Privacy Policy

Draft — under legal review. This wording has been prepared in-house and has not yet been checked by a qualified lawyer. It describes accurately how the site works, but it is not final.

1. Who is responsible for your information

[LEGAL ENTITY NAME], of [REGISTERED ADDRESS], is the data controller for the personal information described here. That means we decide what is collected and why, and we are responsible for looking after it.

You can reach us about anything in this policy at [CONTACT EMAIL].

[IF A DATA PROTECTION OFFICER IS APPOINTED, GIVE THEIR CONTACT DETAILS HERE.]

2. The short version

• Membership of this site says something about your private life, so we treat everything here as sensitive.
• We ask for your explicit consent before we hold that kind of information, and you can withdraw it.
• We do not sell your data. We do not share it with advertisers. There is no advertising or tracking on this site.
• Identity documents are encrypted and destroyed as soon as they have been reviewed.
• You can download everything we hold about you, or delete your account outright, yourself, at any time.

The rest of this document is the detail.

3. Information you give us

When you register: your email address, a password, a display name, whether you are a couple or a single person, and your date of birth.

We store your password only as a cryptographic hash. Nobody here can read it, including us.

Your profile, if you choose to fill it in: a general location, a headline, and whatever you write about yourself.

Photographs, if you upload any, together with whether each one is public to members or kept private.

Messages you send to other members, and the record of which members you have expressed interest in or blocked.

Identity documents, only if you choose to verify yourself. See section 6.

4. Information we collect automatically

Age confirmation: when you confirm you are over 18, we record the date and time, your IP address, and the identification string your browser sends. We keep this as evidence that the confirmation was given.

Sign-in attempts: we record the email address used and the IP address for each failed sign-in, so that we can slow down anyone trying to break into an account. Successful sign-ins clear these.

A session cookie, which is what keeps you signed in as you move between pages. See section 12.

We do not use analytics, advertising networks, tracking pixels or social media buttons. There is no third-party code running on this site.

5. Information that is sensitive by law

Being a member of My Swing Hub reveals something about your sex life and possibly your sexual orientation. Under data protection law this is "special category" information and gets extra protection.

We rely on your explicit consent to hold it. You give that consent when you create an account, and creating an account is entirely your choice.

You can withdraw that consent at any time by deleting your account, which you can do yourself from your account settings. Withdrawing does not undo anything we did lawfully before you withdrew.

6. Identity and address documents

If you choose to verify yourself, this is exactly what happens to the file:

1. It is encrypted the moment it arrives, using AES-256-GCM.
2. It is stored outside the website's own folders, so no misconfiguration of the website can serve it to anyone.
3. Only a member of staff with the specific permission to do so can open it, and every single opening is written to an audit log with their name against it.
4. When a decision is made — approved or rejected — the file is deleted. We keep the fact that you were verified and when. We do not keep the document.
5. If you delete your account while a document is waiting, it is destroyed with the account.

We are honest about the limit of this: the encryption key sits on the same server as the files. It protects against a stolen backup or a leaked database. It would not protect against someone who had already taken full control of the server.

We ask you not to send documents you have not been asked for, and to cover any information on a document that we do not need.

7. Why we use your information, and our legal basis

To run your account and provide the service — showing your profile to other members, delivering your messages, holding your photographs. Basis: performance of our contract with you, and your explicit consent for the sensitive aspects.

To confirm your email address and to send you service messages such as password resets. Basis: performance of our contract.

To moderate photographs and handle reports, so that the community stays safe and lawful. Basis: our legitimate interest in running a safe platform, and compliance with our legal obligations.

To verify identity, where you have asked us to. Basis: your consent.

To protect the site from unauthorised access and abuse. Basis: our legitimate interest in security.

To meet legal obligations, including responding to lawful requests from authorities. Basis: legal obligation.

We do not make any decision about you by automated means alone that has a legal or similarly significant effect.

8. Who can see your information

Other members. Your display name, member type, general location, headline, profile text and approved public photographs are visible to signed-in members who have confirmed their own email address. Your email address and date of birth are never shown to other members. Your private galleries are visible only to members you have personally granted access to.

Until you confirm your email address, your profile is not visible to anyone and you cannot be contacted.

Our staff. Staff accounts have specific, limited permissions — one person may be able to review photographs but not open identity documents, for example. Every action a staff member takes is recorded in an audit log against their name. Staff sign-in requires two-factor authentication.

Our suppliers. Our web hosting provider stores the site and its database, and our email provider delivers messages such as confirmation links. They act on our instructions. [CONFIRM AND NAME THESE PROVIDERS, AND CONFIRM A WRITTEN PROCESSING AGREEMENT IS IN PLACE WITH EACH.]

Nobody else. We do not sell your information, rent it, or share it for anyone else's marketing.

We may disclose information where the law requires it, or to protect someone from serious harm. Where we are permitted to tell you, we will.

9. Where your information is kept

Your information is stored on servers located in [SERVER LOCATION / COUNTRY].

[IF ANY PROVIDER STORES OR ACCESSES DATA OUTSIDE THE EEA/UK, DESCRIBE THE TRANSFER SAFEGUARD RELIED ON — FOR EXAMPLE STANDARD CONTRACTUAL CLAUSES — HERE.]

10. How long we keep things

Your account and profile: until you delete it. Deleting takes effect immediately.

Photographs: until you delete them or delete your account. Rejected photographs are deleted from the server at the moment of rejection.

Messages: until either participant deletes their account.

Identity documents: until a decision is made, and no longer. See section 6.

Age confirmation records and sign-in attempt records: [RETENTION PERIOD — TO BE SET ON LEGAL ADVICE. THEY EXIST AS EVIDENCE AND FOR SECURITY, SO SHOULD NOT BE KEPT INDEFINITELY.]

Staff audit log: kept as a security and accountability record. [RETENTION PERIOD TO BE SET.]

11. Keeping your information safe

• The whole site is served over an encrypted connection.
• Passwords are stored as hashes and are not recoverable, by us or by anyone else.
• Identity documents are encrypted at rest and destroyed once reviewed.
• Photographs are never served directly from storage; every request is checked against who is allowed to see that image.
• Uploaded photographs are re-saved, which removes hidden data such as GPS coordinates.
• Staff access is restricted by role, protected by two-factor authentication, and logged.
• Repeated failed sign-in attempts are throttled.

No system is perfectly secure, and we do not claim otherwise. If a breach affects your rights we will tell you and the relevant authority as the law requires.

12. Cookies

We use one cookie: a session cookie that keeps you signed in. It is marked HttpOnly and Secure, so it cannot be read by scripts and is only ever sent over an encrypted connection. It disappears when you close your browser or sign out.

We also remember that you have confirmed your age, so you are not asked on every page.

We do not use advertising, analytics or tracking cookies of any kind, so there is nothing here to opt out of.

13. Your rights

You can:

• See what we hold. Download a complete copy of your data yourself, from your account settings, at any time.
• Correct it. Edit your profile directly, or ask us.
• Delete it. Delete your account yourself from your account settings. It is immediate and it is real.
• Restrict or object to certain uses of your information.
• Take it elsewhere. Your download is in a structured, machine-readable format.
• Withdraw consent at any time, by deleting your account.
• Complain to a data protection authority.

You do not need to ask our permission or wait for us to act on the first three: they are buttons in your account settings. For anything else, write to [CONTACT EMAIL] and we will respond within one month.

If you are unhappy with how we have handled your information, you can complain to [SUPERVISORY AUTHORITY NAME AND WEBSITE — FOR EXAMPLE THE DATA PROTECTION AUTHORITY IN THE COUNTRY WHERE YOU LIVE OR WHERE WE ARE ESTABLISHED].

14. Children

This site is strictly for adults. We do not knowingly hold information about anyone under 18. If you believe a minor has created an account, tell us immediately at [CONTACT EMAIL] and we will remove it and investigate.

15. Changes to this policy

If we change how we use your information we will update this page, and where the change is significant we will tell you directly.

Last updated: [DATE]

← Back to home