Content Moderation 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.

Circles is intended to be a private adult community built around mutual respect, consent and personal responsibility. Content moderation exists to help protect members, staff and the public; support a lawful and respectful service; and deal with content or behaviour that breaches our rules or creates a serious safety risk.

We use a combination of platform design, member reports, automated tools, human review and account-level safety measures. We aim to act promptly and proportionately, while recognising that moderation decisions are sometimes made with incomplete information and that no online service can identify or prevent every harmful interaction.

We do not promise that every profile, message, image, video, live interaction or listing will be reviewed before another member sees it. We also do not promise that the service is completely free from illegal, abusive, misleading or upsetting material. If you see something that concerns you, report it rather than assuming that somebody else will do so.

Moderation may apply to:

• public pages, articles, comments and waitlist submissions on Circles.London;
• member profiles, profile photographs, descriptions and preferences;
• connection requests, messages and other member communications;
• photographs, videos, audio and other uploaded media;
• live video rooms, room chat, usernames and displayed material;
• club, venue and event listings;
• links, advertisements or promotional material submitted through the service;
• account activity, verification information and attempts to evade restrictions; and
• reports, complaints, appeals and safety-related communications.

We may also consider activity outside the platform where it is directly connected to the service, involves misuse of Circles or SwingCircles, or creates a credible safety, legal or security risk for members or the service. We will take care not to treat unverified allegations or unrelated private conduct as proof of a breach.

Members must follow the Terms of Service, Community Guidelines and Acceptable Use Policy, and any feature-specific rules shown on the platform. In particular, we do not permit content or behaviour involving:

• people under 18, or sexual content involving anyone who is or may be under 18;
• sexual exploitation, trafficking, grooming or the sexual abuse of a person who cannot freely consent;
• threats, stalking, harassment, intimidation, coercion or abusive behaviour;
• repeated unwanted messages, sexual pressure or attempts to bypass a clear refusal;
• intimate images, videos or sexualised depictions shared without the subject’s specific permission;
• non-consensual or deceptive intimate material, including altered or AI-generated depictions of a real person;
• recording, screen-capturing, photographing or redistributing another member or a live room without the required permission;
• doxxing or sharing someone’s address, workplace, contact details, identity or other private information without permission;
• impersonation, fraud, catfishing, financial scams or misleading claims about identity, age or relationship status;
• unlawful sexual services, criminal activity, drugs, weapons or instructions intended to facilitate crime;
• hate, threats of violence or material intended to encourage violence against a person or protected group;
• malware, phishing, hacking, scraping or attempts to compromise the service;
• commercial promotion, recruitment or advertising without permission; or
• deliberate evasion of a block, moderation action, suspension or account restriction.

Legal adult content is not automatically prohibited simply because it is sexual. It must still comply with the applicable feature rules, consent requirements, age restrictions, privacy rights and the law. We may restrict content that is legal but unsuitable for a particular feature, audience or level of access.

The quickest way to report a member, message, profile, image, video, live-room interaction or listing is to use:

Report a Violation: support@circlestech.atlassian.net

Please include enough information for us to locate the concern, such as the username, profile or content link, the date and time, and a short explanation of what happened. If the concern relates to a message or live room, tell us which account or room was involved.

Do not put yourself at risk to collect evidence. Do not confront the person you are reporting, arrange another interaction to obtain proof, or encourage others to contact them. Screenshots or other supporting information may help, but you should not send identity documents, passwords or intimate material by ordinary email.

If the material is already on the platform, use the reporting function attached to it where available. Please do not download, forward or redistribute illegal sexual material, particularly material involving a child. Report the location and account details instead, and follow any instructions from the police or another competent authority.

The reporting route is not an emergency service. If someone is in immediate danger, contact 999. For a non-emergency crime or immediate safety concern, contact the police on 101 or use the appropriate reporting service. If a child may be at risk, contact the police or the relevant child-protection authority without waiting for our response.

We may remove, restrict or preserve content; suspend accounts; and contact law enforcement or another competent authority where we reasonably believe that content or activity may involve a serious crime, an imminent risk of harm, child sexual exploitation or abuse, non-consensual intimate-image abuse, trafficking, threats of violence, fraud or another matter requiring referral.

We may be legally required to disclose information or preserve records. We will not normally tell a reported person about a referral or disclosure if doing so could put someone at risk, prejudice an investigation, breach another person’s privacy or conflict with a legal direction.

A moderation review may begin because:

• a member submits a report or safety concern;
• a moderator identifies a possible breach during ordinary service operation;
• an automated system detects spam, malware, suspected illegal material or another risk signal;
• media is held for pre-publication review;
• a payment, verification, security or account-integrity check identifies suspected misuse;
• a club, venue or event listing is challenged; or
• we receive information from a supplier, regulator, law-enforcement body or other reliable source.

Automated tools may help identify or prioritise content, but they can make mistakes. They are intended to support moderation and security processes. We will not rely solely on automated processing to make a decision with legal or similarly significant effects about a person without the safeguards required by applicable data-protection law.

Where an automated signal leads to an action that materially affects access, the person affected may use the support or appeal route described below. The Privacy Policy explains how moderation information and other personal data are handled.

Photographs, videos, audio and other media may be placed in a temporary review or quarantine state before they become visible to other members. We may use automated screening and, where appropriate, human review to check for issues such as:

• suspected child sexual abuse material or apparent involvement of a minor;
• non-consensual intimate imagery or material involving another identifiable adult without permission;
• extreme violence, exploitation or illegal activity;
• impersonation, fraud, malware or malicious links;
• material that breaches the feature’s audience or access rules; or
• material that is likely to expose another person’s private information.

We may approve, delay, blur, limit the audience for, reject or remove media. A rejection does not necessarily mean that we have concluded that the uploader committed a crime. It may mean that we cannot verify the necessary permission, the material does not meet the feature rules, or the risk is too high for the proposed audience.

If you upload an identifiable person, you must have that person’s permission for the particular use and audience selected. A person appearing in a photograph or video is not, by itself, proof that they consented to its publication.

Live rooms are more difficult to moderate because they happen in real time. Depending on the feature, we may provide room hosts or moderators with tools to:

• remove a participant from a room;
• disable or restrict camera, microphone or chat access;
• block or mute an account;
• close a room;
• preserve limited information needed to investigate a report; or
• restrict a member’s access to live features.

Unless a feature expressly says otherwise, we do not intend to record live video rooms. That does not mean that a participant or third party cannot capture what appears on their own device. Members must not record, photograph, screen-capture, rebroadcast or distribute a live room or identify participants without the informed permission required by the Terms and everyone affected.

If a live interaction creates an immediate risk, use the in-room reporting controls if available and leave the room. Contact emergency services if necessary. Do not remain in a risky interaction simply to provide more evidence.

9. Reviewing reports

We will assess reports according to the apparent seriousness, urgency, credibility and potential impact of the concern. We may ask for clarification, compare information from more than one source, review relevant account activity, or take temporary action while we investigate.

We may give priority to reports involving:

• immediate danger or threats of violence;
• children or people who may be unable to consent freely;
• sexual exploitation, trafficking or non-consensual intimate material;
• stalking, repeated harassment or coercive behaviour;
• compromised accounts, fraud or attempts to defeat safety controls; or
• content that is spreading quickly or may cause serious harm.

We will try to avoid unnecessary disclosure of the reporter’s identity. However, complete anonymity cannot be guaranteed. Information may need to be shared with a service provider, another affected person, a regulator, law enforcement or a court where this is necessary and lawful.

We will not penalise a member for making a report in good faith merely because the report is not upheld. Deliberately false reports, coordinated abuse of the reporting system, retaliation against a reporter or attempts to manipulate moderation may themselves breach the Terms.

Depending on the circumstances, we may take one or more of the following actions:

We may take action against content without taking action against the account, or against an account without removing every item associated with it. We may also act before an investigation is complete where waiting could increase the risk of harm.

When choosing an action, we may consider the nature and seriousness of the concern, the likely harm, whether anyone is at immediate risk, the person’s previous conduct, the reliability of the information available, whether the behaviour was deliberate, whether the person cooperated, and whether a less restrictive action would adequately protect people.

We may give limited information about the outcome of a report. Privacy, safety, legal and security considerations may prevent us from sharing the details of action taken against another person.

Where we take action against your content or account, we will normally tell you:

• what action has been taken;
• the general reason or rule involved;
• whether the action is temporary or permanent, where that can safely be explained;
• what you need to do, if anything, to restore access; and
• how to ask for a review or appeal.

We may delay, limit or withhold notice where giving details could expose another person’s private information, reveal detection methods, enable evasion, prejudice an investigation, increase a safety risk or breach the law.

If you believe that we removed your content, restricted a feature or suspended your account in error, you can ask us to review the decision through:

Appeal route: [appeal link or support email address]
Complaints and Appeals Policy: [Complaints and Appeals Policy link]

Please appeal within 14 calendar days where possible and explain why you believe the decision was incorrect. Include the relevant username, notice or decision reference, and any information that may have been misunderstood. Do not include unnecessary intimate material or another person’s personal information.

An appeal will be reviewed by someone who was not responsible for the original decision where reasonably possible. We may uphold, vary or reverse the action, or ask for further information. An appeal will not automatically restore access while a serious safety, legal or security risk remains.

We aim to acknowledge an appeal within [two] working days and provide a substantive response within [ten] working days. Complex cases, external referrals and cases involving multiple people may take longer. If we need more time, we will explain why where it is safe and lawful to do so.

Nothing in this process prevents you from contacting a regulator, the police, a court or another body with a legal role, or from using any statutory consumer, data-protection or other legal right.

Moderation can involve personal data, including profile information, messages, reports, images, video, room chat, technical information, verification status and records of safety action. We handle that information under the Privacy Policy and applicable data-protection law.

We do not treat a member’s private content as available for general inspection. We may access, preserve or share limited content and account information where reasonably necessary to operate the service, investigate a report, enforce the Terms, protect a person, maintain security, comply with law or respond to a lawful request. Access should be limited to people or suppliers with an appropriate service, safety, security or legal reason.

Moderation records may be retained for as long as reasonably needed to investigate safety concerns, manage appeals, prevent repeat abuse, meet legal obligations or establish, exercise or defend legal claims. The Privacy Policy and internal retention schedule govern the intended retention approach. Removing content does not necessarily mean that every related record can be deleted immediately.

Public listings may be supplied by venues, gathered from public sources or submitted by members. We may review, amend, label, suspend or remove a listing where it appears inaccurate, misleading, unsafe, unauthorised, unlawful or inconsistent with our standards.

A listing is not an endorsement or a guarantee that a venue is safe, accessible, lawful, open, fairly represented or suitable for you. Report an inaccurate or concerning listing using the normal reporting route. Venue operators should contact [listing support email address] if they need to correct information or challenge a moderation decision.

Moderation reduces risk; it cannot remove all risk. Members may misrepresent themselves, copy content, behave unlawfully or cause harm despite our controls. A verification badge is not a guarantee that a person is honest or safe. We do not supervise offline meetings and cannot guarantee the conduct of members away from the service.

Use your own judgment, protect your personal information, use the block and report tools, and take practical precautions before meeting anyone offline. If you believe that someone is in immediate danger, contact the emergency services rather than waiting for a platform response.

We may update this policy as the service, technology, law or risks change. We will publish the current version on the relevant site and may notify members of a material change where appropriate.

Questions, reports, appeals and requests for help can be sent to support@circlestech.atlassian.net.

This policy is intended to describe the planned moderation framework clearly. It should be checked against the actual platform configuration before launch, especially the reporting, appeals, live-room, media-review and law-enforcement procedures.

• Online Safety Act 2023
• Government Online Safety Act explainer
• Ofcom online safety guidance for service providers
• ICO call for views on data protection and content moderation