1. Introduction
Welcome to My-Local-Escorts.co.uk ("the Website"). We are committed to safeguarding the privacy of our visitors and users ("you"). This Privacy Policy explains how we collect, use, store, protect, and disclose your personal data when you use our Website and services. It also outlines your data protection rights under UK law.
We take your privacy very seriously, particularly given the nature of our service, and strive to handle your personal data responsibly and transparently. We encourage you to read this policy carefully.
We may update this Policy from time to time; please review it regularly to stay informed. Your continued use of the Website after changes are posted constitutes your acceptance of the revised policy.
2. Information We Collect
We collect information to provide and improve our services, ensure platform security, and meet legal obligations. We aim to collect only the minimum data necessary. The types of personal data we may collect include:
- Technical & Usage Data: Information about your device and how you use our site, such as IP address, browser type, operating system, pages viewed, visit duration, referral source, and general location data derived from your IP address. This is often collected via cookies and similar technologies (see Section 4).
- Registration Data: Information you provide when creating an account, such as username, email address, and password (stored securely).
- Advertiser Profile Data: Information provided voluntarily by advertisers (escorts and agencies) for their public profiles, which may include names (or aliases), contact details (phone, email, website links), service descriptions, locations served, images, videos, and other relevant details. You control what information is made public.
- Verification Data: Information provided voluntarily or upon request for identity and age verification purposes, such as verification photos or copies of identification documents (handled with strict confidentiality and security).
- Payment Data: Information required to process payments for advertising services, such as billing name, address, and payment card details (processed securely by our payment partners – we do not store full card details).
- Communication Data: Information you provide when contacting us via email or other means, including the content of your communications.
- Review/Report Data: Information submitted when leaving reviews or reporting profiles.
- Behavioural Data (Microsoft Clarity): We partner with Microsoft Clarity to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay. This helps us improve our services, understand user needs, and ensure site security.
3. How We Use Your Information & Legal Basis for Processing
We process your personal data only when we have a valid legal basis under UK data protection law. Here's how we use your data and the corresponding basis:
- Providing & Managing Services (Legal Basis: Contract Necessity):
- To operate the directory, display advertiser profiles, and facilitate user searches.
- To create and manage user/advertiser accounts.
- To process payments for advertising services.
- To communicate with you regarding your account or services (e.g., profile updates, billing).
- Platform Improvement & Security (Legal Basis: Legitimate Interests):
- To analyse website usage (using aggregated/anonymised data where possible) to understand user behaviour, improve site functionality, and enhance user experience (e.g., using technical data and Microsoft Clarity insights).
- To monitor for and prevent fraudulent activity, spam, security breaches, or violations of our Terms & Conditions.
- To moderate content and enforce platform rules.
- Legal Compliance (Legal Basis: Legal Obligation):
- To comply with legal requirements, such as age verification checks where necessary.
- To respond to lawful requests from law enforcement agencies or regulatory bodies.
- To maintain legally required financial records (e.g., anonymised payment data).
- Marketing & Communication (Legal Basis: Consent / Legitimate Interests):
- To send you information about our services, updates, or promotional offers if you have consented to receive such communications, or where permitted under legitimate interests (e.g., informing existing customers about similar services). You can opt-out of these communications at any time. We do not share your contact details with third parties for their marketing purposes.
- Profile Promotion (Legal Basis: Consent / Legitimate Interests based on Advertiser Agreement):
- To potentially use publicly available advertiser profile information (as consented to during submission) for promoting the advertiser's profile and the Website itself on third-party platforms (e.g., search engines, social media). Advertisers can request limitations or removal where feasible.
4. Cookies and Tracking Technologies
We use cookies and similar technologies to operate the website, analyse usage, improve user experience, and ensure security.
- What are Cookies? Small text files stored on your device when you visit our site.
- Types We Use:
- Essential Cookies: Necessary for the website to function correctly (e.g., managing login sessions, processing payments securely via our Payment Service Provider, ensuring site security). These do not require your prior consent but are essential for using our services.
- Analytics & Performance Cookies: Help us understand how visitors interact with the website (e.g., Google Analytics, Statcounter, Microsoft Clarity) by collecting information anonymously (where possible). These cookies help us improve the site.
- Your Consent: Under UK regulations, non-essential cookies (like those used for Analytics & Performance) require your specific, informed consent before they are placed on your device. While we strive for compliance, we acknowledge the technical challenges in implementing consent mechanisms that work seamlessly with all essential third-party services (like payment gateways). We are working towards fully compliant solutions. In the meantime, essential cookies will be placed as necessary for site function.
- Microsoft Clarity: As mentioned, this analytics tool uses cookies and other technologies. For details, see the Microsoft Privacy Statement.
- Managing Cookies: Most web browsers allow you to manage cookie preferences through their settings. You can usually block or delete cookies, but please note that disabling essential cookies may significantly impair website functionality.
5. Data Sharing and Disclosure
We are committed to protecting your privacy and will not sell your personal data. We only disclose your personal information in the following limited circumstances:
- Service Providers: We may share data with trusted third-party companies who provide essential services on our behalf (e.g., payment processors, hosting providers, email delivery services like AWS SES), but only the data necessary for them to perform those services, and under strict confidentiality agreements requiring them to protect your data.
- Legal Requirements & Law Enforcement: We will disclose personal information where legally required by UK law (e.g., court order) or when responding to valid, formal requests from law enforcement agencies to assist in investigations related to crime prevention, public safety, or fraud protection, as outlined in our Terms & Conditions.
- Business Transfers: In the event that we sell or transfer any part of our business, user data relevant to that part of the business may be transferred to the new owner, who will be bound by the terms of this Privacy Policy regarding its use.
6. Data Storage, Security & International Transfers
- Security Measures: We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include measures detailed in our About Us page (SSL/HTTPS encryption, HSTS, firewalls, PCI DSS adherence, secure server configurations, regular updates, and vulnerability assessments). However, no internet transmission is 100% secure, and sending data is at your own risk.
- Storage Location: Your data is primarily stored and processed on secure servers located within the United Kingdom.
- International Transfers: If it becomes necessary to transfer data outside the UK (e.g., using a service provider based elsewhere), we will ensure appropriate safeguards are in place as required by UK GDPR, such as relying on UK Adequacy Regulations or implementing Standard Contractual Clauses approved by the relevant UK authority.
7. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including providing services, maintaining accounts, complying with legal obligations (e.g., accounting records), resolving disputes, and enforcing our agreements.
- Account Data: Retained for the duration your account is active. Upon deletion (see Section 8), personal data is removed from active systems and backups according to our schedule.
- Anonymised Data: Anonymised payment transaction data is retained for legally required accounting periods. Other usage data may be anonymised and retained for statistical analysis.
8. Your Data Protection Rights
Under UK data protection law, you have several rights regarding your personal data:
- Right of Access: You can request a copy of the personal data we hold about you.
- Right to Rectification: You can request correction of inaccurate or incomplete data.
- Right to Erasure ('Right to be Forgotten'): You can request the deletion of your personal data under certain conditions. As stated previously, we offer functionality allowing users to directly delete their accounts and associated data instantly. We also process direct deletion requests promptly.
- Right to Restrict Processing: You can request that we limit the processing of your data under certain circumstances.
- Right to Data Portability: You can request to receive your data in a structured, commonly used, machine-readable format, where applicable.
- Right to Object: You can object to the processing of your data where we rely on legitimate interests as our legal basis.
- Right to Withdraw Consent: Where processing is based on consent (e.g., for marketing emails), you can withdraw your consent at any time (this does not affect the lawfulness of processing before withdrawal).
- Right to Lodge a Complaint: You have the right to lodge a complaint with the UK's Information Commissioner's Office (ICO) if you believe your data protection rights have been infringed.
To exercise any of these rights, please contact us using the details below. We will respond to your request in accordance with legal requirements.
9. Third-Party Links
Our website may contain links to third-party websites. This Privacy Policy applies only to our Website. If you follow links to other sites, please review their respective privacy policies, as we do not accept responsibility or liability for their practices.
10. Policy Updates
We may update this Privacy Policy periodically. We will indicate the date of the last update at the top of this policy. We encourage you to review this page regularly to stay informed about how we protect your data.
If you have any questions about this Privacy Policy or our data protection practices, please contact us via email: enquiries@my-local-escorts.co.uk.
