Privacy Policy

Last Updated: July 2023

1. 1. INTRODUCTION

       

      1. 1. Adult Ad Trader is committed to protecting your privacy. This Privacy Policy sets out how we will treat the Personal Data which you provide to us while using our website www.adultadtrader.co.uk (the “Site”) and/or the services provided from it (the “Services”).
      1. 1. Please read this Privacy Policy carefully and know that we do not sell, share or rent Personal Data to third parties without your consent, except in specific cases described below or unless we are required to do so by law and guidance of the GDPR ( General Data Protection Regulation ).
      1. 1. Your use of the Site means that you have accepted this Privacy Policy. If you are unwilling to be bound by some of the clauses then please do not use the Site. If you register as a User of the Site, or submit personally identifiable information, this indicates that you have read and understood this Privacy Policy and you agreed to its contents.
      1. 1. We may change this Privacy Policy from time to time and such changes will take effect from the date and time the revised Privacy Policy is available on the Site. Please regularly visit the Privacy Policy so that you are aware of any modifications or updates. Your continued use of the Site means that you have accepted any modifications or amends. 
      1. 1. It is important that you read this Privacy Policy together with the Terms and Conditions so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other policies, notices and terms and conditions and is not intended to override them.
      1. 1. The Site is intended for audiences over the age of 18 and does not plan or intend to collect data from those under the age of 18. To respect the privacy of underage persons, those under the age of 18 should not provide any data on the Site. 
      1. 1. Terms not defined herein shall have the meanings given in our Terms and Conditions. The following defined terms shall have the following meanings:

             

            • • “Anonymous Data” means Personal Data that has been amended to the extent that it no longer contains any identifying information and thus, no longer constitutes Personal Data;
            • • “Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed as outlined in the Data Protection Legislation.
            • • “Data Protection Legislation” means all applicable data protection and privacy legislation in force from time to time including the General Data Protection Regulation ((EU) 2016/679); the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended.
            • • “Personal Data” has the meaning given to it in the Data Protection Legislation.
            • • “Processor” means any natural or legal person who processes the data on behalf of the Controller.

1. 1. ADULT AD TRADER

       

      1. 1. The Site, together with all Content, data and other materials contained therein (save for content uploaded by Registered Users) is owned or controlled by Adult Ad Trader (referred to in the Privacy Policy as “we”, “us”, “our” or “Adult Ad Trader”). The brands, products and service names used in the Site and the Content ( including without limitation, “Adult Ad Trader”) are trademarks or trade names of Adult Ad Trader or its affiliates or trading partners unless otherwise stated.

1. 1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

       

      1. 1. You may browse the Site and provide some Personal Data without registering an account, or you may register an account with us as a user, create a profile to post ads and/or view information about the Services available (the “Registered User”), or where you are an escort, you may create a profile to post ads and/or connect with potential customers via the Site (the “Registered Escort”) (together, the “Users”). In all these circumstances we are the data Controller in respect of any Personal Data provided by Users via the Site or otherwise.

1. 1. CONTACT INFORMATION:

       

      1. 1. You can contact us by email at info@adultadtrader.co.uk if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

1. 1. THE DATA WE COLLECT ABOUT YOU

       

      1. 1. From time to time, we may collect, use, store and transfer different kinds of Personal Data about you, which include but are not limited to, the following categories:

             

            • • Identity Data: means your name.
            • • Contact Data: means data that includes your contact information such as your residential address, email address, office address and/ or telephone number.
            • • Technical Data may include internet protocol (IP) addresses you may have visited, your login data for Adult Ad Trader, the type and version of browser you are using, the time zone setting and location from which you are accessing the Site, browser plug-in types and versions, which operating system and platform are being used and other technology on the devices you use to access the Site.
            • • Profile Data: means your username, password, details of Services you have booked, messages and/or ads you have responded to where you are a User; and/or videos, photographs and messages where you are a Registered Escort.
            • • Usage Data: includes information about how you use the Site and our Services such as the full URL through and from the Site (including date and time), pages you viewed or searched for, page response times, download errors, length of visits of certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
            • • Marketing and Communications Data includes your preferences in receiving marketing communications from us and/or our third parties and what are your communication preferences.
            • • Special Categories of Data (only applicable to Registered Escorts): means the kinds of data recognised by the Data Protection Legislation as being more sensitive in nature than Personal Data. This includes details about your race or ethnicity, sex life, sexual orientation and Biometric Data. Biometric Data includes videos and images of your face which are used to verify you at certain points when you engage with the Site.

      1. 1. Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or the Services and/or allow you to register as an escort on the Site). In this case, we may have to cancel a product or service you have with us, or reject your Registration application but we will notify you if this is the case at the time of contracting.
      1. 1. For the avoidance of doubt, Adult Ad Trader accepts no liability for any losses arising from their inability to fulfill any contractual requirement as a result of your failure to provide the data required.

1. 1. HOW IS YOUR PERSONAL DATA COLLECTED?
      We use different methods to collect data from and about you including through:

       

      1. 1. Direct interactions. You may give us your Identity, Contact and Special Category data by registering your account or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

             

            • • register or update your account with us; or
            • • complete an ID Verification for the purpose of registering as a Registered Escort on the Site (for more information on this, please refer to the Terms and Conditions available at www.adultadtrader.co.uk/Freeads/terms-and-conditions/ for our Terms and Conditions.
              • • use our Site, including upload any Content, or information related to your ads; or
              • • request us for marketing material to be sent to you; or
              • • enter a competition, promotion or survey on the Site; or
              • • give us some feedback.

      1. 1. Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
      1. 1. Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
            • Technical Data from the following parties:

             

            • • analytics providers;
            • • advertising networks; and
            • • search information providers.
            • • Identity and Contact Data from publicly availably sources such as Companies House.

1. 1. HOW WE USE YOUR PERSONAL DATA

       

      1. 1. We will only use your Personal Data when and to the extent permitted by the Data Protection Legislation. Most commonly, we will use your Personal Data in the following circumstances:

             

            • • Where we post on the Site any information that you wish to post as part of using our Services.
            • • Where to provide to any other User with whom you have sought to share your Personal Data.
            • • Where we need to notify you about changes to our Services.
            • • Where we need to contact you about your account and our Services.
            • • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
            • • Where we need to comply with a legal or regulatory obligation.
            • • Where we consider it to be in the interests of our Users (Registered Escorts or otherwise) or in the public interest, we may provide Personal Data to law enforcement to assist them with an investigation. If we believe that you are a victim, we may provide your Personal Data without obtaining your prior consent for your protection.

1. 1. CONSENT

       

      1. 1. By using our Site, you consent to the collection and use of your Personal Data. If we change our Privacy Policy at any time, these changes will be reflected here, so please regularly check this policy to ensure you are aware of any updates.

1. 1. VERIFICATION CHECKS

       

      1. 1. In order to become a Registered Escort, and from time to time thereafter, we will ask you to consent to a biometric verification check (a “Verification Check”) to ensure that you are who you say you are. You will be asked to give explicit consent to us processing your Biometric Data in order to verify your age and identity, and to our retention of the Biometric Data provided by you as part of the Verification Check. The Biometric Data that we process is limited to a short video of your face in which you respond to certain prompts such as blinking or turning your head, or one or more photographs.
      1. 1. Verification Checks have automated legal effects including that if the Verification Check identifies that you are below the age of 18, your access to the Site will automatically be blocked. We do not believe that there is any bias or discrimination built into the Verification Checks, but we work with our technology providers to review results and ensure that bias does not creep into the technology. Where you believe that the Verification Check has given rise to an incorrect or unfair legal effect, you may challenge this effect and request a review by providing supporting documentation.
      1. 1. In addition to processing your Personal Data to carry out the Verification Check, we may also carry out further activities with regards to your Personal Data including without limitation:

             

            • • using your Biometric Data to grade the risk that you are being trafficked, forced to work as an escort and/or otherwise at risk;
            • • disclosing your Biometric Data to law enforcement in compliance with our legal obligations; and/or
            • • disclosing your Biometric Data to law enforcement where you have been a victim of crime or where we believe that you are at risk.

      1. 1. The processing conditions applicable to each of the activities set out in paragraph 9.3 are as follows:

             

            • • Grading risk that you are at risk – substantial public interest in (a) preventing or detecting unlawful acts and (b) safeguarding of individuals at risk.
            • • Disclosure to law enforcement in compliance with our legal obligations – substantial public interest in preventing or detecting unlawful acts and/or legal obligation.
            • • Disclosure to law enforcement where you are suspected/known to be a victim of crime or we suspect you are at risk – without your explicit consent.

1. 1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

       

      1. 1. Personal Data will be used by us (and our necessary service providers) to provide you with the Services and other activities associated with them.
      1. 1. We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
      1. 1. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your Personal Data where more than one ground has been set out in the table below.
      1. 1. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
      1. 1. For the avoidance of doubt, this table is not exhaustive of the ways in which Adult Ad Trader may use your Personal Data and there may be occasions where we require additional information.Adult Ad Trader