SoleSpark Privacy Policy

1. Introduction

ToeBros LLC (“Company,” “we,” “us,” or “our”) operates the SoleSpark mobile application (the “App” or “Platform”). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our App, which provides social connection services and an e-commerce marketplace for the foot enthusiast community.

By accessing or using the App, you consent to the collection and use of your information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

1.1 Special Notice Regarding Sensitive Personal Data

IMPORTANT: Our Platform collects information about your personal interests and preferences that may reveal information about your sexual preferences or behavior. Under applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and certain U.S. state privacy laws, this constitutes “special category” or “sensitive” personal data that requires your explicit consent to process.

By creating an account and selecting your interests/preferences during profile setup, you explicitly consent to our processing of this sensitive personal data for the purposes described in this Privacy Policy. You may withdraw this consent at any time by deleting your account.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when creating an account and using the Platform:

• Account Information: Name, email address, date of birth, and password
• Profile Information: Gender identity, profile photos, shoe size, height (optional), weight (optional)
• Interest and Preference Data: Your selected interests and preferences (e.g., Worship, Massage, Domination, Roleplay, Humiliation, Licking, Shoes, Boots, Sniffing, Tickle, Food Play, Trampling, Teasing, Sleeping Feet, Pedicure, Foot Stool, and others)
• Communication Data: Messages exchanged with other users through our direct messaging feature
• Marketplace Data: Product listings, transaction history, and shipping addresses
• Verification Data: Photo verification images; for sellers, government-issued identification and tax documentation (W-9/1099 forms when applicable)

2.2 Information Collected Automatically

When you use the App, we automatically collect:

• Device Information: Device type, operating system, unique device identifiers
• Usage Data: App features accessed, time spent on the App, interactions with other users
• Log Data: IP address, browser type, access times, pages viewed
• Location Data: General location based on IP address (we do not collect precise GPS location)

2.3 Information from Third Parties

We may receive information from:

• Payment Processors: PaymentCloud (for marketplace transactions) and Apple/Google (for subscription payments) provide us with transaction confirmation and limited payment details, but not full payment card numbers
• Shipping Partners: Our double-blind shipping partner provides delivery status updates
• Authentication Services: If you choose to register or log in using a third-party service

3. How We Use Your Information

We use the collected information for the following purposes:

• To provide and maintain the Platform, including matching you with other users based on your preferences
• To process marketplace transactions and facilitate shipping
• To verify your identity and age (18+ requirement)
• To communicate with you about your account, transactions, and Platform updates
• To enforce our Terms of Use and protect against fraud, abuse, and illegal activity
• To moderate content using AI-powered tools and respond to user reports
• To comply with legal obligations, including tax reporting requirements
• To improve and optimize the Platform based on usage patterns

3.1 Legal Basis for Processing (EEA/UK Users)

If you are located in the European Economic Area or United Kingdom, our legal bases for processing your personal data are:

• Explicit Consent: For processing sensitive personal data (interest/preference data)
• Contract Performance: To provide services you have requested
• Legitimate Interests: For fraud prevention, security, and Platform improvement
• Legal Obligation: For tax reporting and compliance with applicable laws

4. How We Share Your Information

We share your information with the following categories of recipients:

4.1 Service Providers

• PaymentCloud: Payment processing for marketplace transactions (classified as high-risk merchant processing; funds may be held in reserve per their policies)
• Apple/Google: Subscription payment processing
• Double-Blind Shipping Partner: Facilitates anonymous shipping between buyers and sellers (holds shipping addresses temporarily for fulfillment)
• AI Content Moderation Services: Third-party AI tools that analyze uploaded content for policy violations
• Cloud Hosting Provider: U.S.-based servers that store Platform data

4.2 Other Users

Your profile information, including your selected preferences/interests, photos, and display name, is visible to other users of the Platform in accordance with your privacy settings. Your shipping address is NOT shared with other users; it is only provided to our shipping partner.

4.3 Legal and Safety Disclosures

We may disclose your information:

• To comply with applicable laws, regulations, or legal process (including subpoenas and court orders)
• To respond to lawful requests from law enforcement or government authorities
• To protect the rights, property, or safety of the Company, our users, or others
• In connection with a merger, acquisition, or sale of assets

5. Data Retention

We retain your personal information for the following periods:

Note: Certain data may be retained longer if required by law or necessary for legitimate business purposes such as resolving disputes or enforcing our agreements.

6. International Data Transfers

Your personal data is stored on servers located in the United States. If you are accessing the Platform from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States.

For users in the European Economic Area, United Kingdom, or Switzerland, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission as our legal mechanism for transferring personal data to the United States. By using the Platform, you consent to the transfer of your information to the United States.

7. Your Privacy Rights

7.1 Rights for All Users

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate personal data
• Deletion: Request deletion of your personal data (subject to legal retention requirements)
• Account Deletion: Delete your account through the App settings, which will result in deletion of your personal data in accordance with GDPR requirements

7.2 Additional Rights for EEA/UK Users (GDPR)

• Portability: Receive your personal data in a structured, machine-readable format
• Restriction: Request restriction of processing in certain circumstances
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for processing of sensitive personal data at any time
• Lodge Complaint: File a complaint with your local data protection authority

7.3 Additional Rights for California Residents (CCPA/CPRA)

• Right to Know: Request disclosure of personal information collected, used, and shared
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of the “sale” or “sharing” of personal information (Note: We do not sell personal information)
• Right to Non-Discrimination: Not be discriminated against for exercising privacy rights
• Right to Limit Use of Sensitive Personal Information: Direct us to limit the use of sensitive personal information to purposes necessary to provide services

To exercise these rights, please contact us at hello@solespark.com or use the in-app settings. We will respond to requests within 30 days (or 45 days for CCPA requests).

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal data, including:

• Encryption of data in transit (TLS) and at rest
• Secure authentication and access controls
• Regular security assessments
• Employee training on data protection
• Screenshot prevention technology within the App

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

9. Third-Party Links and Services

The Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access.

10. Children's Privacy

The Platform is strictly for users 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal data from a minor, we will take steps to delete that information immediately.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. For significant changes, we will provide additional notice (such as adding a statement to the App's homepage or sending you a push notification).

Your continued use of the Platform after such modifications constitutes your acknowledgment of the modified Privacy Policy.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

ToeBros LLC
418 Broadway STE R, Albany, NY, 12207, USA
Email: hello@solespark.com
Phone: 917-848-4882

For EEA/UK users, you may also contact your local data protection authority.

13. California Privacy Notice

This section applies to California residents and supplements the information in this Privacy Policy.

Categories of Personal Information Collected: Identifiers (name, email), protected characteristics (gender identity), commercial information (transaction history), internet activity (usage data), geolocation (general location), sensory data (photos), inferences drawn from the above, and sensitive personal information (interest/preference data).

We collect this information for the business purposes described in Section 3. We do not “sell” personal information as defined under the CCPA. We may “share” personal information for cross-context behavioral advertising, but you may opt out.

To submit a request to know, delete, or opt out, contact us at hello@solespark.com. You may designate an authorized agent to make a request on your behalf.

End of Privacy Policy