Complaints & Appeals 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.

You can use this policy to complain about matters such as:

• the operation of Circles.London or SwingCircles.com;
• a paid membership, payment, renewal, cancellation or refund;
• customer support or the way we have communicated with you;
• accessibility or a difficulty using an important service;
• a moderation decision, account restriction or content-removal decision;
• the handling of a report, safety concern or appeal;
• privacy, cookies, age or identity verification, or the handling of personal information;
• a club, venue or event listing supplied through the service; or
• suspected misuse of our branding, content or intellectual property.

This policy also explains appeals against moderation or account decisions. It does not replace the separate process for copyright notices or security-vulnerability reports, which are described in the Copyright and Intellectual Property Policy and Responsible Disclosure Policy.

These routes overlap, but they are not the same thing.

Support request

A support request asks us to help with a practical problem, such as logging in, changing an account detail or understanding a feature. Contact [support email address].

Report a violation or safety concern

A report tells us about a member, message, profile, image, video, live room, listing or other activity that may breach the Terms, Community Guidelines or law. Use same email for all types of contact (at top of this document):

If there is an immediate risk to life or safety, contact the emergency services first. The Content Moderation Policy explains how reports are assessed and what action may be taken.

Complaint

A complaint says that you are unhappy with our service, decision, conduct or handling of a matter and want it reviewed. A complaint does not need to use legal language or quote a policy. Tell us what happened, why you are unhappy and what outcome you are seeking.

Appeal

An appeal asks us to reconsider a moderation or account decision, such as a warning, content removal, suspension, restriction or termination. An appeal should normally be made within 14 calendar days of the decision. Explain what you think was wrong, include any relevant context, and identify any evidence we should consider.

Data protection complaint

A data protection complaint concerns how we have collected, used, stored, shared or otherwise handled personal information. Send it to us mark it “Data protection complaint”. The Privacy Policy explains your separate data protection rights and how to make a rights request.

Please contact the most relevant address above or use the relevant form on the site. Include:

• your name and the email address connected with your account, if applicable;
• whether you are making a support request, complaint, report or appeal;
• the website or service involved;
• the date and approximate time of the event;
• a clear description of what happened;
• the username, profile, message, room, listing, transaction or decision involved, where relevant;
• copies or links to relevant communications, if it is safe and lawful to provide them; and
• the outcome you would like us to consider.

Please do not send passwords, full payment-card details, identity documents or intimate images by ordinary email. If evidence is sensitive, tell us that it exists and we will provide a safer way to share it where one is available. Do not put yourself at risk, confront another member or arrange another interaction simply to collect evidence.

You may complain on behalf of another person if you have their authority to do so. We may need reasonable evidence of that authority before discussing their personal information.

Our complaints process is not an emergency service. If someone is in immediate danger, call 999. For a non-emergency crime or safety concern, contact the police on 101 or the relevant specialist reporting service.

For serious platform risks, we may restrict content or accounts while a review is continuing. This can include suspected child sexual exploitation or abuse, threats of violence, stalking, coercion, non-consensual intimate-image abuse, trafficking, fraud, serious security compromise or another matter requiring urgent action.

We may preserve information or contact law enforcement or another competent authority where we reasonably believe this is necessary or legally required. We may withhold details of an action or referral where disclosure could put someone at risk, prejudice an investigation, breach another person’s privacy or conflict with a legal direction.

We will log the matter, identify the appropriate route and assess whether urgent action is needed. Where reasonably possible, we aim to acknowledge ordinary complaints, safety reports and appeals within two working days.

Data protection complaints will be acknowledged within 30 days, as required by applicable data protection law. We will investigate them without undue delay, keep you informed where appropriate and tell you the outcome.

For ordinary complaints and appeals, we aim to provide a substantive response within ten working days. Some matters will take longer, particularly where they involve multiple people, sensitive information, technical investigation, a payment provider, a verification provider, law enforcement, a legal claim or a complex safety issue. If we need more time, we will explain why and provide a revised expectation.

These are service targets, not a promise that every matter can be resolved within a fixed period. We will still deal with complaints and appeals without unreasonable delay.

We will review the information reasonably available to us, which may include account records, relevant messages, reports, moderation history, payment records, technical logs, policy wording and information supplied by you or another person.

We will try to ensure that the person reviewing an appeal was not the only person responsible for the original decision. In a sole-trader business, complete separation may not always be possible. Where that happens, we will take reasonable steps to review the decision afresh, consider new information and avoid treating the original decision as automatically correct.

We will consider:

• what happened and what evidence is available;
• the relevant Terms, policy or legal obligation;
• the seriousness and likely impact of the issue;
• the safety, privacy and rights of other people;
• whether the action taken was proportionate;
• any new information or context provided in the appeal; and
• whether an adjustment, correction, apology, refund, restoration or other remedy is appropriate.

We will not usually disclose another member’s private information, moderation history or confidential report to you. This may limit the detail we can provide about a decision.

Depending on the matter, we may:

• explain what happened and close the complaint;
• correct an error or update information;
• apologise or provide further support;
• restore content, access or an account where an appeal is accepted;
• remove or restrict content or activity;
• issue or maintain a warning, restriction, suspension or termination;
• provide a refund, credit or other remedy where appropriate and lawful;
• improve a process, feature, policy or accessibility arrangement; or
• refer the matter to a specialist provider, regulator, law-enforcement body or other competent authority.

We will not promise a particular outcome before the review is complete. A complaint or appeal does not automatically pause a moderation action, payment obligation, account restriction or safety measure.

You should normally appeal within 14 calendar days of receiving the decision. If you were unable to appeal in time for a good reason, explain that reason and we may still consider it.

An appeal should identify the decision, explain why you think it was wrong or disproportionate, and include any relevant new information. We may decline to reopen a matter where no new information is provided, the same issue has already been fully reviewed, or reopening it would create a safety, privacy, legal or security risk.

We may keep a restriction in place while an appeal is considered. We may also take urgent interim action before giving a full explanation where delay could put someone at risk or compromise an investigation.

We will normally give reasons for the outcome, subject to the privacy, safety, security and legal limits described in this policy and the Content Moderation Policy.

Please contact us first so that we have a fair opportunity to investigate and put matters right. If your concern is about personal information and you remain dissatisfied after contacting us, you can complain to the Information Commissioner’s Office (ICO):

Make a data protection complaint to the ICO

You may also have rights through the courts, consumer law, payment-provider processes or another regulator, depending on the subject of your complaint. Nothing in this policy prevents you from contacting a regulator, seeking independent advice or bringing a claim where the law allows.

We are not currently a member of a mandatory ombudsman or alternative dispute-resolution scheme. If that changes, we will update this policy and provide the information required by law.

We will handle complaint, report and appeal information in accordance with the Privacy Policy. Complaint records may contain sensitive information, including information about sex life, sexual orientation, identity, safety or alleged misconduct. Access will be limited to what is reasonably necessary for support, moderation, safety, legal, security, fraud-prevention, accounting or dispute-resolution purposes.

We may retain a limited record after a matter is closed where this is needed to establish what happened, defend or bring a legal claim, protect members, prevent repeated abuse, meet a legal obligation or maintain the security of the service. Retention periods and deletion processes are explained in the Privacy Policy and will be reviewed against the final technical configuration.

We want people to raise genuine concerns. We may restrict communications that are threatening, abusive, discriminatory, deliberately repetitive, knowingly false or intended to harass someone. We will not treat a complaint as misuse merely because it is critical, inconvenient or unsuccessful.

Where possible, we will explain any communication restriction and provide a safer or more appropriate route for genuine future concerns.

We may update this policy to reflect changes to the service, law, suppliers or complaint routes. The current version will be published with an updated date.

Questions about this policy can be sent to support@circlestech.atlassian.net