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.

These Terms apply to your use of both sites where relevant. Some features, including paid membership and the private community, are available only on SwingCircles.com. Joining a waitlist or reading public information on Circles.London does not, by itself, create a paid membership.

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.

By using Circles.London, registering an account, joining the private community, purchasing a membership or uploading content, you agree to these Terms and the documents linked below. If you do not agree, do not use the services.

If you purchase a membership, these Terms form a contract between you and us. The contract begins when we confirm your membership or give you access to the paid service, whichever happens first. The information shown at checkout, including the membership type, price, billing frequency and any offer terms, forms part of that contract.

The following documents form part of, or support, these Terms:

• [Privacy Policy link]
• [Cookie Policy link]
• [Community Guidelines and Acceptable Use Policy link]
• [Content Moderation Policy link]
• [Complaints and Appeals Policy link]
• [Payments, Renewals, Cancellation and Refund Policy link]
• [User Content and Copyright Policy link]

If there is a conflict between these Terms and a more specific policy, the more specific policy applies to the relevant subject unless it says otherwise. Nothing in these Terms limits a legal right that cannot lawfully be limited.

You may use the private community only if:

• you are at least 18 years old;
• you have legal capacity to enter into a contract;
• you provide information that is accurate and not misleading;
• you use the account personally and do not sell, lend or transfer it;
• you comply with the laws that apply where you live and where you use the service; and
• you pass any age or identity checks that we reasonably require.

We do not knowingly permit anyone under 18 to register, appear in user content, participate in a live room or access the private community. Do not upload, request or share sexual or intimate material involving a person who is under 18, appears to be under 18, or whose age you cannot reasonably establish. Report it immediately and do not download, forward or keep copies.

We may limit access from particular locations or to particular features where this is necessary for legal, regulatory, safety or operational reasons.

Circles is intended to provide a private, adult community where people can explore consensual connections and conversations in a more controlled environment. Features may include:

• member profiles and visibility controls;
• private or mutual messaging;
• invitations to connect;
• the “Open Tonight” feature, which may make a member more visible for a limited period and reset at midnight;
• live video rooms and text chat;
• member-only editorial or community areas;
• club, venue and event listings; and
• age or identity verification.

Features may be introduced, changed, suspended or removed as the service develops. We will not remove a paid feature without considering the effect on members and any rights you have under consumer law. Where a material change significantly reduces the service you have paid for, we will provide any notice, remedy or cancellation right required by law.

We do not promise that the service will always be available, uninterrupted, error-free or compatible with every device or browser. Planned maintenance, security work, provider outages, internet failures and events outside our reasonable control may affect availability.

We do not promise that you will meet anyone, receive messages, find a particular type of connection or achieve a particular personal outcome. We provide a platform and tools; we do not arrange, supervise or guarantee relationships or offline meetings between members.

You must provide accurate registration information and keep it up to date. You must keep your password, authentication codes and account access details confidential and notify us promptly if you suspect unauthorised access.

You must not:

• create an account for another person without their knowledge and consent;
• operate multiple accounts to evade a restriction or mislead members;
• impersonate another person or misrepresent your relationship status, age, identity or intentions;
• share your login details; or
• allow another person to use your account.

You are responsible for activity carried out through your account unless it happened because we failed to take reasonable security measures after you reported a problem. We may ask you to complete additional security or verification steps when necessary to protect the community.

Couple memberships

Where a couple membership is offered, it is for two adults who both know about and consent to the linked membership. Each adult must satisfy the eligibility and verification requirements that apply to them. Neither person may present another adult as a partner, participant or account holder without that person’s knowledge and consent.

A couple membership does not give either partner permission to access the other partner’s private messages, private media or account activity unless the relevant feature expressly provides for that access and both people have agreed to it.

We may require age or identity verification before an account can become visible, use particular features or enter the private community. Verification may be carried out by us or by a specialist third-party provider.

A verification result confirms only that the required checking process was completed to the standard and at the time stated by the provider. A verification badge is not a guarantee that a person is honest, safe, compatible or well behaved, and it is not a substitute for your own judgment.

You must not submit another person’s identity document, use a false document, alter verification material or assist another person to bypass a check. We may refuse, pause or withdraw access if verification cannot be completed or if information later appears unreliable.

The Privacy Policy explains what verification information is handled by us, what may be handled by the verification provider, the purposes of that processing and applicable retention arrangements. We do not use verification as permission to publish identity documents or make them available to other members.

The private community is for adults who can communicate clearly, respect boundaries and take responsibility for their own conduct. Consent must be informed, freely given, specific and capable of being withdrawn. Silence, access to a profile, a previous conversation, a photograph, a relationship or a payment does not amount to consent to a particular message, act, meeting or use of content.

You must not use the services to:

• harass, threaten, stalk, intimidate, manipulate or abuse another person;
• send repeated, unwanted, explicit or sexual messages after someone has declined, stopped engaging or asked you to stop;
• pressure someone into sexual activity, sharing media, meeting, drinking, taking drugs or revealing personal information;
• impersonate someone, operate a scam, solicit money or obtain an unfair financial advantage;
• publish or share another person’s intimate material without their specific permission, including so-called revenge pornography;
• create, share or threaten to share a sexualised image or video of a real person without their consent, including an AI-generated or altered depiction;
• record, photograph, capture, redistribute or livestream a live room or another member’s content without the express permission required by the feature and everyone affected;
• expose another person’s identity, address, workplace, contact details or other private information without permission;
• offer, request or facilitate unlawful sexual services, trafficking, exploitation or coercive arrangements;
• promote or facilitate sexual activity involving a minor or vulnerable person who cannot freely consent;
• use the service to arrange or promote unlawful drugs, weapons or other criminal activity;
• upload malware, malicious code or material designed to disrupt the service;
• scrape profiles, harvest contact details, use bots or conduct unauthorised automated searches;
• use the service for commercial advertising, recruitment or promotion without our written permission; or
• deliberately evade a moderation decision, block, suspension or account restriction.

You must follow the Community Guidelines and Acceptable Use Policy. Those documents may give more examples and may be updated as the community develops.

You choose what to include in your profile and who can see it using the controls available on the platform. You should assume that anything you make visible to another member may be copied or described outside the platform, even though copying or redistributing it may breach these Terms.

Private does not mean that no one other than the intended recipient can ever access content. We may access, preserve or disclose content where reasonably necessary to provide the service, moderate suspected abuse, protect a person, investigate a report, comply with law or respond to a lawful request. Our staff and suppliers should access it only for an appropriate service, safety, security or legal purpose.

Media may be checked before publication using automated tools and human moderation. We may reject, delay, blur, restrict or remove media that breaches these Terms, the Community Guidelines, applicable law or the rights of another person.

You must have the necessary rights and permissions for every photograph, video, audio recording, message or other material you upload. You must not upload material featuring another identifiable adult unless you have that person’s permission for the particular use and audience selected on the platform.

You keep ownership of content you create. By uploading or submitting content, you give us a non-exclusive, worldwide, royalty-free licence to host, store, reproduce, adapt where technically necessary, moderate, display and transmit that content only as needed to operate, secure and improve the service, or to comply with law. This licence ends when the content is deleted, except where a copy must be retained for legal, safety, security or dispute-resolution reasons.

We will not use intimate or private member content in public advertising or marketing without a separate permission that clearly covers that use. You must not use our name, logo, member list, screenshots or platform content to imply endorsement or to promote another service.

Live rooms are provided for real-time adult conversation and interaction. Unless a feature expressly says otherwise, live rooms are not recorded by us. You must not record, screen-capture, photograph, rebroadcast or distribute a live room or identify participants without the informed permission of everyone affected and compliance with applicable law.

You are responsible for what you say, show and do in a live room. Do not display anyone who has not consented to being visible, and do not expose private documents, addresses, screens, messages or other personal information. We may remove participants, close a room, restrict camera or microphone access, or preserve relevant information when needed for safety, moderation or law enforcement.

Although we take reasonable measures to protect the service, no online live interaction can be guaranteed to be completely private. Consider using a neutral background, disabling notifications and avoiding information that could identify where you live or work.

Circles may publish listings or information about adult-lifestyle clubs, venues, events, businesses or other third parties. Listings may be supplied by the venue, gathered from public sources or submitted by members, and may be incomplete or out of date.

A listing is not an endorsement, guarantee of safety, guarantee of entry or representation that a venue complies with every law or standard. We do not operate the listed venues and are not a party to any arrangement you make with them. Confirm current opening times, prices, entry rules, age requirements, accessibility, consent expectations and other important details directly with the venue before travelling or paying.

Venue operators must not submit misleading information, use a listing to target or harass members, or upload material they do not have permission to use. We may amend, suspend or remove listings and may require evidence of authority or accuracy.

Membership is available only where shown on the relevant site. At the time of publication, the intended price for each available individual and couple membership option is £35 per month, unless the checkout page clearly states a different price, offer or billing arrangement.

The final price, billing frequency, renewal date, taxes where applicable and any introductory offer will be shown before you submit payment. A monthly membership renews automatically at the end of each monthly billing period unless you cancel it or we end it under these Terms. We will provide the notices required by applicable consumer and subscription law, including any required information about renewal, cancellation and changes.

Payments are processed by a third-party payment provider. You authorise the provider to take the agreed payments using your chosen payment method. You must keep payment information current and must not use a payment method without permission.

If a payment fails, we may restrict paid features while the amount remains unpaid. We will give you a reasonable opportunity to correct the problem. This does not prevent us from suspending or ending access immediately where there is a serious security, fraud or safety concern.

The separate Payments, Renewals, Cancellation and Refund Policy explains the payment process in more detail. If that policy has not yet been published, the checkout information and your statutory consumer rights still apply.

You can cancel a monthly membership through your account area or by contacting support@circlestech.atlassian.net Cancellation should be as straightforward as joining. Unless you have a legal right to an earlier refund or end date, cancellation normally stops the next renewal and allows access to continue until the end of the current paid period.

If you are a consumer, you generally have a 14-day right to cancel an online service contract. If you ask us to start supplying the service during that period, we may be entitled to charge a proportionate amount for the service supplied before you cancel, as permitted by law. We will not treat this clause as removing any statutory cancellation or refund right.

You may also have additional cancellation or refund rights if we fail to provide required subscription information, reminders or an effective way to cancel, or if the service does not conform to the legal standards that apply to digital services. Nothing in these Terms limits those rights.

The cancellation form or instructions are available in your account area or by contacting support@circlestech.atlassian.net

We may review reports, use automated detection, ask for information, restrict visibility, remove content, pause features, suspend an account or terminate membership where we reasonably believe this is necessary to:

• protect members, staff or the public;
• investigate suspected illegal activity, fraud, abuse or a breach of these Terms;
• comply with a legal or regulatory obligation;
• protect the security or integrity of the service;
• respond to a valid request from law enforcement or another competent authority; or
• recover unpaid amounts or prevent misuse of the service.

We may take action before an investigation is complete where delay could create a risk. We will give an explanation and an opportunity to appeal where appropriate and where doing so would not compromise safety, an investigation, another person’s privacy or a legal obligation.

You can report a concern through support@circlestech.atlassian.net. Please provide enough information for us to identify the account, content or incident. Do not put yourself at risk to collect evidence.

If we suspend or terminate your membership because of a serious breach, we may refuse a refund for the period affected by the breach where the law allows. This does not affect any refund or remedy that the law requires.

You may close your account at any time. Closing an account is not the same as cancelling a paid membership, so check that your recurring membership has also been cancelled.

We may end or suspend the contract in accordance with these Terms. If we end a paid membership for a reason unrelated to your breach, we will normally refund the unused part of the period you have paid for, unless a different remedy is required or permitted by law.

After termination, your right to use the private community ends. We may delete or anonymise content and account information in line with the Privacy Policy, but may retain limited information where needed for legal, safety, security, fraud-prevention, accounting or dispute-resolution purposes.

Terms that are intended to continue after termination, including provisions about intellectual property, confidentiality, liability, disputes and retained records, will continue to apply.

The website design, software, branding, logos, editorial material, graphics, text and other material supplied by us belong to us or our licensors. We give you a limited, personal, non-transferable right to use them while you are permitted to use the relevant service.

You must not copy, republish, sell, licence, modify, reverse engineer, scrape or commercially exploit our material or branding without written permission, except where the law expressly permits it.

The service may rely on third-party providers for hosting, security, payments, email, verification, communications, analytics or other functions. Their own terms and policies may apply to the part of the service they provide. We remain responsible for our obligations to you under these Terms and applicable law.

Links to third-party websites are provided for convenience. We do not control those websites and are not responsible for their content, availability, security or privacy practices. A link to a club, venue or supplier is not an endorsement.

We will provide the paid service with reasonable care and skill and will comply with the consumer rights that apply to it. We do not exclude or limit liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, breach of legal rights that cannot be excluded, or anything else that cannot lawfully be excluded or limited.

To the extent permitted by law, we are not responsible for loss caused by:

• another member’s conduct, statements, decisions or actions;
• an offline meeting or arrangement between members;
• content supplied by members or third parties;
• your failure to protect your account or follow reasonable safety advice;
• an event outside our reasonable control; or
• your use of the service for a purpose it was not designed to support.

We are not an emergency service. If you or another person is in immediate danger, contact the emergency services or an appropriate specialist organisation.

Nothing in this section prevents you from relying on rights or remedies available under consumer law.

You are responsible for losses we suffer as a result of your deliberate misuse of the service, fraud, unlawful conduct or serious breach of these Terms. This does not make you responsible for losses caused by our own negligence or give us a wider claim than the law allows.

Our Privacy Policy explains how we process personal information, including registration information, verification information, messages, reports, moderation records and sensitive information connected with your use of an adult community.

Our Cookie Policy explains cookies and similar technologies on Circles.London and SwingCircles.com. Please read both policies before registering or purchasing a membership.

We may update these Terms to reflect changes to the service, law, security requirements or business arrangements. We will publish the updated version with a new “last updated” date. If a change is material, we will take reasonable steps to draw it to your attention and, where required, ask you to accept it before continuing to use the affected service.

If we change the price or a significant part of a paid service, we will give the notice required by law. You may cancel before the change takes effect where applicable. Continuing to use a service after an effective date may mean that you accept the updated Terms, but it will not remove rights that cannot lawfully be removed.

You may not transfer your account or this contract to another person. We may transfer our rights and obligations to a future business structure or service operator, including a limited company established to operate Circles or SwingCircles, provided your legal and privacy rights are not reduced and you are given any notice required by law.

If a court finds one part of these Terms invalid or unenforceable, the rest will continue to apply. A failure to enforce a provision immediately does not mean that we waive it.

These Terms, together with the documents and checkout information referred to in them, contain the agreement between you and us about the service. You will not be charged for anything that was not clearly disclosed before you agreed to pay.

These Terms are governed by the law of England and Wales. If you are a consumer living elsewhere in the United Kingdom, you retain any mandatory protections available under the law of the part of the UK where you live and may be entitled to bring proceedings in your local courts.

Please contact us first using [support email address] so that we can try to resolve a complaint. Our Complaints and Appeals Policy explains the process. Nothing in this section prevents you from contacting a regulator, bringing a claim or using any statutory dispute-resolution right available to you.

Questions about these Terms, memberships, reports or cancellation can be sent to the person named at the top of this document using the email support@circlestech.atlassian.net

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.

Purpose	Typical legal basis
Provide Circles.London content, the waitlist and public contact facilities	Consent, where required; or our legitimate interests in operating and communicating about the service
Create and administer a SwingCircles.com account and provide member features	Performance of a contract with you, or steps taken at your request before entering a contract
Process payments, subscriptions, refunds and accounting records	Performance of a contract and compliance with legal obligations
Confirm that members are adults and operate identity or age verification	Compliance with legal obligations where applicable, performance of a contract, and our legitimate interests in protecting the community
Display and deliver profiles, messages, media, live rooms and other features you choose to use	Performance of a contract; and explicit consent where the information is special category data and consent is required
Moderate content, investigate reports, prevent abuse and protect members	Our legitimate interests, compliance with legal obligations and, where relevant, explicit consent or another permitted special-category condition
Keep the sites, accounts and services secure and investigate suspected misuse	Our legitimate interests and compliance with legal obligations
Answer questions, provide support and handle complaints or appeals	Performance of a contract, our legitimate interests and compliance with legal obligations
Send optional marketing or research communications	Consent, or another lawful basis permitted by electronic-marketing law
Produce statistics and improve the service	Our legitimate interests, consent where required, and anonymisation or pseudonymisation where reasonably possible
Establish, exercise or defend legal claims	Our legitimate interests, compliance with legal obligations and, where relevant, a permitted special-category condition

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:

Information	Intended retention approach
Waitlist information	Until you unsubscribe, the purpose ends, or the record has been inactive for the period set in our retention schedule; we may retain a minimal suppression record so we do not contact you again
Public enquiries and support messages	Usually up to 24 months after the enquiry is closed, unless a longer period is needed for a complaint, dispute or legal claim
Active member account and profile information	While the account is active and for a limited period after closure to complete deletion, prevent abuse and handle disputes
Messages, reports and moderation records	For as long as needed to provide the service, investigate safety issues, manage appeals and defend legal claims; higher-risk safety records may be kept longer where justified
Verification information	The minimum verification result and reference needed to operate the account; identity documents and verification media should remain with the verification provider and be deleted under the provider’s stated retention policy unless the law requires otherwise
Payment and accounting records	For the period required by tax, accounting and other legal obligations
Security and technical logs	For the shortest period reasonably needed to secure the service, investigate incidents and meet legal obligations
Backups	Deleted information may remain in encrypted backups until those backups expire through the normal backup cycle
Marketing preferences	Until you unsubscribe, plus a minimal suppression record where needed to respect that choice

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