Privacy Notice

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. Who are we?

We are SextMe. SextMe is a Limited Company registered in England and Wales under the name “Miller Connections Limited” with company number 12908454 and with our registered office at Ebenezer House, Ryecroft, Newcastle Under Lyme, Staffordshire, United Kingdom, ST5 2BE

2. Our commitment to privacy

SextMe appreciates the trust that you have put in our platform by choosing to use our services. We take the overall privacy of our customers seriously and aim at keeping your personal information as discreet as possible. SextMe will never sell your personal information.

3. What data do we collect?

In order to provide our service to you and to allow you to browse our site and use our services, it may be necessary for us to collect some personal information about you.

If you use our website (henceforth “Users”), we may collect some or all of the following information about you:

Your display name and username
Your phone number
Your email address
Your password (stored only in encrypted form)
Payment information
Purchase history
Information about your device and how you use our website
Your IP address
Media you upload to our website
Other content and posts submitted to our website

In addition, if you are a model who wishes to provide services through our platform (henceforth “Performers”), we may collect some additional data:

Your legal name and date of birth
Copies of identification documents

4. How do 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)

4.1 Your display name and username
In order to use our service, you must register and choose a display name and username. Please be aware that your display name and username will be visible publicly on the website. This applies to both Users and Performers.

Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – As a social platform, SextMe relies on the use of name and username identifiers to allow Users to identify each other on the platform.

4.2 Your phone number
As a site which facilitates contact between Users and Performers, SextMe may collect your phone number if you are a User who chooses to use our texting or phonecall service, or if you are a Performer who chooses to provide texting or phonecall services. We use a system which does not reveal your phone number to the User or Performer we are connecting you with.

Basis: GDPR Art. 6(1)(b) – “Performance of contract” – We are required to know your phone number in order to facilitate the texting and phonecall services that we offer through the platform.

4.3 Your email address
We will use your email address to send you updates about our services and offers we think you may be interested in. We may also collect this information if you email us for any other reason, such as to request information or for support.

We also require your email address to be able to send you updates about this Privacy Notice, for example if we wish to process your data in a new way.

Basis: GDPR Art. 6(1)(a) – “Consent” – When you sign up for our services, you provide your consent for us to provide you updates about our platform which we think you might be interested in. To withdraw your consent, please see the ‘Questions about privacy?’ section of this Privacy Notice.

Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – Being able to communicate updates with you about your use of our platform is vital to our business function. We also cannot reply to any emails you send without using your email address.

4.4 Your password
We will store your password on our servers in an encrypted format. This is needed to make sure you can log in to our systems.

Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – It is critical to our commitment to protect our customers to ensure that accounts and account information is accessible only to the customers themselves.

4.5 Payment information
We may store some information related to payments and to your transactions on our site. This is important to allow you to grant access to the services which you have paid for, and to help combat fraud. We do not store your full bank or payment details, as these are handled by our third-party payment processor.

Basis: GDPR Art. 6(1)(b) – “Performance of contract” – It is necessary for us to keep records of the payments our third-party processor has processed on your behalf, so that we can provide the services which you purchase on our site.

Basis: GDPR Art. 6(1)(c) – “Legal obligation” – For the purposes of taxation and appropriate record filing, it is important that we keep records of the purchases made through our site.

Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – In order to perform our business functions and to ensure proper reporting and auditing, it is important for us to maintain records of payment transactions.

4.6 Purchase history
In order to assist with processing support queries and with financial forecasting for our business, we maintain records of the services purchased by customers to our site.

Basis: GDPR Art. 6(1)(b) – “Performance of contract” – We need to keep records of your purchase history to allow us to deal with returns if you need to raise a support query in the future.

Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – In order to perform our business functions and to forecast and predict demand and shape our business around popular products, it is important to know what services Users are purchasing.

4.7 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. This allows us to know where to focus the business strategy for our site, and also to predict and protect against potential attacks which may cause disruption to our service.

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

4.8 Your IP address
If you access our site, we will collect the IP address of the device you are accessing it from. We need to do this to predict and protect against potential attacks which may cause disruption to our service.

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

4.9 Media you upload
If you choose to upload media, such as images, to our website, it is your responsibility to ensure that the media is not identifiable if you do not wish to be identified from it. Media which may identify you is your own responsibility. If you wish for us to remove identifiable media from our website, please contact us using the contact details provided in this Privacy Notice.

Basis: GDPR Art. 6(1)(a) – “Consent” – when you upload your media, you provide us with consent and a worldwide license to publish the media as part of our website. We need this because our website is accessible from anywhere in the world.

Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – by uploading media as a Performer, you grant SextMe a license to distribute the media in accordance with our Terms of Service. Please see our Terms of Service for specific information about this grant of license.

4.10 Other content and posts submitted to our website
It is your responsibility to ensure that comments, wall posts, and other content which you post to our website are not identifiable if you do not wish to be identified from them. Comments, reviews or forum posts which may identify you is your own responsibility. If you wish for us to remove comments, reviews, or forum posts which you have submitted to this website, please contact us using the contact details provided in this privacy notice.

4.11 Your legal name and date of birth
As a Performer, we will collect your legal name and date of birth for the purposes of fraud prevention and record keeping in relation to our obligations to ensure all Performers are aged 18 or older. Your legal name or date of birth will never be visible to other Users of the SextMe platform.

Basis: GDPR Art. 6(1)(c) – “Legal obligation” – For the purposes of record keeping, we must store and process your legal name and date of birth to ensure you are above the age of 18.

Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – For the protection of our business, we must ensure that we keep accurate and extensive records that show we have conducted due diligence in confirming all Performers are at or above the age of 18.

4.12 Copies of identification documents
In addition to the above, as a Performer, we will ask that you provide a copy of a Government-issued photo ID when signing up to provide your services through our platform. This is to ensure that we fulfil our obligations to ensure that all Performers are aged 18 or older. Your identification documents will never be visible to other users of the SextMe platform.

Basis: GDPR Art. 6(1)(c) – “Legal obligation” – For the purposes of record keeping, we must store and process copies of your Government-issued identification documents to ensure you are above the age of 18

5. Third-parties we may share your data with

Operating a modern web platform like ours requires us to rely on a number of third parties to help us provide our services. We take your privacy seriously and only share your data with trusted third-parties. We will never sell your data.

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.

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.

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

The privacy policy for Google Analytics can be found here.

Stripe
We use Stripe to process payments you submit for orders placed through our site. This ensures that we do not need to process your card or banking details directly, and is necessary to ensure a secure service for all our customers.

You can find Stripe’s Privacy Policy 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 the 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.

We will keep data for longer periods if reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions.

7. 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.

8. Updates to this notice

We regularly review and may, where necessary, update this Privacy Notice from time to time.

If we plan to use personal data for a new purpose, we will update this information and communicate any changes to you before starting any new processing.

We will communicate any updates to this notice prominently on our website, as well as directly to previous customers by email.

9. Questions about privacy?

If you have questions about privacy or any of the contents of this notice, please don’t hesitate to get in touch with us!

You can email us at << email address >>, or write to us at: << our trading address >>.