Privacy Policy

Last updated: 12 August 2026

This Privacy Policy explains how SpicySwingers ("we", "us", "our") collects, uses, stores, and protects your personal data when you use the Platform at spicyswingers.com (the "Platform"). It is written to meet UK GDPR transparency requirements.

By creating an account or using the Platform, you acknowledge that you have read this policy. Where we rely on consent (including for special-category data), we will ask for that consent separately and clearly.

1. Data Controller

1.1 The data controller responsible for personal data processed through the Platform is:

1.2 For all privacy queries, data-subject requests, and complaints about how we handle personal data, contact us at privacy@spicyswingers.com.

1.3 This policy applies under UK GDPR and the Data Protection Act 2018. Where you are in the EEA, equivalent rights under the EU GDPR may also apply.

2. Data We Collect

2.1 Account data: Username, email address, date of birth (used to confirm you are 18+), password (stored hashed), profile type, and registration date.

2.2 Profile data: Display name, location (city/region), biography, physical attributes, interests, looking-for preferences, and profile content you choose to add.

2.3 Location data: If you enable the GPS feature, we collect your approximate location to show nearby members. This is optional and can be turned off at any time in account settings. We never show your exact coordinates to other members - only approximate distance ranges.

2.4 Communications data: Messages and other content you send to members on the Platform.

2.5 Usage and technical data: Pages visited, features used, approximate time on the Platform, IP address, browser type, device information, and security signals used to protect accounts (for example bot-protection tokens).

2.6 Payment data: We do not store full payment card details. Payments and subscriptions are processed by Stripe. Stripe handles card data under its own privacy notice.

2.7 Verification and age-assurance data: Records that an account has completed verification or age assurance (for example a pass/fail or completed status), and related moderation notes. See Section 12 for AI and age-assurance detail.

2.8 Support data: Information you send us when you contact support or exercise privacy rights.

3. Special Category Data

3.1 SpicySwingers is an adults-only lifestyle community. Some information you provide is special-category personal data under UK GDPR Article 9. This includes, in particular:

  • data concerning sexual orientation
  • sexual preferences, lifestyle interests, and related profile content
  • private profile content related to your lifestyle preferences

3.2 We process this data only because it is necessary to operate the service you choose to use (matching, profiles, messaging, and community features) and only with your explicit consent under UK GDPR Article 9(2)(a).

3.3 Explicit consent is requested at registration (and may be refreshed if this policy changes materially). Agreeing to the Terms of Service alone is not treated as consent for special-category processing. You can refuse or withdraw that consent.

3.4 If you withdraw consent for special-category processing, we will stop that processing and remove or limit the relevant profile fields and content as far as reasonably possible. In practice this may mean parts of your profile cannot remain visible, or your account may need to be closed if the service cannot operate without that data.

3.5 We do not use special-category data for unrelated advertising networks, and we do not sell it. Sharing with other members only happens according to your visibility and privacy settings. Sharing with processors is limited to what is needed to host, secure, moderate, and operate the Platform (see Section 6).

3.6 Where age-assurance or safety screening involves biometric or similarly sensitive technical processing, we describe that separately in Section 12 and rely on explicit consent and/or substantial public interest grounds for safeguarding children under applicable UK law, as appropriate to the specific check.

4. How We Use Your Data

We use personal data to:

  • Create and manage your account
  • Provide Platform features (profiles, matching, messaging, forums, events, and related tools)
  • Show your profile to other members according to your privacy settings
  • Suggest relevant members based on preferences and (if enabled) approximate location
  • Send transactional emails (verification, password reset, security and service notices)
  • Process payments and manage subscriptions via Stripe
  • Detect and prevent fraud, spam, abuse, and under-18 access
  • Moderate content and enforce our Terms
  • Improve reliability and security of the Platform
  • Comply with legal obligations (including Online Safety Act duties where applicable)

5. Legal Bases for Processing

5.1 Contract (UK GDPR Article 6(1)(b)): creating your account and providing the core service you request.

5.2 Consent (Article 6(1)(a) and, for special-category data, Article 9(2)(a)): special-category profile content, optional location features, non-essential analytics/cookies where used, and certain age-assurance methods that require consent.

5.3 Legitimate interests (Article 6(1)(f)): securing the Platform, preventing fraud and abuse, basic service analytics required to keep the service safe and usable, and improving features - balanced against your rights.

5.4 Legal obligation (Article 6(1)(c)): records and actions we must take to comply with applicable law.

6. Third-Party Recipients and Processors

6.1 We do not sell your personal data.

6.2 We share personal data with the following categories of recipients, only as needed to operate the Platform:

  • Other members: public or shared profile information according to your settings (this can include special-category information you choose to publish)
  • Stripe: payment and subscription processing
  • Cloudflare: content delivery, security (including WAF and bot protection such as Turnstile), DNS, and related edge services
  • Cloudflare R2: secure storage for member content
  • Email validation providers: checks to reduce disposable or abusive email sign-ups
  • Transactional email providers: delivery of service emails (verification, resets, notices)
  • Specialist AI content-moderation providers: automated screening of uploads for possible under-18 or other prohibited content (see Section 12)
  • Professional advisers and authorities: where required by law, court order, or to protect users or the public

6.3 These providers process data on our instructions as processors where applicable, or as independent controllers for their own regulated services (for example Stripe for payment data). We require appropriate data-protection terms with processors.

6.4 We may also use limited security and infrastructure sub-processors that support the services above. A current list of primary named recipients is set out in this section; contact privacy@spicyswingers.com if you need further detail for a rights request.

7. International Data Transfers

7.1 We are based in the United Kingdom. Personal data is primarily processed in connection with providing the Platform to UK users.

7.2 Some of our providers (including Cloudflare, Stripe, AI moderation providers, and email-related services) may process data in the United States, the European Economic Area, or other countries outside the UK.

7.3 Where personal data is transferred internationally, we use appropriate safeguards required by UK GDPR. Depending on the provider and destination, this may include:

  • transfers to countries covered by a UK adequacy regulation
  • the UK International Data Transfer Agreement (IDTA) and/or the UK Addendum to the EU Standard Contractual Clauses
  • other lawful transfer mechanisms recognised under UK data protection law

7.4 You can contact privacy@spicyswingers.com for more information about the safeguards that apply to a particular transfer.

8. Profile Visibility

8.1 Your profile is visible to other registered members according to your privacy settings.

8.2 Your exact location is never shown. Only approximate distance ranges are displayed when location features are enabled.

8.3 You can hide your profile from search results, control online status, and control who can message you through privacy settings.

8.4 Private profile areas are only visible to members you explicitly allow.

9. Cookies and Limited Analytics

9.1 We use essential cookies and similar technologies to operate the Platform (session, authentication, security, and preference cookies). These are required for the service to work.

9.2 We may use limited analytics tools to understand aggregate traffic and reliability. Where non-essential analytics cookies are used, we will seek consent via our cookie controls and keep use to what is needed to improve the Platform.

9.3 We do not use analytics to build intimate advertising profiles from your special-category lifestyle data for third-party ad networks.

9.4 You can manage cookie preferences through the cookie settings on the Platform where available. Disabling essential cookies will prevent login and core features from working. See also our Cookies page.

10. Data Retention

10.1 We retain account and profile data while your account remains active.

10.2 When you delete your account, personal data is retained for up to 30 days to allow recovery, then permanently deleted from live systems, subject to the exceptions below.

10.3 We may retain limited data for longer where needed for legal obligation, fraud prevention, security, dispute resolution, or safeguarding (for example records of under-18 enforcement actions).

10.4 Age-assurance outcomes are retained as a status on the account (for example that a check was passed). We do not retain raw biometric templates or estimated ages from age-assurance checks as a standing profile attribute (see Section 12).

10.5 Messages you sent to other members may remain visible to those recipients after your account is deleted.

10.6 Backups are rotated on a limited schedule and then purged.

11. Data Security

11.1 We use technical and organisational measures appropriate to the sensitivity of lifestyle platform data, including HTTPS, hashed passwords, access controls, and infrastructure security controls.

11.2 No online service is perfectly secure. We work to protect your data but cannot guarantee absolute security.

11.3 If a personal-data breach is likely to result in a risk to your rights and freedoms, we will notify you and the Information Commissioner's Office (ICO) as required by UK GDPR.

12. Age Assurance, Children's Privacy, and AI Screening

12.1 The Platform is strictly for adults aged 18 and over. We do not knowingly allow under-18s to register or use the service.

12.2 Account age gate and further assurance: We collect date of birth at registration and require confirmation that you are 18 or over. Further age-assurance methods may be required under the UK Online Safety Act and related guidance before full access to adult content. Methods may include (as rolled out): mobile-network adult-content checks; SMS PIN checks; live selfie age estimation; selfie plus ID document checks; credit-card based confirmation; and email age verification/estimation. We may use third-party providers to run these checks, including AgeVerif (https://www.ageverif.com/) as a provider and fallback (including email verification and other methods we enable through that service). Details of the member-facing process are also described on our Age Assurance page.

12.3 What we keep from age assurance: Following ICO-oriented guidance for age assurance, our policy is to retain the minimum needed - typically that the account passed (or failed) a check - and not to keep standing copies of passport images, raw biometric templates, or an estimated age score on the member profile after the check completes. Temporary processing needed to complete a check is deleted when no longer required, subject to security and fraud exceptions. Where a provider such as AgeVerif completes a check, they process verification data under their own terms and privacy notice; we receive and retain an assurance outcome for the account (for example passed/failed and related audit metadata), not a standing gallery of ID images or biometric templates.

12.4 AI screening of uploads: Separately from member age-assurance checks, we use automated AI tools operated by specialist third-party providers to screen member uploads for signs that someone depicted may be under 18, or for other prohibited material. Content that is flagged is held for human moderator review before it can appear on the Platform. We do not rely on AI alone as the final decision-maker for publishing.

12.5 What AI screening produces: Providers return technical signals/scores and labels to us for moderation. We may store those moderation results with the uploaded item (and related audit information) to enforce safety rules. We do not publish biometric age estimates from those scans to other members.

12.6 Why we do this: To keep the community adults-only, to meet legal child-safety duties, and to reduce harmful or illegal content.

12.7 If we discover that a user is under 18, we will terminate the account and delete associated personal data except where we must retain limited records for safeguarding, legal, or fraud-prevention reasons.

12.8 If you believe a minor has registered, contact privacy@spicyswingers.com immediately.

13. Your Rights

Under UK GDPR you have the right to:

  • Access - request a copy of personal data we hold about you
  • Rectification - correct inaccurate data
  • Erasure - request deletion (subject to legal retention needs)
  • Restriction - ask us to limit processing in certain cases
  • Portability - receive certain data in a structured, machine-readable form
  • Objection - object to processing based on legitimate interests
  • Withdraw consent - where processing is based on consent, including special-category consent, without affecting the lawfulness of processing before withdrawal

To exercise these rights, email privacy@spicyswingers.com. We will respond within one month (extendable where permitted by law for complex requests).

14. Complaints

14.1 Please contact us first at privacy@spicyswingers.com so we can try to resolve your concern.

14.2 You also have the right to complain to the UK supervisory authority:

15. Third-Party Links

The Platform may link to third-party websites. We are not responsible for their privacy practices. Read their policies before providing data to them.

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and change the "Last updated" date. For material changes, we will give additional notice (for example email or an in-product notice) where appropriate. If changes affect processing based on consent, we will seek fresh consent where required.

17. Contact

Privacy questions and data-rights requests: privacy@spicyswingers.com.