Last Updated: June 2024
We use different methods to collect data from and about you including through:
using your Biometric Data to grade the risk that you are being trafficked, forced to work as an escort and/or otherwise at risk;
disclosing your Biometric Data to law enforcement in compliance with our legal obligations; and/or
disclosing your Biometric Data to law enforcement where you have been a victim of crime or where we believe that you are at risk.
The processing conditions applicable to each of the activities set out in paragraph 9.6 are as follows:
Grading risk that you are at risk – substantial public interest in (a) preventing or detecting unlawful acts and (b) safeguarding of individuals at risk.
Disclosure to law enforcement in compliance with our legal obligations – substantial public interest in preventing or detecting unlawful acts and/or legal obligation.
Disclosure to law enforcement where you are suspected/known to be a victim of crime or we suspect you are at risk – without your explicit consent.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a Registered User or Registered Escort | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Special Categories (where you are a Registered Escort) | (a) Performance of a contract with you (b) Relying on explicit consent (c) Where you are a Registered Escort, to track and monitor your online behaviour in order to assist law enforcement in their investigations |
To carry out Verification Checks (where you are a Registered Escort) | (a) Identity (b) Contact c) Profile | (a) Performance of a contract with you (b) Relying on explicit consent (c) Necessary to comply with a legal obligation |
To process Service requests and ad responses by unregistered users, Registered Users and/or Registered Escorts: (a) manage payments, fees and charges; and (b) collect and recover money owed to us and to Registered Users and/or Registered Escorts | (a) Identity (b) Contact (c) Financial (d) Transaction (e) User (f) Profile (g) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and prevent fraud) |
To manage our relationship with you which will include: (a) notifying you about changes to our terms or Privacy Policy; and (b) asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how Users use our Site and/or Services, so that we can develop our Services to suit the demands and preferences of those using our Site and/or Services) |
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant Site Content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (e) Usage (f) Marketing and Communications (g) Technical | Necessary for our legitimate interests (to study how Users use our products/Services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve the Site, products/Services, marketing, and User relationships and experiences. | (a) Technical (b) Usage (c) Profile | Necessary for our legitimate interests (to define types of Users for our products and Services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about products or Services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
To grade the risk that a Registered Escort is at risk – substantial public interest in (a) preventing or detecting unlawful acts and (b) safeguarding of individuals at risk. Disclosure to law enforcement in compliance with our legal obligations – substantial public interest in preventing or detecting unlawful acts and/or legal obligation. Disclosure to law enforcement where you are a victim of crime or at risk – your explicit consent.
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| (a) substantial public interest in (i) preventing or detecting unlawful acts (ii) safeguarding of individuals at risk.
(b) substantial public interest in preventing or detecting unlawful acts (c) legal obligation.
(d) consent
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Payment providers
Analytics providers
Advertising partners
Customer Service providers
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, please note that, in the event we sell our business to any third party, we may share your data with a prospective buyer and their advisors, and we will transfer your data to the buyer for the purposes of continuing to provide the Services to you.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.