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Privacy Notice

Thank you for choosing to be part of our community at Sensualism.club. We are committed to protecting your personal information and right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regard to data protection matters and your personal information, please contact us at https://sensualism.club/contact.

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such data, including the Data Protection Act 2018 and the European General Data Protection Regulation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 repealing Directive 95/46/EC, also known as the “GDPR” (these laws are referred to collectively in this Policy as the “data protection law”).

We are committed to protecting your privacy and the integrity of your personal information. This privacy notice explains what information we collect when you use our website, how we use it, and your rights in relation to it. We hope you take some time to read through this important notice carefully. If there are any terms in this privacy notice that you do not agree with, please immediately discontinue use of our website.

This privacy notice will help you understand what we do with the information we collect. Please read it carefully.

WHO WE ARE

This privacy notice (“Notice”) is issued on behalf of Sensualism Limited (“we”, “us”, “our”), a company incorporated under the laws of England and Wales with registration number 13013673 and having its registered office in London. For the purposes of the data protection law, Sensualism Limited is the data controller and the entity responsible for the Sensualism.club website (the “Site”).

SCOPE

This Notice applies to anybody who uses the Site or who provides personal data via the Site. It also applies to those who upload photos, material, information or other content via the Site, request communication via the Site, and to personal data processed in pursuit of our own marketing and business development efforts. We may also ask you for personal data when you report a problem on our Site.

The Site is not intended for children under 18 years of age and we do not knowingly collect data relating to children.

It is important that you read this Notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements other notices and privacy policies and is not intended to override them.

ACKNOWLEDGEMENT

The first time you submit data via the Site, you will be asked to acknowledge and accept the practices described in this Notice. If you do not accept this Notice, you will not be able to post on, or view events or activities publicised via the Site.

In addition, we will endeavour to bring this Notice to your attention every time we ask for your personal information and we will seek your specific consent whenever it is required.

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect the information you provide to us.

We collect personal data that you voluntarily provide to us when you express an interest in receiving information about us or our services, when you participate in activities on our Site (e.g., posting messages in our forums, entering contests, giveaways, etc.), or when you contact us.

The personal information that we collect depends on your interactions with us and the Site, your choices, and the services and features you use. The personal information we collect may include names, email addresses, phone number, profile information submitted on registering as a user of the Site (a “User”), your marketing preferences, and other similar information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information we automatically collect

In Short: We automatically collect some information, including your Internet Protocol (IP) address and/or browser and device characteristics when you visit our Site.

When you visit, use, or navigate the Site, we automatically collect certain information. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, country, browser and device characteristics, operating system, language preferences, referring URLs, and information about how and when you use our Site. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

In Short: When you visit our Site, some information — such as your Internet Protocol (IP) address and/or browser and device information — is automatically collected.

Log and Usage Data. Our servers automatically collect log and usage data for service-related diagnostic usage and performance information and record this data in log files. Depending on how you use the Site, this log data may include your IP address, device information and event information (such as system activity, error reports (i.e., 'crash dumps'), and hardware settings), browser type, and settings and information about your activity on the Site (e.g., date/time stamps associated with your time on the Site, pages and files you view, searches, and other actions you take such as which features you use).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Site. Depending on the device, this data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model, Internet service provider, and/or mobile carrier, or operating system configuration information.

Location Data. We collect information data about your device's location, which can be precise or imprecise. How much information we collect depends on the settings on the device you use to access the Site. For example, we may use GPS and other technologies to determine your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your device’s location settings. If you choose to opt out, you may not be able to use certain aspects of the Site.

HOW DO WE USE YOUR INFORMATION?

In Short: Your information is processed for legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or with your consent.

We will only use your personal data to the extent required to fulfil a User’s instructions, or to improve the functionality of the Site, or when the law allows us to. The following table summarises the type of processing activities we will undertake in relation to personal data subject to this Notice.

Information we Process	Purposes for Processing	Legal Basis for Processing
Publicly available information	To contact third parties to enquire whether they are interested in joining the Sensualism community.	Our legitimate interests, namely the pursuit of our own marketing and business development efforts.
Any personal data you provide to us on or after registration, such as names, contact details, interests and preferences, and payment and purchase data.	(1) To facilitate the delivery of the services offered via the Site by: establishing and maintaining contact between us and you; to provide you with information regarding activities reflecting your preferences and which we feel may interest you; to personalise our services to meet your tastes and interests; to process one-off payments or any other fees and charges associated with use of the Site; to provide training and receive feedback; any other requests you may have as a User of the Site. (2) To deliver promotional materials when: specifically requested; consent is given by way of your marketing preferences; authorised in the context of a specific request. (3) To allow you to participate in competitions, prize draws, surveys or special features of the Site, if you choose to do so; (4) To notify you about changes to our services and policies; (5) To publish reviews and testimonials; (6) To promote security and good practice on the Site, to investigate suspicious activity or violation of our terms and conditions, and to ensure the Site is being used for legitimate purposes; (7) To establish, exercise or defend legal claims, and to prevent and deter fraudulent use of the Site; (8) To fulfil our contractual obligations to third parties, and to take appropriate action with respect to copyright infringement and/or unlicensed or inappropriate content.	(1) The performance of our contractual obligations to you. (2) The performance of our contractual obligations to other users of the Site and third parties. (3) Your consent, or our legitimate interests, specifically the pursuit of our own marketing and business development efforts. (4) Our legitimate interests, namely monitoring and improving the Site’s performance and level of service to customers, and your consent whenever required.
Information you generate when you use the Site, e.g. likes, services offered and sought, preferences and purchase history	(1) To ensure that content downloaded via the Site is presented in the most effective manner for you and your device; (2) To administer and protect our business and the Site, including troubleshooting, data analysis, testing, system maintenance, reporting and hosting of data; (2) To provide and/or enhance functionality of the Site; (3) To analyse the performance of the Site, and/or diagnose performance issues; (4) To process payments; (5) To use data analysis to improve our services and customer experience, marketing, customer relationships; (6) To deliver relevant marketing from time to time from us and our partners; (7) To fulfil our contractual obligations to the owners of any content made available to users of the Site; (8) To establish, exercise or defend legal claims, and to prevent and deter fraudulent use of the Site.	(1) Our legitimate interests, namely monitoring and improving the Site and our level of service to customers, and your consent whenever required. (2) The performance of our contractual obligations to other users of the Site and third parties. (3) Our legitimate interests, namely monitoring and improving the Site’s performance and our level of service to customers, to monetise the services we provide, to deter misuse of the Site and to maintain the integrity and reputation of the Site.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We use third party service suppliers in order to facilitate transactions made via the Site; or with your consent; or to protect our respective rights; or to fulfill our contractual obligations to you; or to comply with the law.

We seek contractual undertakings from our third party suppliers that they will safeguard personal data disclosed to them in the course of providing such services in accordance with our instructions.

In addition to these suppliers, there are other third parties with whom we may need to share your personal information for the reasons set out below:

Third Party	Purposes for Processing	Legal Basis for Processing
Companies within our corporate group (including affiliates and ultimate beneficial owners), or who acquire a controlling interest in our business or its assets.	To facilitate the provision and promotion of our business and to monitor our business development.	The performance or negotiation of the contractual relationship between us and Users of the Site, and our legitimate interests, specifically the pursuit of our own marketing and business development efforts, and your consent whenever required by law.
Third party applications and devices	To allow you to connect the Site on your chosen device, and to facilitate the functionality of the Site by sharing of technical data.	The performance of our contractual obligations to you, and your consent to the extent the application or device requires disclosure of your personal data.
Suppliers, such as payment merchants, software/IT systems, user service support, software providers and other third party service providers.	To facilitate the provision and promotion the Site, and to process payments associated with content and any services we provide via the Site.	The performance or negotiation of the contractual relationship between us and our legitimate interests, specifically the pursuit of our own marketing and business development efforts, to secure payments and the deterrence of fraud.
Sensualism promotional partners	We may share your personal data in order to allow our partners to customise any promotional material you receive via the Site in line with your interests and preferences. We may also share your personal data relating to your use of the Site, for example your take-up of promotional offers, and the ways in which you use the Site.	The performance of our contractual obligations to you, are legitimate interests, namely the improvement and enhancement of the Site and the User experience, and your consent to the extent it is required by law in relation to the processing activity to be undertaken.
Professional advisors, such as accountants and solicitors.	Only when necessary, and limited to what is necessary.	Our legitimate interests, namely the proper administration of our business, or fulfilling our legal obligations to users of the Site or in relation to enforcing or defending legal claims.
Competent authorities, such as regulatory authorities, law enforcement and national tax authorities	Only when compelled to and/or when under an obligation to do so.	Compliance with legal obligations, such as for the purposes of fraud reporting or other criminal activity, or in order to apply or enforce our terms and conditions.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: Cookies and other tracking technologies may collect and store your information.

We may use cookies and other tracking technologies (such as web beacons and pixels) to access and/or store information. Specific information about how we use such technologies and how to refuse certain cookies can be found under the Cookies and Similar Technologies section.

Most web browsers are set to accept cookies by default. If you do not want to accept cookies, you can usually change your browser settings to remove and reject cookies. Please be aware that rejecting or removing cookies could affect certain features or services offered by our Site. To opt out of interest-based advertising by advertisers on our Site, visit: http://www.aboutads.info/choices/.

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information shared with third-party providers who advertise on, but are not affiliated with, our Site.

The Site may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of the data you provide to any third parties. This Notice does not cover any data collected by third parties. We are not responsible for the content, privacy and security practices, and policies of any third parties that may be linked to or from the Site. Review the policies of such third parties and contact them directly with any questions.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: Unless otherwise required by law, we store your information for as long as it is needed to fulfill the purposes outlined in this Notice. It is your responsibility to inform us of any material changes to your personal data to ensure it is accurate.

We will not keep your personal information any longer than is necessary for the purposes set out in this Notice, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements). Outdated personal data will be periodically deleted in accordance with our internal data retention policies. However, nothing in this Notice requires us to keep your personal data for more than 2 years.

Once we no longer have a legitimate business need to process your personal information, we will either delete or anonymise your information so it no longer identifies you, unless we are legally entitled or required to maintain certain personal data, for example an unresolved issue relating to your User Account. If for any other reason it is not possible to anonymise your data (such as if your personal information has been stored in backup archives), we will securely store your personal data and isolate it from use until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We work hard to protect your personal information through our system’s organizational and technical security measures.

We have taken appropriate technical and organisational measures to ensure our own and our suppliers’ information security standards are appropriate to the risks associated with the personal data processing we undertake. Our security objectives include guaranteeing the confidentiality, integrity and availability of personal data and the resilience of the systems that process it. We have introduced policy standards such as pseudonymisation, encryption and retention policies to minimise the risk of a personal data breach. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

However, despite our efforts to safeguard your information, no electronic transmission of data over the Internet or data stored via information technology can be guaranteed to be 100% secure. We cannot guarantee that unauthorised third parties such as hackers and cybercriminals will not be able to defeat our security, and improperly collect, access, steal, or otherwise modify your personal information. Although we strive to protect your personal information, transmission of personal data to and from our Site is at your own risk. You should only access the Site in a secure environment.

It is your responsibility to keep the password provided to you on registration secure and confidential at all times. We will not be held liable for any breach of data protection law arising from your improper use of the Site, or due to your password details being disclosed to any third party, or your failure to exercise control over your User account settings. In the event you have reason to believe your interactions with us are not secure, or the integrity of your login has been compromised, please contact us immediately.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: We are committed to guaranteeing your statutory rights as an individual data subject under data protection law.

The persons to whom this Notice applies are under no statutory or contractual obligation to provide personal data to us. However, should you decide to submit personal data to us, you will have the following rights, as a data subject, under data protection law as summarised below:

the right to be informed	the right to access	the right to rectification
the right to erasure	the right to restrict processing	the right to object to profiling (e.g. automated decision-making)
the right to request a copy of your personal data in electronic format (‘data portability’)	the right to complain to the Information Commissioner's Office (or your local data protection authority)	the right to withdraw consent (e.g. to direct marketing)

If you send us a request regarding your rights under data protection law, we will respond within 30 calendar days of receipt and, where possible, address your request within such time. Where necessary, this period may be extended by up to a further 60 days.

Please note these rights may not always apply, for example if fulfilling your request would require us to reveal personal data relating to another user, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping. If this is the case, then we will let you know at the same time as we respond to your request.

We do not engage in profiling which is capable of producing legal or other significant effects for individual data subjects.

Detailed information on the content and the means to exercise your rights is provided by the United Kingdom's Information Commissioner's Office, available here.

INTERNATIONAL TRANSFERS

In Short: We may store and process your personal data outside your home country.

We work solely with world-class suppliers, some of whom have branches outside the United Kingdom (‘UK’) and the European Economic Area (‘EEA’). Any transfers of your personal data outside the UK and the EEA take place only subject to appropriate safeguards as provided in data protection law. These safeguards are intended to secure your rights as an individual data subject with respect to any relevant non-UK/EEA domiciled entities. The transfer of personal data to a country outside of the UK/EEA shall take place only if one or more of the following applies:

the transfer is to a country, territory, or one or more specific sectors in that country (or international organisation), that the European Commission has determined ensures an adequate level of protection for personal data (Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland and Uruguay;
the transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; Standard Contractual Clauses adopted or approved by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the UK Information Commissioner’s Office); certification under an approved certification; contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
the transfer is made with your explicit consent; or
the transfer is necessary for the performance of our contract with you.

DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, this notice is updated as necessary for compliance with relevant laws.

We may occasionally update this Notice. The updated version will be indicated by an updated date, and the updated version will be effective as soon as it is posted. If we make material changes to this Notice, we may notify you either by prominently posting a notice of major changes or by directly sending you an update. We encourage you to review this Notice frequently to stay informed of how we are working to protect your information.

CONTACT

In relation to any queries about this Notice or any other data protection matters, please email contactus@sensualism.club.