Cookie Policy

Circles.London and SwingCircles.com are two websites operated by the same sole trader, Samantha Dee trading as Circles.London and Swingcircles.com. They are not two unrelated businesses, and the use of two domains is not intended to obscure who is responsible for either website.

Circles.London is the public-facing information, editorial, advertising, market-research and waitlist site. SwingCircles.com is the main private adult community platform for registered and verified members. We use separate domains to keep public information and private member services distinct, apply appropriate access and security controls, and support the staged development of the service. This separation is about clarity and privacy, not about hiding who operates either site.

The services are provided by:

Samantha Dee, trading as Circles.London and Swingcircles.com (referred to as “we” in this document set)
Business correspondence address: A BC address follows as soon as it is created.
Support Email: support@circlestech.atlassian.net

We do not have an email address for every ‘department’. This email creates a support ticket in our ‘back end management system’ which is hosted by Atlassian. Because we want ‘one single point of truth’ for all, not twenty inboxes.

Cookies are small text files placed on your computer, phone, tablet or other device when you visit a website. They can allow a website to remember your device, maintain a login session, remember a preference, protect an account, understand how the site is being used or support advertising.

The same rules can apply to technologies that do not use traditional cookies, including pixels, tags, scripts, local storage and other methods of storing information on, or accessing information from, your device. This policy uses “cookies” as a short way of referring to cookies and those similar technologies.

We group cookies by what they do rather than simply by who provides them.

Strictly necessary cookies

These cookies are needed for a service you have requested or for the basic security and operation of the websites. They may be used to:

• keep pages and forms working;
• maintain a secure login session on SwingCircles.com;
• protect the sites from abuse, fraud, malicious traffic and automated attacks;
• route traffic through our hosting or content-delivery services;
• remember your cookie choices; and
• support a payment, verification or other secure process that you have actively started.

Strictly necessary cookies do not require consent where they are genuinely necessary for the service or feature requested. We will still explain them clearly and will not describe optional cookies as essential simply because they are convenient.

Preference or functional cookies

These cookies remember choices that improve your experience but are not always essential to provide the website. For example, they may remember display, language or feature preferences.

We will ask for your permission before using preference or functional cookies where the law requires permission. If you reject them, the sites should remain usable, although some preferences may not be remembered.

Analytics and statistical cookies

These cookies or similar technologies help us understand how people use the public site and improve its content, design, performance and reliability. They may record information such as pages viewed, approximate location, device type, referring page and interactions with site features.

Analytics technologies will be treated as optional unless a particular technology clearly falls within a legal exception that applies to the way we use it. Our default approach is to keep analytics disabled until you give permission.

Marketing and advertising cookies

These cookies, pixels or similar technologies may be used to measure advertising, limit repeated advertisements, understand whether a campaign has worked or support advertising displayed on Circles.London. They may include technologies associated with advertising partners, social-media platforms or WordAds if advertising is active.

Marketing and advertising technologies will not be loaded until you give the relevant permission. They will not be used on SwingCircles.com to target you based on sensitive adult-community information.

When you first visit a site, our consent mechanism should offer clear choices such as:

• Accept all;
• Reject all; and
• Customise.

Essential cookies may operate without consent where they meet the strictly necessary exception. Optional categories should be switched off by default. Choosing “Reject all” should leave only essential cookies and technologies operating.

You can change or withdraw your optional cookie choices at any time through the [Cookie Settings / Manage Cookies link] in the site footer or through the cookie control available on the relevant site. Withdrawing permission will stop future use of the relevant optional technologies, although it may not undo processing that took place before you changed your choice.

We will keep a record of cookie choices where needed to remember and respect them. If the purposes or providers change materially, we may ask for fresh permission.

We do not treat simply continuing to browse as consent to optional cookies. Optional cookies and similar technologies should not be loaded before the relevant choice has been made.

The precise cookies used can change when we add, remove or configure a WordPress theme, plugin, security service or member feature. The live cookie settings panel and cookie inventory should therefore be checked whenever the sites are updated.

The following providers and technologies are relevant to the current or planned service:

Some providers may process technical information outside the UK or European Economic Area. Their own policies explain their wider processing, international transfers and retention practices. Our [Privacy Policy link] explains how personal information generated through these technologies is handled by us.

The exact name, provider, purpose, type and duration of each cookie should be shown in the live cookie-preference panel or a linked cookie table. Cookie names and durations can change when a plugin, theme, consent tool or security configuration changes.

Before either site is treated as fully launched, we will complete and maintain a technical cookie inventory covering both domains. That inventory should record, at minimum:

• the exact cookie or technology name;
• the domain and provider responsible;
• whether it is a first-party or third-party technology;
• its purpose and category;
• whether it is a session or persistent technology;
• its duration or expiry; and
• the consent or legal exception relied upon.

Cookies will not be kept for longer than reasonably necessary for their stated purpose. Where a provider controls the expiry of its own cookie, its stated retention period may apply, subject to our configuration and applicable law.

Our policy explains how cookies are used in connection with Circles.London and SwingCircles.com. It does not replace the privacy or cookie policies of third-party providers.

Relevant supporting policies may include:

• Hostinger Cookie Policy
• Cloudflare Cookie Policy
• Cloudflare Cookies documentation
• WordPress.com Cookie Policy
• Automattic privacy notice for visitors to users’ sites
• Stripe Privacy Centre
• Meta Privacy Policy

The list will be updated if a provider is added and the provider’s technology is used on either site. A link to a provider’s policy does not make that provider responsible for our own failure to describe or control cookies used on our sites.

If you follow a link or open an embedded service operated by another website, that website may set its own cookies or use similar technologies. Its cookie and privacy policy will apply. We cannot control those technologies once you leave our sites, and we recommend checking the third party’s information before submitting personal information or continuing to use its service.

Most browsers (Internet Explorer, Mozilla Firefox, Google Chrome for example) allow you to view, delete or block cookies through their privacy settings. Blocking all cookies may affect the operation of the websites, especially login, security, forms, payment and verification features. Browser controls do not necessarily replace the consent choices offered by our sites, particularly where similar technologies are used.

Cookies may involve personal information, such as an IP address, online identifier, device information or information about how you use a site. Where that happens, the processing is also covered by our [Privacy Policy link].

The use of cookies and similar technologies is governed in the UK primarily by the Privacy and Electronic Communications Regulations 2003 (PECR), alongside the UK GDPR and Data Protection Act 2018 where personal information is involved. Where EU law applies, we will also consider applicable EU data-protection and electronic-privacy requirements.

We may update this Cookie Policy when our websites, plugins, providers, advertising arrangements, consent mechanism or legal obligations change. The latest version will be published on the relevant site, with the update date shown at the top. If a change is significant, we will take additional steps to bring it to your attention where required.

If you have a question about our use of cookies, cannot change your choices or believe optional technologies have been used without permission, contact:

Please contact us first so we can investigate. You can also complain to the Information Commissioner’s Office in the United Kingdom. If you are in the European Economic Area, you may also contact the data-protection supervisory authority in the country where you live, work or believe an infringement took place.