Privacy Policy

Last Updated: June 10, 2020

Your privacy is important to the Adult Empire family of companies ("AdultEmpire"). When we refer to 'AdultEmpire,' we,' 'our,' or 'us' in this Privacy Policy, we are referring to Ravana, LLC, and its subsidiaries and affiliates. We realize that visiting any of the AdultEmpire websites (adultempire.com, adultdvdempire.com, dvdempire.com, gaydvdempire.com, popporn.com, gamelink.com, gay.gamelink.com, pornstarempire.com, sugarinstant.com, sugartvstore.com, tlagay.com, and tlavideo.com (the 'Websites') requires trust on your part. We value your trust very highly and pledge that we will work to protect the security and privacy of your personal information.

We believe that you have a right to know what personal data we collect from you, why we collect it and how we use it. This Privacy Policy explains how we collect, use, disclose, store and protect your personal information.

Read More About:

  1. Information Collected
  2. Uses Of Information
  3. Disclosure of Information
  4. Security
  5. Age of Consent
  6. Advertising
  7. Your Control of Your Personal Information
  8. Notice of Non-U.S. Residents; EU-US.Privacy Shield
  9. California Consumer Privacy Act ("CCPA") Privacy Notice
  10. Changes to Privacy Policy
  11. How to Contact Us

1. Information collected

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household ('Personal Information'). We receive and store information about you such as: Information you provide to us: We collect Personal Information that you choose to provide voluntarily when using the Websites. This information is summarized below.

  1. Your name, email address, postal address, telephone number, and password when you create an Account. While you can browse our online stores without opening an account, you will need to create an account in order to make purchases and take advantage of certain features.
  2. When you make a purchase using a credit card, we collect your name and billing address for the card, the card type, number and expiration date. We collect this information in order to verify your billing address. You can choose to save your billing information for one or more credit cards in "Your Account." You may change or delete this saved information anytime. Simply go to Your Account, log-in with your username and password and edit whatever personal information you wish.
  3. For DVD customers and for catalog requests, we also collect a U.S. postal address when you complete a catalog request that allows us to ship your purchase and mail your catalog.
  4. From time to time we conduct surveys and contests via our Websites, or through email or other forms of media. If you chose to participate, we may request your name, email address, mailing address and other personal information in connection with such participation.
  5. We may also ask for personal information when you contact Customer Service. This will allow us to protect your confidentiality by verifying your identity.

Information we collect automatically: As is true with most websites, we collect certain information automatically. This information includes:

  1. Internet Protocol (IP) addresses, your computer's operating system, browser type, and the IP address of a referring site, if any.
  2. 'Cookies' or similar technologies that we use to identify you when you visit the Websites, analyze trends, administer and improve the Websites, track your movements around the Websites and gather demographic information about our user base as a whole. Cookies are small, unique identifier text files that are commonly stored on your device when you browse and use browsers and online services. To shop without cookies, you can configure your browser to reject all cookies or notify you when a cookie is set. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.)
  3. We use Google Analytics to collect standard internet log information and details of visitor behavior patterns. We do this, for example, to find out the number of visitors to various parts of the Websites so that we may improve the content that is offered on the Websites. This information is only processed in a way which does not identify anyone including anonymizing the IP address. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our Websites. You can prevent your data from being used by Google Analytics on our Websites by installing the Google Analytics opt-out browser add-on here.
  4. Geolocation data, which is collected by our streaming applications, although precise geolocation data is not collected from our GPS sensors. However, we do collect IP addresses from which we may be able to determine your general location for lawful purposes such as fraud prevention and currency options.

2. Uses of Information

We use information collected on the Websites to provide, analyze, administer, enhance and personalize your shopping experience in the following ways:

  1. Deliver merchandise that you purchase online
  2. Register you as a member
  3. Bill your credit card for your purchases
  4. Confirm your shopping orders
  5. Respond to your customer service inquiries or requests
  6. If you opted-in to receive such communications, notify you about sales, promotions, and specials, as well as new features, content, and offers that compliment your shopping experience
  7. Improve our service (including user interface and user experience) and optimize our content selection and delivery
  8. Customize your shopping experience
  9. Prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enf-rce our terms of use
  10. Assist you with operational requests such as password reset requests

When you create an Account on any of the Websites or sign-up by entering your email address, after verifying that you are 18 years of age or older, you will receive via email from SugarInstant only information regarding the various aspects of Your Account, unless you also opted-in to receive marketing communications. You may opt-out of receiving marketing communications at any time, by requesting removal from SugarInstant's email and catalog mailing list as provided on the SugarInstant Websites and as described in this Privacy Policy.


3. Disclosure of Information

We do not sell or rent your Personal Information to others. We share your personal information only as described below.

  1. Related companies: We share your information among the Adult Empire family of companies as needed to: provide you with access to our services; provide customer support; improve our services; and for other purposes consistent with the Use of Information section of this Privacy Policy.
  2. Service providers: We may use other third parties to perform services on our behalf or to assist us with providing services to you. For example, we may use third parties to provide marketing, communications, infrastructure and IT services, to process credit card transactions or other payment methods, to collect debts, to analyze data, to fulfill orders for products or services, to deliver catalogs and packages, and to provide customer service. We contractually prohibit third parties from using or disclosing your Personal Information except in connection with providing their services to us.
  3. Legal protection: We may disclose or use information, including Personal Information, where we reasonably believe that disclosures is needed to: satisfy any applicable law, regulation, legal process, or governmental request; investigate violations and enf-rce applicable terms of use; detect, prevent and otherwise address illegal or suspected illegal activity such as payment fraud, data security or technical issues; or protect against harm to the rights, property and safety of Adult Empire, its users or the public, as required or permitted by law.
  4. Business transfers: If we are involved in any reorganization, restructuring, merger or sale or other transfer of all or a portion of our assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your Personal Information in a manner that is consistent with our privacy policy.

4. Security

We have implemented comprehensive data privacy and security measures designed to safeguard and protect your personal information against loss, theft and unauthorized access, use and modification. 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 ('TLS'). These measures are designed to provide a level of security appropriate to the risks of process your Personal Information. No measures can be guaranteed to provide 100% security and we cannot, therefore, guarantee the security of your Personal Information.

You 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 it anytime by going to Your Account, then click "Change Password" and enter a new password.


5. Age of Consent

The Websites contain sexually-oriented adult material and are not intended for individuals under 18 years of age. SugarInstant does not knowingly collect Personal Information from individuals under 18 years of age who visit the Websites. If a person under 18 years of age has provided SugarInstant with Personal Information, we ask that a parent or guardian immediately contact our Data Protection Officer by email at privacy@adultempire.com.


6. Advertising

We use third-party advertising linking to both websites and apps on the Adult Empire family of Websites, as well as our affiliate partners. However, we do not share or provide any personal information that we collect about you with third-parties that are not included within the Adult Empire family of companies.

If you opt-in to receive periodic news and updates from us, we may periodically send you email messages describing new items, sales, specials and other offers that we think will be of interest to you. If you would like to opt-out of receiving these emails from SugarInstant please click on Your Account click on "Notification Options" and remove the check in the box next to the "Sales & Specials" notification option. 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 periodic news and updates from us, the only email messages you will receive from SugarInstant are emails to confirm any purchases you make on our site, let you know your order has been shipped, respond to your Help Desk inquiries and to respond to inquiries you may ask about our site.


7. Your Control of Your Personal Information

Creating an account lets us provide a better shopping experience for you and allows you to make purchases more conveniently without having to re-enter your payment and shipping information each time you make a purchase on our site. Although you must create an account in order to purchase products, it is not necessary to open an account to visit our site.

As an existing customer, you can modify your personal information anytime. Simply log into Your Account then click "Contact Information" and edit whatever information you wish. To have your Personal Information deleted, please log into Your Account and follow the procedures for deleting your Personal Information. Once you request to have your personal information be 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, unless we are required by law to maintain the Personal Information.


8. Notice to Non-U.S. Residents; EU-U.S. Privacy Shield

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

The lawful basis for our processing of Information You Provide to Us is to perform or take steps to perform a contract with you (e.g., complete a sale) and the personal data 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 Information 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 US and we process personal data in the U.S. We establish appropriate and suitable safeguards for the processing of your personal information, including self-certification under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (the 'Privacy Shield Frameworks'). You may request a copy of these safeguards by emailing privacy@adultempire.com.

We maintain your Personal Information so long as you keep an account with us. You have the right to request access to, rectification, or erasure of your Personal Information, which you may exercise at any time by emailing privacy@adultempire.com. 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 data, you may lodge a complaint with the appropriate supervisory authority.

Ravana, LLC has certified compliance with the Privacy Shield Frameworks, and the lawfulness of its transfer of any data from the EU or Switzerland to the US is based on that compliance.

The Privacy Shield Frameworks as set forth by the U.S. Department of Commerce establishes requirements regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/list.

Ravana, LLC is responsible for the processing of Personal Information it receives from you and subsequently transfers to a third party for processing on our behalf. We comply with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.

With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, Ravana, LLC is subject to the regulatory enf-rcement powers of the U.S. Federal Trade Commission. In certain situations, Ravana, LLC may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enf-rcement requirements.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection and use of your Personal Information. We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution provider located in the U.S. and operated by TrustArc. You may access the TrustArc dispute resolution platform here.

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. For more information, please visit the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint. In the event that we appoint a representative in your country or region, such as an EU representative, we may direct inquiries from you or the applicable data protection supervisory authority to our representative, as applicable and appropriate.


9. California Consumer Privacy Act ('CCPA') Privacy Notice

This Privacy Notice applies to California consumers and supplements the Privacy Policy.

Read More About:

  1. Personal Information Collected
  2. Uses of CA Personal Information
  3. Categories of CA Personal Information Disclosed for Business Purposes
  4. Sources of CA Personal Information
  5. No Sales of CA Personal Information
  6. Your Rights Under the CCPA

Personal Information Collected

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household ('CA Personal Information'). We have collected the following categories of CA Personal Information from California residents within the last twelve (12) months:

  1. Use Identifiers: This category covers a broad range of information, including your name, email address, postal address, telephone number, and IP address. We collect some CA Personal Information that falls into this category. For example, when you make a purchase using a credit card, we collect your name and billing address for the card, the card type, number and expiration date. We collect this information in order to verify your billing address. For DVD customers and for catalog requests, we collect a postal address when you complete a catalog request that allows us to ship your purchase and mail your catalog. We also collect IP addresses when you connect to our service online. These sorts of identifiers are connected to your account.
  2. Characteristics of protected classifications under California or federal law: This covers a broad range of information like race, sex, marital status, among other protected classes. We do not collect this type of information when you subscribe to or purchase any SugarInstant service or product.
  3. Internet or other electronic network activity information: Our streaming services and DVD purchases are online services, so we collect CA Personal Information in this category, like your interactions with our service.
  4. Geolocation data: Our streaming applications don't collect precise geolocation data from GPS sensors. However, we do collect IP addresses from which we may be able to determine your general location.

Uses of CA Personal Information

We use categories of CA Personal Information described above for the purposes noted in the Uses of Personal Information section of our Privacy Policy. For ease of reference, that section is repeated below:

Personal information that we collect on the Websites may be used to enhance and personalize your shopping experience in the following ways:

  1. Deliver merchandise that you purchase online
  2. Register you as a member of SugarInstant
  3. Bill your credit card for your purchases
  4. Confirm your shopping orders
  5. Respond to your customer service inquiries or requests
  6. Notify you about sales and specials, as well as offers that compliment your shopping experience after you create a SugarInstant account
  7. Improve our service (including our user interface and user experience) and optimize our content selection and delivery
  8. Customize your shopping experience
  9. Determine your general geographic location, identify your Internet service provider, and help us quickly and efficiently respond to inquiries and requests
  10. Prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enf-rce our terms of use
  11. Communicate with you concerning our service so that we can send you news about SugarInstant, details about new features and content available on the Websites, special offers, and promotional announcements, unless you choose to opt-out of such communications
  12. Assist you with operational requests such as password reset requests

When you create an Account on any of the Websites or sign-up by entering your email address, after verifying that you are 18 years of age or older, you will receive via email from SugarInstant only information regarding the various aspects of Your Account, unless you also opted-in to receive marketing communications. You may opt-out of receiving marketing communications at any time, by requesting removal from SugarInstant's email and catalog mailing list as provided on the SugarInstant Websites and as described in this Privacy Policy.

Categories of CA Personal Information Disclosed for Business Purposes

The categories of third parties to who we disclose CA personal information listed above for our business are described in the Disclosure of Personal Information section of our Privacy Policy.

Sources of CA Personal Information

We explain our sources of information in the Personal Information Collected section of our Privacy Policy. Please see that section for detailed information that may be of interest to you.

No Sales of CA Personal Information

In the last 12 months, we have not 'sold' CA Personal Information relating to California residents within the meaning of the CCPA. For the purposes of this Disclosure, 'sold' means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.

Your Rights Under the CCPA

If you are a California resident, you have the right to:

  1. know what categories and specific pieces of CA Personal Information have been collected about you; the categories of sources from which CA Personal Information was collected; our business or commercial purpose for collecting, using, or disclosing CA Personal Information; the categories of third parties with whom we share CA Personal Information; the categories of CA Personal Information we have disclosed about you for a business purpose. We do not sell personal information.
  2. receive a copy of the specific CA Personal Information that we have collected about you.
  3. deletion of your CA Personal Information, subject to exceptions under the CCPA.
  4. be free from unlawful discrimination against you based on your exercise any of your CCPA rights.

You can assert these rights only where we receive a verified request from you. To make a request, or if you have a question regarding our privacy practices, please contact our Data Protection Officer at privacy@adultempire.com. As an existing customer, you can modify your personal information anytime. Simply log into Your Account then click "Contact Information" and edit whatever information you wish. To have your Personal Information deleted, please log into Your Account and follow the procedures for deleting your Personal Information. Once you request to have your personal information be 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, unless we are required by law to maintain the Personal Information.


10. Changes to this Privacy Policy

We reserve the right to change, modify or amend this Privacy Policy at any time, without prior notice, 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 Website 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 or visit any of the Websites. To find out when this Privacy Policy was last updated, please see the 'Last Updated' notice.


11. How to 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

Please note that if you contact us to assist you, for your safety and security and ours, we may need to authenticate your identity before fulfilling your request. We will address any issue to the best of our abilities.


Last Updated: June 10, 2020