients can retain or further disclose information they receive. Removing a connection or membership does not necessarily erase information already received. We remain responsible for honoring the access restrictions and deletion obligations that apply to information under our control.
Authorized personnel and providers can access information as necessary to deliver the feature, handle a report or support request, protect security, or comply with law, subject to appropriate restrictions. We do not promise end-to-end encryption unless a particular feature expressly provides it and explains its limits.
7. PROVIDERS AND OTHER RECIPIENTS
7.1 Service providers
We use Wix to support the platform. Wix and other providers can process information needed to perform contracted functions such as website hosting, database and file storage, authentication, media processing and delivery, communications, security, and technical support. The actual services and contractual roles depend on our configuration.
Current provider inventory, relevant roles and purposes, and the data categories each receives: [PROVIDER_INVENTORY].
Where a provider processes information on our behalf, we use the contracts and restrictions required by applicable law. A provider's separate privacy notice may apply to information it processes independently; it does not replace this Policy or eliminate our obligations for disclosures we make.
Wix privacy information: https://www.wix.com/about/privacy
7.2 People you interact with
We disclose information to your selected recipients, other participants, or the public as described in Section 6 and the feature you use. A recipient is not necessarily our service provider. Do not assume information voluntarily sent to another person remains solely under our control.
7.3 Legal, safety, and professional recipients
Where authorized or required by law, we disclose relevant information to courts, regulators, law enforcement, the National Center for Missing & Exploited Children, or other competent recipients to respond to valid process, make required reports, protect safety, investigate unlawful activity, or establish and defend rights. We assess requests and limit disclosures as required; a request alone does not automatically authorize disclosure.
We may share necessary information with legal, accounting, insurance, and other professional advisers subject to appropriate confidentiality obligations. Copyright notices and counter-notices may be shared with the opposing party as explained in the Terms. Safety reports are handled with attention to the reporter's and affected person's privacy.
7.4 Business transactions
If the Services are involved in a merger, financing, acquisition, reorganization, insolvency, or asset transfer, relevant information may be disclosed to advisers and transaction participants subject to appropriate safeguards and legal restrictions. Any successor must respect applicable privacy obligations. A transaction does not itself authorize an incompatible use of personal information or eliminate consent requirements.
7.5 Your separate directions
We may make a disclosure that you specifically request or separately authorize, after providing appropriate information about the disclosure. Broad agreement to Terms is not a substitute for consent that the law requires to be specific or separate.
8. SENSITIVE INFORMATION, INFERENCES, AND AI
Some information is subject to heightened protection. Examples include account credentials, certain private communications, precise location, biometric identifiers used for recognition, health information, and information revealing race, religion, sexual orientation, or other protected characteristics. Images, audio, messages, and viewing behavior may contain or reveal such information even if we do not ask for it in a form.
Our actual sensitive-information collection, purposes, inferences, and restrictions are: [SENSITIVE_INFORMATION_PRACTICES]. Ordinary storage of a photograph or audio clip is different from creating a biometric identifier to recognize a person.
Our actual use, or non-use, of facial recognition, biometric templates, sensitive-trait inference, automated age estimation, and health profiling is: [BIOMETRIC_AND_SENSITIVE_INFERENCE_STATUS]. Any applicable separate biometric or consumer-health notice and consent must be provided before that processing begins.
Our actual use, or non-use, of User Content or personal information to train AI models, and any AI provider that processes user information, is: [AI_PROCESSING_STATUS]. Technical media conversion, ordinary statistical analytics, and general-purpose model training are different activities. This Policy and the ordinary content license do not by themselves supply consent or rights for unrelated AI training.
9. SALE, SHARING, AND TARGETED ADVERTISING
Certain privacy laws define "sale" to include transfers for valuable consideration, not just money. California "sharing" can include disclosure for cross-context behavioral advertising. Other laws regulate targeted advertising across unrelated websites or applications. A disclosure can fall within these definitions even if a company says it does not sell a customer list.
Our current and preceding-12-month sale, sharing, and targeted-advertising practices, including relevant categories, recipients, purposes, and knowledge of any sale or sharing involving people under 16, are: [SALE_SHARING_AND_TARGETED_ADVERTISING_STATEMENT].
Privacy choices and any required "Do Not Sell or Share My Personal Information" or equivalent control: [ADVERTISING_PRIVACY_CHOICES]. Where an applicable opt-out right exists, we honor it without requiring you to create an account or provide unnecessary identity documents. We also honor legally recognized browser or device opt-out preference signals, such as Global Privacy Control, where required. Implementation and whether a choice applies to the browser, device, or known account are explained with the control.
We do not knowingly engage in a sale, sharing, or targeted-advertising practice involving a minor in violation of applicable consent or prohibition rules. A general age statement or acceptance of this Policy is not a substitute for those rules.
10. COOKIES, TRACKING CHOICES, AND VIDEO PRIVACY
You can manage optional technologies using [COOKIE_SETTINGS_METHOD]. Appendix B identifies actual technologies and lifetimes. Essential functions and optional analytics or advertising are distinguished by purpose, not merely by the name given to a cookie.
Where consent is required, refusal or withdrawal stops the relevant optional processing going forward. Some information needed to provide a requested function, protect security, maintain legal records, or honor your choice may still be processed under a lawful basis. We do not describe all account-linked analytics as essential solely because they are useful to the business.
Browser controls may let you block or delete cookies. Doing so can affect login, preferences, and playback. Your settings may need to be applied to each browser or device unless our control expressly offers an account-wide choice. Deleting a preference cookie may reset a choice; legally required opt-out signals must still be honored.
Our response to older "Do Not Track" browser signals is: [DO_NOT_TRACK_RESPONSE]. Do Not Track and Global Privacy Control are different mechanisms. A statement about one does not excuse compliance with requirements applying to the other.
Whether third parties collect personal information through the Services about activity over time and across unrelated websites or services is: [CROSS_SITE_TRACKING_DISCLOSURE]. Include embedded players, pixels, advertising integrations, and server-side transmissions where applicable.
Video-viewing information can be subject to additional legal protections. We do not treat acceptance of this Policy or the Terms as the separate consent required for a protected disclosure. Before a disclosure requiring specific video-privacy consent, we will obtain that consent in the legally required form and provide withdrawal controls. Our actual recipients and practices must still be disclosed in Sections 7 and 9; this paragraph does not authorize undisclosed transfers.
11. COMMUNICATIONS AND YOUR CHOICES
We use relevant contact information for verification, account recovery, security, support, safety, and material service notices. You may still receive essential non-marketing messages after opting out of marketing.
Marketing channels, any email open or click tracking, providers, and how to opt in or out: [MARKETING_COMMUNICATIONS_DETAILS]. Marketing texts, automated calls, and other channels requiring specific authorization are not authorized by joining the Services alone.
Where offered, you can unsubscribe from marketing email through the message link or contact [PRIVACY_EMAIL]. Push notifications can be controlled through relevant account or device settings when supported. A choice about push notifications does not automatically change email marketing or cookie preferences.
12. HOW LONG WE KEEP INFORMATION
We keep personal information only for as long as reasonably necessary and proportionate for a disclosed purpose, subject to legal requirements and valid deletion rights. We consider the type and sensitivity of the information, the feature requested, whether an account remains in use, the risk from retention, legal requirements, and a specific need to resolve a dispute or prevent abuse.
Our category-level retention rules are:
Account and profile records: while needed to provide the account, subject to valid deletion requests. Treatment of inactive accounts and any inactivity cutoff: [INACTIVE_ACCOUNT_RETENTION].
Authentication and verification records: verification secrets expire according to the configured verification process and must not remain usable afterward. Retention of expired codes, incomplete registrations, failed-login records, session credentials, and verification metadata: [AUTHENTICATION_RETENTION].
Uploaded media, boards, and associated metadata: while you maintain the content in the relevant feature, followed by the deletion process below, subject to specific lawful exceptions. Treatment of shared recipient-held copies: [SHARED_CONTENT_RETENTION].
Likes, follows, memberships, Bonds, and invitations: while required for the feature or to reflect the current relationship, with retention of ended relationships and unaccepted invitations limited as follows: [SOCIAL_RECORD_RETENTION].
Raw viewing events, playback checkpoints, detailed diagnostic traces, and similar temporary records: [RAW_ANALYTICS_RETENTION].
Profile-linked cumulative viewing totals: while necessary for the disclosed account-related analytics purpose, with periodic necessity review and deletion or effective de-identification following account deletion or an applicable rights request. Any shorter retention rule or inactivity cutoff: [PROFILE_ANALYTICS_RETENTION]. The word "lifetime" does not override these limits.
Security, moderation, support, and legal-request records: [SECURITY_AND_SUPPORT_RETENTION], with a longer period only where a specific legal obligation, documented legal hold, or proportionate continuing need requires it.
Agreement, consent, and privacy-request records: [CONSENT_AND_REQUEST_RECORD_RETENTION], restricted to compliance and evidence of the relevant choices or requests.
Payment or tax records, if collected: the period stated in [PAYMENTS_AND_PROMOTIONS_DISCLOSURE], taking into account applicable accounting and tax duties.
Restricted backups: [BACKUP_RETENTION_PERIOD]. Backup copies are restricted from ordinary use and expire through the applicable cycle; if restoration occurs, relevant deletion instructions must be reapplied.
Legal holds are limited to information needed for the particular matter and reviewed when the basis ends. We may retain statistics that have been genuinely de-identified so that they cannot reasonably be associated with an individual, subject to law. Merely removing a name, hashing an email, or keeping a profile ID does not necessarily de-identify a record.
13. ACCOUNT AND CONTENT DELETION
You can request account deletion through [ACCOUNT_DELETION_METHOD] or contact [PRIVACY_EMAIL]. To request deletion of a particular upload, use the relevant content control where available or identify the content in your request. Uninstalling an app or logging out does not itself delete an account.
After appropriate verification and review, we remove or de-identify eligible information from active systems within [ACTIVE_SYSTEM_DELETION_PERIOD], subject to any shorter legally required deadline and permitted exceptions. We notify providers when required to carry the request through. We explain a refusal or partial refusal where law requires and provide available appeal information.
Deleting a profile should not leave its identifiable viewing analytics available for ordinary use merely because the analytics are stored separately. Related media, connections, shared records, authentication data, caches, and analytics are handled under the applicable category rules rather than assuming one profile deletion removes everything.
Information another person independently posted or lawfully retained may remain subject to that person's rights. Public search-engine copies or independent screenshots may persist beyond our control. We take legally required steps for information we disclosed or made public; we do not use third-party persistence to excuse our own obligations.
We may retain limited information when a valid legal exception applies, such as evidence necessary to resolve a claim, fulfill a mandatory preservation duty, or maintain a proportionate abuse-prevention record. We do not keep the entire account indefinitely merely because a narrow record may be retained.
14. SECURITY
We use administrative, technical, and organizational measures intended to protect information, including access restrictions and controls appropriate to its sensitivity and the risks of processing. No online system can be guaranteed completely secure.
This statement is not a waiver of our duty to provide legally required security or notifications. If we determine a security incident requires notice, we will provide the notices required by applicable law. We do not promise a certification, encryption method, audit result, or particular security feature unless it is actually in place and specifically identified.
Protect your account and notify [SUPPORT_EMAIL] promptly about suspected unauthorized access. For a security vulnerability or suspected data exposure, contact [SECURITY_EMAIL] and avoid accessing or disclosing other users' information unnecessarily.
15. PRIVACY REQUESTS AVAILABLE UNDER APPLICABLE LAW
Depending on your location, our activities, and the applicable law, you may have rights to:
- Confirm whether we process your information and access it.
- Receive a portable copy in a usable format.
- Correct inaccurate information.
- Request deletion, subject to lawful exceptions.
- Withdraw consent for processing that relies on consent.
- Object to or restrict certain processing.
- Opt out of a sale, sharing, targeted advertising, or qualifying profiling.
- Limit specified uses of sensitive information where applicable.
- Obtain information about recipients, including specific third parties where the applicable law grants that right.
- Challenge certain automated decisions or request human review where applicable.
- Appeal a refusal of a rights request where provided by law.
- Complain to a competent regulator and exercise rights without unlawful discrimination.
Submit a request through https://www.solesmiling.com/privacy or info@solesmiling.com. Describe the request and provide enough information to locate the relevant data. You do not need to open a new account. We offer reasonable assistance and accessible formats through info@solesmiling.com.
We may verify identity or authority when necessary for a request involving disclosure, correction, or deletion, using information proportionate to the risk. We do not require a password by email or excessive documentation. Verification information is used for verification and related security, not unrelated marketing. Different rules apply to opt-outs; we do not impose identity-verification requirements where prohibited.
Where allowed, an authorized agent may act for you. We may request evidence of authorization and, where lawful, confirmation from you. We follow applicable rules for powers of attorney, parents, and legal representatives.
We respond within the time required by the applicable law, explain a permitted extension when required, and give reasons for a denial or limitation as required. Requests are generally free; a fee or refusal based on abuse, repetition, or excessiveness is permitted only where the governing law allows and with the required explanation.
To appeal a denial where an appeal right applies, email [PRIVACY_EMAIL] with "Privacy Appeal" and identify the decision. We will give a written response within the applicable deadline and explain available regulator complaint options. You may contact your state attorney general or competent privacy regulator without first completing our internal process.
16. CHILDREN AND TEENAGERS
The Services require a minimum age of 13, subject to any higher requirement in a user's location. They are not directed to children under 13. We do not knowingly collect personal information from children under 13 in violation of applicable law. A contractual age limit does not allow us to ignore credible information that a user is underage or to avoid additional protections for teenagers.
If you believe we collected information from a child who is not eligible to use the Services, contact info@solesmiling.com. We will assess the concern, restrict access where appropriate, and delete information or take other steps required by law. We may retain a limited record if necessary and lawful to address safety or prevent renewed unauthorized use.
Where eligible teenagers use the Services, applicable law may require stronger privacy defaults, restrictions on profiling or advertising, age-appropriate explanations, specific consent, or parental involvement. Our actual youth features and controls are described here: [YOUTH_PRIVACY_CONTROLS]. A general consent checkbox or parental statement does not replace those requirements.
Parents and guardians may contact us about applicable rights. We verify authority proportionately and respect the teenager's own rights under local law. Users should avoid posting identifying information about children without appropriate authority and consideration of the child's safety.
17. INTERNATIONAL PROCESSING
Our operations are based in the United States. Personal information may be processed in countries in which our enabled providers operate. The actual locations or meaningful location categories and the relevant providers are: [PROCESSING_LOCATIONS]. Other countries may have different privacy rules and lawful-access regimes.
Where a transfer is subject to a legal safeguard requirement, our applicable mechanisms and safeguards, relevant limitations, and how to request information or a copy are: [INTERNATIONAL_TRANSFER_SAFEGUARDS]. A provider's certification does not mean Sole Smiling itself is certified under a framework.
Using the Services does not constitute blanket consent to an international transfer that needs a separate legal mechanism. Contact info@solesmiling.com for information about applicable safeguards, with legally permitted redactions for confidentiality.
18. EEA, UNITED KINGDOM, AND SWITZERLAND
This section applies to processing subject to the applicable European, UK, or Swiss data protection law; it does not imply that every activity falls within every law.
We identify a lawful basis for each relevant processing activity. For account functions and delivery of content or messages you request, we rely on contractual necessity only to the extent that processing is objectively needed for that service. This does not make every analytics, advertising, or improvement activity necessary to perform a contract.
For proportionate service security, abuse prevention, and basic operational diagnostics, we may rely on legitimate interests after considering necessity, your reasonable expectations, and your rights. The interests are protecting accounts and users, keeping media delivery reliable, and preventing fraudulent activity. We use a different basis when required.
The specific lawful basis and necessity explanation for profile-linked viewing analytics and any personalization are: [PROFILE_ANALYTICS_LEGAL_BASIS]. Consent is used for optional activities where required, including non-exempt device tracking and relevant marketing. We rely on a legal obligation for processing needed to comply with a law that applies to us. Any processing of special-category information requires an additional applicable condition, identified in the relevant notice or consent; a general legitimate interest alone is insufficient.
If you do not provide information needed to register or perform a feature you request, we may be unable to provide that feature. Optional processing must be distinguished from required information. You can withdraw consent without affecting the lawfulness of processing before withdrawal. Where processing is based on legitimate interests, you may object based on your circumstances; objections to direct marketing are honored as required by law.
You may exercise applicable access, rectification, erasure, restriction, objection, and portability rights through Section 15. We ordinarily respond to GDPR or UK GDPR rights requests within one month, with an extension of up to two further months where legally permitted for complexity or number of requests and with notice during the first month. Other applicable laws may set different rules.
You may complain to your local supervisory authority, including the UK Information Commissioner's Office or the Swiss Federal Data Protection and Information Commissioner where appropriate. You do not have to contact us first.
EU representative, if required: [EU_REPRESENTATIVE_DETAILS]
UK representative, if required: [UK_REPRESENTATIVE_DETAILS]
Data protection officer or designated privacy contact: [DPO_OR_PRIVACY_CONTACT_DETAILS]
19. U.S. STATE PRIVACY RIGHTS AND CALIFORNIA DISCLOSURES
Where a U.S. state privacy law applies to you and our processing, you may exercise the rights described in Section 15, including applicable opt-outs and appeals. The exact scope and exceptions depend on the state and our activities. A small business is not automatically exempt from every privacy, child-safety, security, or disclosure requirement.
For California consumers when the CCPA applies, this includes applicable rights to know categories and specific pieces of information, correct, delete, receive portable information, opt out of sale or sharing, limit qualifying sensitive-information uses, and be free from unlawful discrimination. Appendix A identifies categories, sources, purposes, and recipients; Section 9 provides sale and sharing disclosures; Section 12 explains retention. This Policy must be reviewed and updated at least as often as applicable law requires, including the CCPA's annual update requirement where applicable.
For a covered California access, correction, or deletion request, we confirm receipt within 10 business days and ordinarily respond within 45 calendar days. A further 45-calendar-day extension is used only when permitted and explained within the initial period. Sale or sharing opt-outs have a different timetable: we act as soon as feasibly possible and no later than 15 business days, subject to requirements that particular signals or technologies demand. We apply shorter or different deadlines where another applicable law requires them.
The actual sensitive-information uses and whether they create a right to limit are disclosed in Section 8. If such a right applies, the mechanism and scope are: [SENSITIVE_INFORMATION_LIMIT_METHOD]. Do not assume that an access credential or private message may be used for unrelated profiling merely because we need it for a service function.
Financial incentives or price/service differences related to personal information, if any: [FINANCIAL_INCENTIVE_STATUS]. Any covered program requires its own legally compliant notice and participation choice; a social interaction count does not by itself create such a program.
California residents may contact [PRIVACY_EMAIL] about applicable disclosures of personal information to third parties for those parties' direct marketing under California's Shine the Light law. Eligible registered California minors may also request removal of content they posted where the applicable minor-content law applies; removal can have statutory exceptions and may not erase third-party copies.
Nevada residents may submit an applicable request to opt out of covered sales at [PRIVACY_EMAIL]. Definitions and exceptions differ from other state laws. Additional applicable state rights, such as rights concerning specific recipients or consumer health information, remain available even if not separately named here.
20. AUTOMATED PROCESSING AND CONTENT ORDERING
We use software to process uploads, maintain counts, apply selected categories or following filters, and order content using factors such as recency, likes, popularity, and randomized selection. These routine functions should not be confused with a representation that every user is subject to an individualized interest profile.
Our use of individualized recommendation profiles, automated moderation, or decisions with legal or similarly significant effects, including relevant information used, purposes, effects, and review options, is: [AUTOMATED_PROCESSING_DETAILS]. Before introducing a use that requires additional notice, assessment, or consent, we complete those steps.
21. CHANGES TO THIS POLICY
We update this Policy when our practices or legal requirements change and identify the revised date. We provide additional notice of material changes when appropriate or required. If a new use or disclosure requires renewed or separate consent, we obtain it before the affected processing.
A posted update alone does not retroactively supply consent or authorize an incompatible use of information already collected. Prior choices remain effective according to their scope and applicable law. You can contact info@solesmiling.com for information about material changes or an accessible copy.
22. CONTACTS
Sole Smiling LLC
Connecticut, United States of America
Privacy questions, rights requests, and privacy appeals: info@solesmiling.com
Privacy request form: https://www.solesmiling.com/privacy
Account deletion: Reach out to info@solesmiling.com for all help in this matter
Support and accessibility: info@solesmiling.com
Security concerns: info@solesmiling.com
Safety and content concerns: info@solesmiling.com
Intimate-image removal: https://www.solesmiling.com/privacy
APPENDIX A — PERSONAL INFORMATION INVENTORY AND CALIFORNIA HISTORY
DRAFTING NOTE: This is a proposed category map based on the described service. Confirm actual collection, disclosures, and sale/sharing for the preceding 12 months, including discontinued integrations. Do not publish a hypothetical inventory. Replace the status fields and remove this drafting note after review. The detailed provider list in Section 7 and sale/sharing statement in Section 9 must agree with this appendix.
Lookback period: [CALIFORNIA_LOOKBACK_PERIOD]
A1. Identifiers and account contact information
Examples: email, username, account/profile ID, session or device identifiers, IP address, and an optional name.
Sources: you, the device connection, authentication providers, and invitation senders where relevant.
Purposes: account administration, communications, feature delivery, security, and relevant analytics.
Recipients: authentication, hosting, storage, communications, security, and support providers; public audiences receive only information designated public; legal recipients receive information only as described in Section 7.
Collected/disclosed status and any historical differences: [CA_IDENTIFIERS_STATUS].
A2. Personal information categories listed in California Civil Code section 1798.80(e)
Examples relevant to these Services: a supplied name or other contact information, as specified in the collection disclosure below. The statutory category is broader than the information necessarily collected by the Services.
Sources, purposes, and recipients: those applicable to the particular information in Sections 2, 4, 5, and 7.
Collected/disclosed status and actual categories: [CA_CUSTOMER_RECORDS_STATUS].
A3. Internet or other electronic network activity
Examples: pages and media accessed, viewing durations, repeat plays, searches, likes, follows, playback diagnostics, and profile-linked usage totals.
Sources: interaction with the Services, devices, and enabled providers.
Purposes: service delivery, discovery, performance measurement, abuse prevention, and the specifically disclosed analytics or advertising purposes.
Recipients: relevant hosting, analytics, security, and technical providers; creators or users only to the extent specified in Section 6 and the analytics-visibility disclosure.
Collected/disclosed status and historical differences: [CA_ACTIVITY_STATUS].
A4. Audio, electronic, visual, or similar information
Examples: uploaded photographs, videos, audio, avatars, messages, and support submissions.
Sources: you, other users, and information submitted in reports.
Purposes: content delivery, communications, moderation, support, and rights handling.
Recipients: the audience selected for the content; media-processing, hosting, storage, delivery, moderation, and support providers; lawful recipients when required.
Collected/disclosed status and historical differences: [CA_MEDIA_STATUS].
A5. Geolocation information
This category distinguishes IP-derived approximate location, locations people disclose in content, and precise device location. Actual collection and purposes are specified below.
Sources and recipients: relevant device or submitted-content sources and enabled providers, plus a selected public or restricted audience for user-posted location information.
Collected/disclosed status, purposes, and actual precision: [CA_LOCATION_STATUS].
A6. Inferences
This category covers any interest, preference, relationship, or other profile inferred from activity, as identified below. Cumulative activity counts do not necessarily mean a detailed interest profile is created.
Sources: only the actual source data identified above.
Purposes and recipients: only those actually used for the described inference, specified here.
Collected/disclosed status, examples, purposes, and recipients: [CA_INFERENCES_STATUS].
A7. Sensitive personal information
This category includes account login information combined with access credentials, qualifying private communications where we are not the intended recipient, and any sensitive information actually collected or inferred from content. The actual categories collected, including any precise geolocation, biometric identifiers, or health information, are specified below.
Sources: relevant account, device, user-content, or inference sources.
Purposes: the specific uses disclosed in Section 8, including necessary authentication or delivery of restricted communications where applicable.
Recipients: providers and selected recipients needed for the relevant function, and lawful recipients under Section 7, subject to heightened restrictions.
Actual categories, collected/disclosed status, purposes, and recipients: [CA_SENSITIVE_STATUS].
A8. Remaining statutory categories and additional historical collection
This disclosure addresses commercial information, protected-classification characteristics, professional or employment information, nonpublic education information, and biometric information, distinguishing user-submitted content from deliberate structured collection and identifying sources, purposes, and recipients for categories actually collected.
Disclosure: [CA_OTHER_CATEGORIES_STATUS].
For each category above, sale and sharing status and recipients are specified in Section 9. Retention is described in Section 12, and request methods and rights are described in Sections 15 and 19.
APPENDIX B — COOKIE AND SIMILAR-TECHNOLOGY NOTICE
DRAFTING NOTE: Populate this appendix from a real audit of the website, widgets, embedded media, and apps. A generic Wix cookie list is not a complete inventory of custom code and installed integrations. Remove this note after review.
Manage choices at: [COOKIE_SETTINGS_METHOD]
Complete inventory: [COOKIE_AND_TRACKER_INVENTORY].
The inventory identifies, for each actual technology:
1. Name or meaningful identifier, domain, and provider.
2. Whether it is a cookie, local-storage entry, pixel, SDK, embedded service, or server-side integration.
3. Its specific purpose and information processed.
4. Whether it is essential, functional, analytics, or advertising, based on its actual use.
5. Its lifetime or retention criterion, including relevant server-side retention.
6. Whether information goes to a provider acting only on our behalf or to an independent third party.
7. Whether it operates before a choice, requires consent, supports an opt-out, or falls within a specifically assessed exception.
8. How to change the choice, including any effect on a requested feature.
Categories are explained below; the inventory identifies which are actually used:
Essential: technologies needed to provide a function you request, establish a session, protect access, or remember privacy choices. The label does not cover every measure convenient for the business.
Functional: optional preferences or enhanced features where not covered by an applicable essential-use exception.
Analytics: performance or usage measurement, including any persistent identifiers. Profile-linked watch statistics and anonymous platform-wide counts have different privacy implications.
Advertising: technologies used to select or measure advertising, associate activity across services, or build audiences, if enabled.
We honor applicable consent, withdrawal, and opt-out requirements. A choice about browser storage must also be respected by related server-side processing where required. Information about older Do Not Track signals, Global Privacy Control, cross-site collection, and video-viewing disclosures is in Sections 9 and 10.
END OF PRIVACY POLICY
