Privacy Policy

This Privacy Policy is between Ravana, LLC and its subsidiaries and affiliates (“AdultEmpire,” “we,” “our,” “us,” etc.) and you, the user, (“you,” “your,” “yours,” etc.) as it relates to information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to you or your household (“Personal Information”) that we collect, use, store, protect, analyze, modify, delete, and disclose (“Process”) when you use any website owned or operated by us, including adultempire.com, adultdvdempire.com, dvdempire.com, gaydvdempire.com, popporn.com, gamelink.com, gay.gamelink.com, hotmovies.com, gayhotmovies.com, pornstarempire.com, sugarinstant.com, sugartvstore.com, tlagay.com, and tlavideo.com (“Websites”). We may freely use publicly available data and deidentified data that may identify, relate, or describe you or your household, and such data is not included within the definition of Personal Information.

We reserve the right to change, modify, or amend this Privacy Policy at any time, without prior notice, for any reason, including in response to changing legal, regulatory, or operational requirements. We encourage you to check this Privacy Policy periodically for any changes. You are responsible for regularly reviewing this Privacy Policy and your continued use of the Websites constitutes your acknowledgement and acceptance as to all such changes. If you do not agree to the terms of this Privacy Policy, then do not use the Websites. To find out when this Privacy Policy was last updated, please see the “Last Updated” notice at the top of this page.

Read More About:

1. Personal Information
2. Sources
3. Uses
4. Disclosure
5. Retention
6. Security
7. Age Restrictions
8. Controls
9. State-Specific Privacy Rights
10. Notices to Non-US Residents
11. Contact Us

1. Personal Information

We may Process the following categories of your Personal Information:

1. “Identifiers” such as your real name, alias, postal address, shipping address, username, email address, customer ID, password, IP Address, birthdate, and telephone number.
2. “Location Information” such as your general geolocation information.
3. “Financial Information” such as your billing address, bank account number, debit card number, credit card number, card type, and expiration date.
4. "Technical Information” such as your IP Address, operating system, browser type, device ID, device type, and referring websites.
5. “Historical Information” such as your browsing history, search history, online interactions, and purchase and consumption history on the Websites, but not on third-party websites.
6. “Preferences” meaning inferences we have drawn from your Personal Information to create a profile about your suspected content preferences.

We do not Process your social security number, taxpayer ID, driver’s license, passport, or other government-issued identification number or document; biometric or genetic information; health information; precise geolocation information; private messages directed to third parties; audio, electronic, visual, thermal, olfactory, or similar information; employment or educational information; nor protected characteristics such as race, ethnicity, religion, sex, gender, sexuality, citizenship, immigration status, and marital status.

2. Sources

You may directly provide us (or our third-party service providers) with:

1. Your Identifiers and Location Information through the account registration process; the age verification process; and contests we allow you to enter.
2. Your Identifiers, Historical Information, and Preferences through your search queries; the reviews, ratings, profile information, and other content that you post on the Websites; and the surveys that we ask you to complete.
3. Your Identifiers, Financial Information, Historical Information, and Preferences through the purchase process.
4. All categories of your Personal Information through your off-site contacts, interactions, and communications with us such as when you contact customer service by email or telephone or when you interact with us on social media.

We (or our third-party service providers) may also collect your Identifiers, Location Information, and Technical Information automatically from you through our servers, log files, cookies, pixel tags, web beacons, analytics services, and similar automatic processes. In some instances, you may configure your browser to reject or otherwise limit the automatic collection of your Personal Information. However, you understand and agree that rejecting or otherwise limiting the automatic collection of your Personal Information may negatively impact your user experience.

3. Uses

As reasonably necessary, we process:

1. Your Identifiers to register you as a member or otherwise provide access to the Websites, and to conduct age verification as required by law in certain jurisdictions; and to notify you of changes to our website policies.
2. Your Identifiers, Historical Information, and Preferences to notify you about sales, promotions, specials, new features, content, offers, and changes to the Website, if you opted-in to receive such communications.
3. Your Identifiers and Financial Information to bill you for your purchases; to deliver catalogs; and to fulfill and confirm fulfillment of your orders.

We may also Process all categories of your Personal Information to engage in any of the following activities, (collectively, the “Business Purposes”):

1. Provide, analyze, administer, enhance, improve, customize, and personalize the goods and services we offer on the Websites.
2. Perform age verification services in compliance with the laws in certain jurisdictions.
3. Serve and audit non-personalized and non-behavioral advertising.
4. Conduct technical research and repairs including storage, ensuring the security and integrity of the Websites and your Personal Information, and improving and analyzing the Websites and your Personal Information.
5. Process payments and collect debts.
6. Deliver catalogs and fulfill orders.
7. Provide customer support such as responding to your customer service inquiries and assisting you with password reset requests.
8. Comply with any applicable law, regulation, legal process, or governmental request.
9. Comply with a legal or tax obligation.
10. Investigate violations of and enforce our website policies.
11. Detect, prevent, investigate, and otherwise address suspected illegal activities.
12. Protect our legitimate interests and protect against harm to the rights, property, and safety of Adult Empire, our users, and any third party.
13. Engage in any other activity with your consent.

4. Disclosure

As reasonably necessary, we may disclose all categories of your Personal Information to the following categories of third parties for any Business Purpose:

1. Our third-party service providers.
2. Law enforcement authorities, governmental agencies, and private litigants.
3. Potential buyers or successors involved in any reorganization, restructuring, merger, sale, joint venture, assignment, divestiture, dissolution, bankruptcy, liquidation, or other transfer of all or a portion of our assets.
4. Other third parties with your consent.

5. Retention

We may retain all your Personal Information for so long as you maintain an account on the Websites, and for so long as reasonably necessary to fulfill any Business Purpose, whichever is longer. We may permanently delete your account and your Personal Information at any time, for any reason. We may automatically delete your Personal Information at any time, including at predesignated intervals, for any reason. We reserve the right to retain publicly available data and deidentified data indefinitely..

6. Security

We have implemented comprehensive security measures designed to safeguard and protect your Personal Information against loss, theft, and unauthorized Processing. For example, all data transmitted to or from any of our Websites is encrypted at rest and in transit using strong encryption protocols and technologies such as Transport Layer Security. These measures are designed to provide a level of security appropriate to the risks associated with your Personal Information. No measures can be guaranteed to provide 100% security, so we cannot and do not guarantee the security of your Personal Information.

You must protect your Personal Information by using a strong password for your account and keeping that password confidential. The confidentiality of your password is your responsibility to protect. You may change your password anytime by clicking “Reset Password” or some similar language during the log-in process and entering a new password.

7. Age Restrictions

The Websites contain sexually-oriented adult material and are not intended for individuals under the age of eighteen (18) or the age of majority in your jurisdiction, whichever is greater. We do not knowingly collect any Personal Information from minors. If you suspect that a has provided us with any Personal Information or otherwise accessed the Websites, please contact our Data Protection Officer by email at privacy@adultempire.com immediately.

We may require you to provide your Identifiers and Location Information to us or our third-party service providers to verify your age if you attempt to access the Websites from certain jurisdictions. You will not access any sexually-oriented materials on the Websites until you have provided the necessary Identifiers and Location Information to pass our age verification process to our satisfaction. We never have access to the Identifiers and Location Information that you provide directly to our third-party age verification service providers, and such providers automatically delete your Identifiers and Location Information after the age verification process is complete.

8. Controls

While you do not need to create an account to use the Websites, you must create an account to make purchases on the Websites, and we may require you to provide your Identifiers and Location Information to us or our third-party age verification service providers before you are granted full access to the Websites in certain jurisdictions. As a registered member, you can modify or remove certain categories of your Personal Information at any time by logging into your account and editing or deleting whatever Personal Information you wish.

We may allow users in certain jurisdictions to make certain requests related to their Personal Information, as required by law and detailed in the State-Specific Privacy Rights and the Notices for Non-U.S. Residents sections of this Privacy Policy. Unless we have a valid reason to reject your request, we will comply with requests for deletion within fifteen (15) days for residents of New Jersey and within thirty (30) days for residents of Maryland and we will comply with all other valid requests within forty-five (45) days.

You may opt-out of receiving notifications about sales, promotions, specials, new features, content, offers, and other changes to the Websites by logging in to your account, clicking "Notification Options" or some similar language, and removing the check in the box next to the option titled "Sales & Specials" or some similar language. You can also opt-out of receiving these messages by clicking the "Unsubscribe" link in the email message itself. If you do not opt-in to receive such notifications from us, the only email messages you will receive from us are emails to confirm any purchases and shipments, and to respond to your customer support inquiries.

9. State-Specific Privacy Rights

1. California: In the last twelve (12) months, we have not “sold” or “shared” your Personal Information as those terms are defined by the California Consumer Privacy Act. We do not make disclosures of your Personal Information for “direct marketing purposes” as that term is defined by California’s Shine the Light law. If you are a resident of California, you have a right to know the categories of Personal Information that we have collected about you, the sources of your Personal Information, the business purposes that we collected your Personal Information, and the categories of third parties to whom we have disclosed your Personal Information. Such information is laid out in the preceding sections of this Privacy Policy. If you are a resident of California, you also have a right to know the specific pieces of Personal Information that we have collected about you, and you have the right to, no more than twice per year, send us a request by emailing privacy@adultempire.com to (i) delete your Personal Information, (ii) correct inaccuracies in your Personal Information, and/or (iii) obtain a copy of your Personal Information.
2. Colorado: We do not meet the triggers of the Colorado Privacy Act.
3. Connecticut: We do not meet the triggers of the Connecticut Data Privacy Act.
4. Delaware: We do not meet the triggers of the Delaware Personal Data Privacy Act.
5. Florida: We do not meet the triggers of the Florida Digital Bill of Rights.
6. Indiana: we do not meet the triggers of the Indiana Data Privacy Law.
7. Iowa: We do not meet the triggers of the Iowa Consumer Data Protection Act.
8. Kentucky: We do not meet the triggers of the Kentucky Consumer Data Protection Act.
9. Maryland: If you are a resident of Maryland, you may, no more than once per year, send us a request by sending an email to privacy@adultempire.com to: (i) confirm whether we are processing your Personal Information, (ii) access your Personal Information, (iii) correct inaccuracies in your Personal Information, (iv) delete your Personal Information, and/or (v) obtain a copy of your Personal Information that is collected by automatic means. We do not maintain a list of third parties to whom we have disclosed your Personal Information, but you may access a list of categories of third parties to whom your Personal Information has been disclosed under the Disclosures section of this Privacy Policy. We do not (i) use your personal information for targeted advertising, (ii) sell your personal information, nor (iii) use your personal information for profiling in furtherance of solely automated decisions that results in the provision or denial of certain protected services.
10. Minnesota: We do not meet the triggers of the Minnesota Consumer Data Privacy Act.
11. Montana: We do not meet the triggers of the Montana Consumer Data Privacy Act.
12. Nebraska: If you are a resident of Nebraska, you may, no more than twice per year, send us request, or appeal a prior request, by sending an email to privacy@adultempire.com to: (i) confirm whether we are processing your personal information, (ii) correct inaccuracies in your personal information, (iii) delete your personal information, and/or (iv) obtain a copy of your personal information that we collect throughout automated means. We do not (i) use your personal information for targeted advertising, (ii) sell your personal information, nor (iii) use your personal information for profiling in furtherance of a decision that results in the provision or denial of certain protected services.
13. Nevada: We do not meet the triggers of Nevada Revised Statute Chapter 603A. While we do not sell your personal information, Nevada residents may submit an opt-out request to privacy@adultempire.com which we will honor if we sell your personal information at a future date.
14. New Hampshire: We do not meet the triggers of the New Hampshire Privacy Act.
15. New Jersey: If you are a resident of New Jersey, you may send us a request by sending an email to privacy@adultempire.com to: (i) confirm whether we are processing your Personal Information, (ii) correct inaccuracies in your Personal Information, (iii) delete your Personal Information, and/or (iv) obtain a copy of your Personal Information.
16. Oregon: We do not meet the triggers of the Oregon Consumer Privacy Act.
17. Rhode Island: We do not meet the triggers of the Rhode Island Data Transparency and Privacy Protection Act.
18. Tennessee: We do not meet the triggers of the Tennessee Information Protection Act.
19. Texas: If you are a resident of Texas, you may, no more than twice per year, send us request, or appeal a prior request, by sending an email to privacy@adultempire.com to: (i) confirm whether we are processing your personal information, (ii) access your personal information, (iii) correct inaccuracies in your personal information, (iv) delete your personal information, and/or (v) obtain a copy of your personal information. We do not (i) use your personal information for targeted advertising, (ii) sell your personal information, nor (iii) use your personal information for profiling in furtherance of a decision that results in the provision or denial of certain protected services.
20. Utah: We do not meet the triggers of the Utah Consumer Privacy Act.
21. Virginia: We do not meet the triggers of Virginia’s Consumer Data Protection Act.

10. Notices to Non-US Residents

The General Data Protection Regulation 2016/679 (GDPR) grants certain rights to individuals in the EU related to our processing of their Personal Information. Under the GDPR, Ravana, LLC is the data controller of your Personal Information, and you may contact Ravana at privacy@adultempire.com. The purposes of our processing are set out in the Uses section of this Privacy Policy.

The lawful basis for our processing of Personal Information that you provide to us is to perform or take steps to perform a contract with you (e.g., complete a sale) and the Personal Information you provide is necessary to consummate the sale. As to marketing communications, the lawful basis for us to transmit those communications to you is your consent to receive those communications, which you can withdraw at any time.

The lawful basis for the processing of Personal Information that we collect automatically is our legitimate interest in delivering the Websites to you and monitoring and improving our Websites and service offerings.

Ravana is headquartered in the U.S. and we process Personal Information in the U.S. We establish appropriate and suitable safeguards for the processing of your personal information.

We maintain your Personal Information so long as you keep an account with us. You have the right to request access to and rectification of your Personal Information, which you may exercise at any time by emailing privacy@adultempire.com. To have your Personal Information deleted, please log into your account and follow the procedures for deleting your Personal Information as detailed herein. Once you request to have your Personal Information deleted, it will be permanently removed by and from Ravana, LLC, along with your complete purchase history and library within thirty (30) days of your deletion request, unless we are required by law to maintain the Personal Information. Further, if you have consented to receive marketing communications from us, you may withdraw your consent at any time.

If you have a complaint about our handling of your Personal Information, you may lodge a complaint with the appropriate supervisory authority.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our Data Privacy Officer at privacy@adultempire.com. Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

11. Contact Us

If you have any questions about your account or how to contact customer service for assistance, please contact our Customer Service department. For questions specifically about this Privacy Policy or our use of your Personal Information, please contact our Data Protection Officer by email at privacy@adultempire.com or by conventional mail at:

Ravana, LLC
Attn: Data Protection Officer
2140 Woodland Rd.
Warrendale, Pennsylvania U.S.A. 15086

For safety and security reasons, we may require you to authenticate your identity before fulfilling any request or otherwise assisting you with questions related to this Privacy Policy.

Last Updated: October 1, 2024