Privacy Policy

We take the privacy of our visitors very seriously. We ask that you review this privacy notice carefully, as it contains important information about how we use your personal data.

1. Information we hold: Site visitors

As a site visitor, we collect the following information about you:

Information about your device and how you interact with our website.
Your IP address.

2. Information we hold: Site members

As a subscriber, we will collect the information as above, and we may collect some additional information which you provide us, including:

Your name.
Your email address.
Your phone number.
Your password, in encrypted form.
Your photo ID (e.g. passport / driving license).
Your date of birth.
Subscription and purchase information, collected from our payment processor partners.

3. How we use your information

References in this section to a basis of processing (e.g. GDPR Art 6 (1)(a)) are references to the relevant lawful basis we use to process your data under the General Data Protection Regulation (GDPR).

3.1 Information about your device and how you use our website

We collect information about your device and how you use our website. This may take the form of our own server logs, or information passed to us by Google Analytics when you load our website.

Basis: GDPR Art. 6(1)(f) – “legitimate interests” – this information allows us to plan our business strategy.

3.2 Your IP address

We may collect your IP address when you browse and interact with our website.

Basis: GDPR Art. 6(1)(f) – “legitimate interests” – this logging information forms part of our business strategy planning and helps us maintain a secure and reliable site for our visitors and subscribers.

3.3 Your name, date of birth, and identification documents

If you provide your name, date of birth, or photo identification documents to us, we will store them securely for the purposes of verifying your identity and age.

Basis: GDPR Art. 6(1)(f) – “legitimate interests” – we ask for name and identifying documents to verify your identity and that you are of legal age to offer or receive services through our site.

3.4 Your email address

When you subscribe to our site, we collect your email address. We use this for various purposes such as: sending you updates, information, invoices and billing information, or for resetting your password.

Basis: GDPR Art. 6(1)(c) – “performance of contract” – we need to collect your email address to authenticate you as a subscriber to our site and to provide you with customer support where needed.

Basis: GDPR Art. 6(1)(f) – “legitimate interests” – this information helps us to keep in contact with you to provide you with relevant updates.

3.5 Your password

Your password is required to authenticate you as a user of our services. We will never store it on our systems in its unencrypted “plaintext” form.

Basis: GDPR Art. 6(1)(c) – “performance of contract” – we need to collect your password to authenticate you as a member of our site.

Basis: GDPR Art. 6(1)(f) – “legitimate interests” – we require members to set a password to ensure that your account information stays secure and visible only to you.

3.6 Subscription and purchase information

We collect information about our subscribers to link your subscription information collected by our third-party payment providers to your account on our site, to ensure that you are authorised to access paid content.

Basis: GDPR Art. 6(1)(c) – “performance of contract” – we need to collect your subscription information to authenticate which purchases you have successfully completed on our platform, to provide you the relevant services.

Basis: GDPR Art. 6(1)(f) – “legitimate interests” – we need to ensure users are authorised to access paid content to protect our business interests, and that we have the relevant information to resolve disputes and prevent fraud and abuse.

4. Your rights

You have a number of relevant rights in respect of our processing of your personal data. The relevant rights are:

You may request access to your personal data, and information about our processing of it.
You may request us to rectify information about you which you think is inaccurate.
In some circumstances, you may restrict our processing of your data or request that we delete it.
You have the right to object to our processing of the personal data we collect about you when you visit or browse the site.

If you wish to exercise any of these rights, please contact us.

You also have the right to lodge a complaint about our processing with a supervisory authority. In the case of the UK, for example, this would be the Information Commissioner’s Office.

5. Third parties

5.1 Google Analytics

We make use of Google Analytics on our site to collect data about our visitors for technical capacity planning and for business strategy planning.

The privacy policy for Google Analytics can be found here.

You can opt out of data processing by Google Analytics by enabling Google’s “Google Analytics Opt-out Browser Add-on” on your device.

5.2 [Payment processor]

[This section will contain relevant information about the payment processor selected for use by AdultAspire.]

5.3 Cloudflare

We make use of Cloudflare’s services to deliver our web platform to you. Cloudflare helps protect our site’s servers against unexpected spikes in demand, and against various forms of web attack.

Cloudflare maintains some log data about events on their network. Some of this log data will include information about visitors to and/or authorized users of a customer’s domains, networks, websites, application programming interfaces (“APIs”), or application. This metadata contains extremely limited personal data, most often in the form of IP addresses. Cloudflare process this type of information on behalf of their customers in their main data center in the U.S. for a limited period of time.

Cloudflare publish detailed information about the data they have access to, and their approach to GDPR compliance on their website here.

6. Retention periods

We hold on to the information we collect about you, detailed above, for as long as you have your account, or for as long as is needed to be able to provide our services to you, or (in the case of any contact you have with our customer support) for as long as is necessary to provide support-related reporting and trend analysis.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

7. Changes and updates to this notice

From time to time, we may make changes to this notice to reflect how we are processing your data.

If we make significant changes, we will make this clear on the website, or by some other means of contact such as email.

8. Contact us

If you have any questions regarding your data, or this Privacy Policy, please contact us at [contact details to be provided].