Privacy 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 data controller is Samantha Dee, a sole trader trading as Circles.London and Swingcircles.com

Business correspondence address: A business correspondence address is pending and will be available before launch.
Email: support@circlestech.atlassian.net – this is used instead of an enclosed privacy@domain address because it creates a work item directly in our back-end management system visible by our Team and does not rely on anyone checking a particular email inbox.

In this policy, “Circles”, “we”, “us” and “our” mean [FULL LEGAL NAME], trading as [TRADING NAME, if different].

If you have questions about this policy or want to exercise your rights, contact us at [privacy email address]. Our data protection contact, if one is appointed, can be reached at [DPO or privacy contact details].

This policy applies when you:

• visit Circles.London or SwingCircles.com;
• join or manage the Circles.London waitlist;
• contact us or respond to our research or marketing;
• create, use or apply for a SwingCircles.com account;
• use member profiles, messaging, live rooms, forums, media or other community features;
• submit a report, complaint, appeal or support request; or
• provide information for a club, venue or other public directory listing.

It does not apply to websites or services operated by third parties, even when we link to them. Those services have their own privacy notices.

We collect different information depending on how you use Circles.

Information from public visitors

When you visit either site, we may process technical information such as your IP address, browser and device type, operating system, approximate location derived from your IP address, pages viewed, referring page, dates and times of access, and security or error logs.

Some of this information is collected automatically by hosting, content-delivery, security and website-management services. We use it to operate the sites, keep them secure, understand general usage and investigate faults or misuse.

Waitlist and public contact information

If you join the Circles.London waitlist or contact us, we may collect your first name, email address, location, information about what you are looking for, and any other information you choose to include. We may also keep your communication history and records of your preferences, consent and unsubscribe choices.

The waitlist is not a membership application and does not give access to SwingCircles.com. We may use waitlist information to send launch news, invitations, research updates and other communications you have agreed to receive. You can unsubscribe at any time.

Account and member information

If you use SwingCircles.com, we may collect:

• your email address, username, password credentials and account details;
• your age or date of birth where needed to confirm that you are an adult;
• your location or approximate location;
• profile information, photographs, video, audio, interests, preferences and relationship information that you choose to provide;
• information about how you use member features, including profile visibility, connection requests, blocks and preferences;
• messages, room chat, reports, complaints, appeals and support communications; and
• records of verification status, account activity, moderation decisions and safety actions.

You control much of the information shown on your profile, but information shared with other members may be copied, saved or disclosed by those members. Do not upload anything you would not want another person to see or retain.

Age and identity verification

SwingCircles.com is intended for adults aged 18 and over. Where verification is available, you may be asked to complete an age or identity check through a specialist verification provider. At the time of writing, we have chosen “Veriff” to provide this service.

The verification provider may collect information such as an identity document (driving licence or passport), photograph or video, technical information and, where its process requires it, biometric information used for identification. The provider will give you its own privacy information before you submit verification material.

Our intended design is to receive and retain the minimum information needed to operate the service, such as a verification result, status, reference and relevant dates, rather than keeping identity documents on member profiles. We will not publish identity documents or verification material to other members. The exact information retained, retention period and deletion process will depend on the provider and the final verification configuration, which we will confirm before the feature becomes live and operational.

Payments

If you pay for membership or another service, payment details are handled by our payment provider. We generally receive information such as your name, billing details, transaction reference, subscription status, payment dates and limited payment-method information. We do not intend to store complete payment-card numbers or security codes on our own systems.

Club and venue listings

If you submit information for a public club or venue listing, we may collect the name and contact details of the person submitting it, together with the venue’s name, address or general location, description, facilities, website, social links, logo and other information supplied for publication by the club or venue owner. Published business information may be visible to anyone using the relevant directory.

Information from other people

We may receive information about you when another person reports a profile, message or piece of content, submits a safety concern, or contacts us about an interaction. We keep and use this information for moderation, safety, complaints, appeals, legal compliance and the protection of our users and service. The information will be stored in a dedicated management system provided by Atlassian, called JIRA and called “CirclesUEX” (Circles User Experience Management System). Specifically chosen as we have used this system for several decades and trust the reputation of this company entirely.

Cookies and similar technologies

We use cookies and similar technologies needed to operate and secure the sites. With your permission where required, we may also use analytics, preference and marketing technologies. Our Cookie Policy explains what we use, why we use it and how you can manage your choices.

4. Sensitive information

Because Circles is an adult community platform, information that people choose to provide may reveal aspects of their sex life, sexual orientation, relationship status or other sensitive personal information. Under UK GDPR and EU GDPR, information concerning a person’s sex life or sexual orientation is special category data and requires additional protection.

We do not require you to provide more sensitive information than is needed for the feature you want to use. Where information is special category data, we will process it only where a specific legal condition applies. This may include your explicit consent, where you choose to provide and display the information after being told how it will be used, or another condition permitted by data protection law.

You can withdraw consent where consent is the legal basis. Withdrawal will not affect processing that took place before withdrawal, and it may mean that we cannot provide a feature that depends on the information. We will not sell sensitive information or use it to target unrelated advertising.

Because Circles is an adult community platform, information that people choose to provide may reveal aspects of their sex life, sexual orientation, relationship status or other sensitive personal information. Under UK GDPR and EU GDPR, information concerning a person’s sex life or sexual orientation is special category data and requires additional protection.

We do not require you to provide more sensitive information than is needed for the feature you want to use. Where information is special category data, we will process it only where a specific legal condition applies. This may include your explicit consent, where you choose to provide and display the information after being told how it will be used, or another condition permitted by data protection law.

You can withdraw consent where consent is the legal basis. Withdrawal will not affect processing that took place before withdrawal, and it may mean that we cannot provide a feature that depends on the information. We will not sell sensitive information or use it to target unrelated advertising.

We use personal information for the purposes below. The legal basis depends on the circumstances and the type of information involved.

Where we rely on legitimate interests, we consider the effect on your rights and interests and will not use that basis where your interests override ours. You can ask us for more information about our legitimate-interest assessment.

We process profile information, photographs, messages, room chat and other content to provide the features you choose, make content available to the intended audience, moderate content, respond to reports and protect the community.

Member content is not automatically public. Visibility depends on the feature, your settings and the choices you make. Some content may be visible to other verified members, some may be visible only to people you have accepted or connected with, and some may be visible to moderators or service providers acting for us.

We do not intend to record live video rooms. If that changes, we will update the relevant feature information and this policy before recording begins.

We do not sell personal information, rent member lists or provide member contact details to advertisers for their own unrelated marketing.

We may share information with:

• hosting, website-management, content-delivery and security providers;
• providers of email, forms, customer support, payments, identity or age verification, analytics, media storage, live chat and video-room services;
• moderators, investigators and professional advisers who need information to perform their role for us;
• carefully selected suppliers who process information only on our instructions and under a written contract where required;
• other members or visitors, where you choose to make profile or directory information available through a feature;
• law-enforcement, regulators, courts or other authorities where we are legally required or permitted to do so; and
• a purchaser, successor or professional adviser if the business or service is sold, transferred, reorganised or brought into a different legal structure, subject to appropriate confidentiality and data-protection safeguards.

For example, we use Cloudflare to process technical traffic and security information when it provides network and security services, and WordPress or hosting providers (currently Hostinger) may process information needed to run the websites. We will update this policy or provide additional notices when a new provider materially changes how personal information is used.

Our current hosting arrangement is intended to use servers in the European Union. However, some suppliers may operate across more than one country, including countries outside the United Kingdom or European Economic Area.

When information is transferred outside the UK or EEA, we will use a lawful transfer mechanism and appropriate safeguards. Depending on the destination and the supplier, this may include an adequacy decision, the UK International Data Transfer Agreement or UK Addendum, EU Standard Contractual Clauses, and supplementary technical or organisational measures.

You can contact us for more information about the relevant safeguards for a particular transfer.

We keep information only for as long as it is needed for the purpose for which it was collected, for legitimate safety and accountability needs, or to meet legal, tax, accounting or dispute-resolution requirements.

Our intended retention schedule is:

The exact periods will be recorded in our internal retention schedule and matched to the technical settings of the live service. If a specific period is required for a feature, we will explain it in the relevant notice.

Depending on the circumstances, you may have the right to:

• ask for a copy of your personal information;
• ask us to correct inaccurate or incomplete information;
• ask us to delete information when there is no good reason for us to keep it;
• ask us to restrict how we use information while a concern is being resolved;
• receive certain information in a portable format;
• object to processing based on legitimate interests;
• object at any time to direct marketing;
• withdraw consent where we rely on consent; and
• ask for human review of a decision based solely on automated processing where the law gives you that right.

These rights are not absolute. For example, we may need to retain limited information to comply with the law, prevent fraud or abuse, protect another person, or establish or defend a legal claim.

To exercise a right, contact [privacy email address]. We may need to confirm your identity before responding. We normally respond within one month, although the law allows more time for complex or multiple requests.

We may use automated tools to help with security, spam detection, content screening, recommendations or verification. These tools should support human processes and should not make decisions with legal or similarly significant effects about you without the safeguards required by law.

If an automated verification or moderation decision affects your access, you may use the relevant appeal or support process. We will explain more about a particular automated process when it is introduced.

We use technical and organisational measures intended to protect personal information, including access controls, account security, encryption or secure transmission where appropriate, separation of verification information from member profiles, monitoring, moderation controls and backup and recovery arrangements.

No online service can guarantee absolute security. Please use a unique password, keep your login details private, and tell us promptly if you suspect unauthorised access or a safety problem.

Circles is for adults aged 18 and over. We do not knowingly collect or provide community access to children. If you believe a person under 18 has provided information or obtained access, contact us immediately.

Please contact us first so we can investigate and try to put matters right. You also have the right to complain to the Information Commissioner’s Office (ICO) in the United Kingdom:

Information Commissioner’s Office
Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113

If you live in the European Economic Area, you may also complain to the data-protection supervisory authority in the country where you live, work or believe an infringement took place.

We may update this policy when our services, suppliers, legal obligations or data practices 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.

For privacy questions, rights requests or concerns about personal information:

Samantha Dee, trading as Circles.London and Swingcircles.com
Email: mailto:support@circlestech.atlassian.net