Data Protection Update
On the 25th May 2018, the new General Data Protection Regulation (GDPR) came into effect. Under this new law, European standards in data protection shall align with current technology standards. This is good news for all individuals who are affected by data processing and shall maintain standards in relation to the security of your personal data.
What this means for you:
Table of Contents
1. A Special Note About Children
This Service is exclusively for adults in the UK aged 18 or older. Anyone under eighteen years of age is prohibited from using our Website or Service. Anyone outside the UK or who is in the UK but under the age of 18 should leave our website immediately and not attempt to use the Service.
2. How We Collect, Use and Disclose Information
i. What Information Do We Collect?
During any registration process for, or while using, our Service, you may choose to provide us with certain "Personal Information" including: your name and email address, billing information, "Sensitive Personal Information". When we refer to "Personal Information" in this Policy, unless we say otherwise, this includes "Sensitive Personal Information."
We may also collect information about your activities when you browse our Website or use our Service or choose to send us personal correspondence such as emails or when other users or third parties send us correspondence, which may include their comments about you. All this information will be kept in a secure file that is accessed only by authorised personnel or our business partner(s) in the course of providing the Service.
Providing your Personal Information to us is voluntary. However, if you do not provide your Personal Information to us, you will not be able to access some or all of our services.
ii. How do We Use Your Information?
If you provide Personal Information to us, we will use it to contact you about our services, to process payment for our services, and to tailor our services to your meet your preferences.
We use your Personal Information for many specific purposes, including: - communicating with you about our Service - improving and customising our content - analysing our Website usage and delivering information targeted to your preferences - providing you with information about the services provided by our Website or third parties.
We may also use your Personal Information to resolve disputes, troubleshoot problems, enforce any agreements, policies and rules governing the use of our Website and Service, and observe our Website for quality control and customer service purposes.
iii, When and to Whom Will We Disclose Your Information?
Due to the nature of the Service provided by us, some of your Personal Information may be disclosed to a third party for the purpose of providing you with the Service.
We may share or transfer your Personal Information with affiliates (and or business partners) in the course of providing the Service.
IMPORTANT: We may disclose Personal Information to third parties (for example, credit card processing companies, billing services and Phone-paid Services Authority, the UK regulator of premium rate services) as reasonably necessary or appropriate to provide the Service or resolve a complaint.
We may be required to disclose your Personal Information in order to comply with a court order or as otherwise compelled by law. In addition, we expressly reserve the right to disclose your Personal Information when we have a good faith belief that disclosure is necessary to protect our rights, to enforce our agreements, policies, and rules governing your use of our Services, to cooperate with UK law enforcement, and/or to report information concerning abuse or a threat of serious injury or death.
We DO NOT sell or rent any of your Personal Information to third parties for marketing purposes without your express permission or consent. We may, however, disclose to third-party advertisers certain aggregated or hashed (i.e., encrypted) information in a manner that no longer reflects or references an individually identifiable user, for other marketing and promotional purposes.
When you provide your Personal Information and Sensitive Personal Information to us, you consent to our use and disclosure of that information as described in this Policy. If you do not want us to use or disclose your Personal Information as described in this Policy, do not provide it to us or use the Service.
Our Website uses "cookies" to store and sometimes track information to make your online experience easier and more personalised. Cookies are small pieces of data that are stored by a user's web browser on the user's storage drive. Cookies may record information that is accessed by a user on a webpage in order to simplify subsequent interactions with our website by the same user, or to streamline the user's transactions on related webpages. Cookies make it easier for a user to move from webpage to webpage and to complete transactions over the Internet.
Most major web browsers are set up so that they will initially accept cookies, but you may modify your computer's preferences to issue you an alert when a cookie is downloaded, or to disable the ability of third parties to download a cookie to you. If you choose to reject all cookies, there may be areas of our Website that may not function properly. You may obtain further information about cookies and how they function at: http://en.wikipedia.org/wiki/HTTP_cookie
We, or a data provider or advertiser that we have engaged, may also place or recognise a cookie on your browser to enable you to receive customised content. These cookies contain no Personal Information. The cookies may reflect de-identified demographic or other data that is linked to data that you have voluntarily submitted to us (e.g., your email address or geographical location) that we may share with the data provider or advertiser.
We may also use standard Internet technology, such as web beacons or 1x1 "gifs" and other similar technologies (collectively "Pixel Tags"). A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Members and may be associated with cookies on the Members' storage drives. We use Pixel Tags to track your use of our Website, for advertising, marketing, or promotional purposes, and to determine whether you opened an email message from us. The information also enables us to customise the services we offer.
Other parties may collect Personal Information about your online activities over time and across different websites when you use our Services. We honour web browser "do not track" signals that provide you with the ability to exercise choice regarding the collection of Personal Information about your online activities over time and across third-party websites or online services, when the web browser's http header includes the field "dnt:1". We do not presently honour any other types of "Do Not Track" mechanism.
5. Your Use of Information
You may not use information you acquire in the course of using the Service, whether private or not, for commercial purposes, to spam, to harass, or to make unlawful threats. We reserve the right to block a Service User who misuses the Service or who otherwise violates another Service User or breaches our Terms of Services, policies, or rules governing the use of our Website or Service.
6. Do Not Disclose Your Personal Information in Messages
Please DO NOT include, share or disclose Personal Information that you do not wish to become public.
7. How We Protect Your Information
Our Website uses reasonable security measures to help protect and prevent the loss, misuse, and alteration of the information under our control. We use industry standard efforts, such as firewalls, to safeguard your Personal Information. While "perfect security" does not exist on the Internet, or elsewhere, our technical staff and business partners work hard to help ensure your secure use of our Service.
8. Reviewing, Updating, Accessing or Removing Your Personal Information and Registering Privacy-Related Complaints
You can contact us 24/7/365 via our contact page
Removing your Personal Information. Please note that, despite your request, we may retain in our files certain data if necessary to:
- resolve disputes
- troubleshoot problems
- comply with agreements, rules or regulations
- enhance security, reduce fraud, or comply with the law, or enforce any agreements, policies, and rules governing your use of our Website and Service.
Note that removed information may exist in backup copies or other Service Users' caches or on their mobile devices. As an example, a message exchange may remain in someone else's device. Whether your messages are kept by someone you choose to exchange messages and or images with is beyond our control.
You are entitled to contact us using the above contact page to register a privacy-related complaint. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right. We will also let you know what other complaint procedures may be available to you.
10. Terms of Service
Go to our Terms of Service
- - - - - IMPORTANT - - - - -
11. * The Right to Privacy Protection
The following provides a description of the service and covers:
a) The information we record and hold about a Service User's Service interactions (private and confidential 'Message Log')
b) Information requests made by a Service User (a person who has used, and been charged for, using the Service)
c) Third party requests for information, with or without the Service User's explicit informed consent
d) Information Requests made by the Phone-paid Services Authority (the UK regulator, known as PhonepayPlus until 1 November, 2016
e) 'Communication Data' v. 'Content Information'
f) What information we can and cannot disclose
The Service is a UK Adult 18+ Premium Rate Service ("PRS").
The 'Service' is an online adult virtual sex text service.
All Service User Service interactions are recorded and held in a comprehensive
each Message Log is stored securely in a remote location (not on our servers) and is not accessible by any third party or over the Internet.
Your Service User 'Personal Message Log'
As a Service User, your personal Message Log shows ALL your Service interactions, including free messages sent and delivered to your mobile phone.
In addition, your personal Message Log shows the precise time of each message sent/delivered and received.
For your protection and ours
In the event that you (as the Service User) query (or raise a complaint) about the Service, your personal Message Log can be accessed and referred to by us, for the purpose of dispute resolution.
Your Service interactions are private and confidential.
Query or Service Complaint - Requests for Information
What we CAN provide:
We can provide information defined as Communication Data (“CD”) such as:
1. Confirmation of the mobile number used to access the service
2. Evidence that the double opt-in requirement to use the Service was satisfied
3. What date of birth was provided
4. Evidence that cost information was provided
5. Evidence that how to opt-out was given
6. The dates and times of messages
7. Information relating to ‘System’ generated messages such as:
- Spend reminders
- Stop message confirmations
- Service User ‘swap’ messages
8. Any other information which is defined as ‘communication data’
9. 'Service information' such as:
- A description of the service and how it works
- The shortcode used to access the Service
- Details of the journey from a 'consumer' to a 'Service User'
- Information about the marketing and promotion of the service
What we CANNOT provide:
We do not have the authority to provide any information which is defined as Content
Information (“CI”) such as:
1. The content of messages
3. Video clips
We do not have authority to disclose any information which is defined as ‘Content Information’ even if you own the phone and pay the bill, because the records we hold (i.e your Message Log) will show messages sent to you by someone else and that person has privacy rights.
In relation to a Service query, request for information, the law says that any sharing of information must be necessary and proportionate.
Invasion of privacy
We have a legal obligation and an ethical duty not to allow a third party to snoop on what is essentially a private and confidential service, involving personal and confidential message exchanges between two consenting adults.
Section 7 of the Data Protection Act 1998 - Subject Access Request (“SAR”)
If a third party makes a request for information (i.e. the Phonepaid Services Authority) they have to prove they have your permission as the Service User. Only information considered to be your information can be released under a SAR. However, we won’t be able to provide the content of text messages, or photos or video clips as this information is defined as Content Information.
An individual’s Privacy Rights are protected by both UK and European Law.
What does all this mean?
It means that your private message exchanges remain private and confidential.
If you delete or lose a message(s) we do not have authority to provide you, or anyone
else, with a copy unless we are required to do so by law.
You CAN trust us
Over 100 million people use devices to access the Web and interact with others privately every day, because they feel free to have fun and express themselves. We take the security and privacy of all that self expression seriously.
Private. Confidential. Secure
Here at XXX Sex Contacts, people trust us to send their content in a way that helps them feel free to be themselves. We treat the content of all messages as private and confidential, and it’s right that we do.
As a Service User, your message exchanges (the content of your messages, including photos and video clips) are private and remain private and cannot be accessed from any records we or our partners or the networks hold without a court order. Therefore, once messages have been deleted (or if lost), it should be considered they are gone forever (save for an order by the court for us to produce a copy).
Effective date: 9th April, 2014
* Updated: 12 Sept, 2016 at 18:10
01.11.2016 - UK PRS regulator name change. As from 1 November, 2016, PhonepayPlus will be known as the Phone-paid Services Authority