CAREFULLY READ THIS PRIVACY POLICY STATEMENT.

This site expressly and strictly limits its membership to adults. All persons under the age of 18 are strictly prohibited from accessing or viewing the contents of this Site.

Email - Update/Delete/Unsubscribe

If you wish to remove yourself from our email lists then you can simply click the unsubscribe link from one of our emails, edit the settings in your profile under ‘My Account>Edit Profile’ or send an email (from the address you have registered with us) to admin@swinger-nation.co.uk; or writing to us at SMOOCHY BRANDS LIMITED, Suite 1C, Block B, Weston Chambers, Weston Road, Southend on Sea, Essex, SS1 1AT United Kingdom; or calling us at +44 121 288 7427.

We may collect and process the following data:

Information that you provide to us via the Site which includes information provided at the time of registering to use our Site, subscribing to our service, posting material or requesting further services.

If you contact us, we may keep a record of that correspondence.

Details of your visits to our site (including, but not limited to traffic data, location data, chatroom postings and other communication data), whether this is information required for our own billing purposes, provided by our Moderators and Chatroom Ops or otherwise.

The Site uses cookies.

What do we do with the information?

To ensure that content from our site is presented in the most effective manner for you and for your computer.

To allow you to participate in interactive features of our service, when you choose to do so.

To notify you about changes to our service.

Disclosure of your information

Our Services allow you to share information about yourself with other individuals and other companies, including other users and potential users of the Services or other products or services offered by Swinger Nation. Consider your own privacy and personal safety when sharing your information with anyone, including information you share through your profile, as profiles include basic information that was provided at registration, information provided through a Social Networking Site, and may include other information added by you or your friends (for example, your religion, ethnicity and physical characteristics), as well as information about your use of the Service (for example, whether you were recently logged in to Swinger Nation).

Information on your profile is viewable by other users or visitors to our Services, and may also be viewable through public search or on third-party sites that you use. We do not control who reads the information you share or what others may do with this information, so we encourage you to use discretion and caution with respect to your personal data. Also, when sharing information about others, please consider their safety and privacy and get their consent for that sharing.

We may share your personal data with the parties set out below for the purposes in the table above.

• Technology Services Providers, including infrastructure partners (such as AWS), customer support service providers, analytics service providers, cybersecurity partners, anti-fraud analytics companies, payment providers, chargeback representation services and similar partners.
• Advertising networks and technology companies, including Google, Facebook, and Twitter, and companies that measure advertising performance and attribution.
• Third parties, including consultants, who we engage to provide services on our behalf or to jointly provide services to you, including but not limited to contests and sweepstakes, marketing outreach and analytics, customer support, safety checks, and payment services.
• Social Networks, such as Facebook and Google+, where you have given permission to do so or where you have used your social network account to log-in to Swinger Nation. If you have chosen to do this, your data will be governed by the privacy policy of that social network.
• to, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use Agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Swinger Nation, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
• In connection with any company transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.

We require third parties to respect the security and privacy of your personal data and to treat it in accordance with the law. The majority of the third parties we share your personal data with are service providers that are permitted to process your personal data for specified purposes and in accordance with our instructions only. Some third parties will process your personal data for their own purposes as data controllers; please refer to their privacy policy which applies to their processing of your personal data. We are not responsible for those third parties.

We may/would only have the discretion to disclose your personal information to third parties.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions and other agreements; or to protect the rights, property or safety of Smoochy Brands Ltd, our subscribers or others. This includes exchanging information with other companies and organisations including the police and governmental authorities for the purposes of fraud protection or any other kind of illegal activity whether or not identified in the acceptable use policy.

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or asset.

Where we store your personal data

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen a password) which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site. Any transmission is at your own risk.

Other information

Our Site may, from time to time, contain links to and from the websites of our affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for these.

THE DATA WE COLLECT ABOUT YOU AND HOW IT IS COLLECTED

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Information You Provide. When you register, use or subscribe to any of our Services or take part in any interactive features of the Services (such as any contests, games, promotions, quizzes, surveys, research or other services or features), we may collect a variety of information, including:
  • Contact Information such as your name, email address, and address (“Contact Information”);
  • Sensitive Information such as race, ethnicity, sexual preferences and experiences, political affiliation, religious affiliation, union memberships, or any biometric information you provide through the use of our Services (your “Sensitive Personal Data”).
  • Other Information such as birth date, videos, password, billing information, credit card information, demographic information, place of work or education, your personal interests and background, gender, age, dating age range preference, physical characteristics, personal description, life experiences, geographic location, your photos and any information derived from them, and any other information you share with the Services. We may collect billing or payments information if you engage with a paid Service.
• Information About How You Use the Services. We may collect information about your participation and actions on the Services. This may include information such as the pages and profiles you view, how you browse the Services, dating insights your Swinger Nation credit balance and purchases you make through the Services such as boosts and gifts. It can also include the various functions and features that you use, the connections you make, other friends or contacts you invite to the Services and profile searches you perform, or your use of our applications.
• Information from Content You Upload. When you upload photos, videos or other content to the Services, we may collect information about the content, such as the time, date and place the photo or content was taken or uploaded (also known as metadata), and how you use them, who views them or with whom you share. We may also scan and analyse the photos, videos, and other content you provide to us using third party services for several purposes, including for anti-fraud purposes, for the assessment of whether the photos are consistent with our Terms of Use, to help identify your interests and activities, such as if your photo includes pets, sports, or trips, and to help us provide better matches for you.
• Information Automatically Collected. When you access our Services, we and our third party partners automatically record information from your device and its software, such as your IP address, browser type, Internet service provider, platform type, the site from which you came and the site to which you are going when you leave our website, date and time stamp and one or more cookies that may uniquely identify your browser or your account. When you access our Services using a mobile device, we may also receive or collect identification numbers associated with your device (such as a unique device ID, IDFA, Google AdID), device type, model and manufacturer, mobile device operating system brand and model, mobile carrier, phone number, email address, and other apps that you have downloaded. We also collect information about your usage of, and activity on, our Services, including internet navigation details (for example, how your mouse moves on a screen which tells us if you’re a bot or real person).
• Cookies and Similar Technologies. We and our third party partners may use cookies and similar technologies, including those from third parties, to collect, analyse and store information, to provide customized advertising on our site and applications and on other sites or applications, to provide and improve the Services or other products or services offered by Swinger Nation, and to identify and prevent fraudulent activities. You can find out more about our use of cookies and similar technologies in our Cookie Policy.
• Your Communications with Us and Other Users. We collect communications you send to us (such as emails), comments that you post on the pages we have on a third-party service, such as our Instagram, Twitter, Facebook, Pinterest, Tumblr, and Youtube pages and messages that you send us directly through those services. We may also collect and analyse any comments, photos, messages or other content or communications you and other users share on the Services or send to each other.
• Third-Party Social Networking Sites. When you have enabled the use of our Services through a third-party social networking site or mobile or other application such as Facebook, Google+ or Twitter (a “Social Networking Site”) or connect or link our Services to a Social Networking Site, you permit Swinger Nation to access and use certain information about you that is made available to Swinger Nation through or from that Social Networking Site. The information obtained by Swinger Nation varies by Social Networking Site and may be affected by the permission and privacy settings you establish at that Social Networking Site, but can include information such as your name, profile picture, public Facebook profile, network, gender, username, user ID, age range or birthday, place of work, relationship interests, language, location, country, interests, photos, photos you are tagged in, videos, contacts list, friends lists or followers and other information such as information about Facebook friends you might share in common with other members of the Services. By using or linking our Services through or with a Social Networking Site, you are authorizing Swinger Nation to collect, store, retain and use, in accordance with this Policy, any and all of your information that Swinger Nation has obtained from the Social Networking Site, including to create a Swinger Nation profile page and account for you. Depending on the Social Networking Site and your privacy settings, Swinger Nation may also post information to your Social Networking Site. Your agreement to the foregoing takes place when you “accept” or “allow” or “go to” (or other similar terms, such as tapping “Okay”) our application from a Social Networking Site, go to a Social Networking Site from the Services, when you sign up or login to the Services through a Social Networking Site (such as by tapping “Sign up with Facebook” or “Log in with Facebook” on the Services), when you otherwise connect or link your Social Networking Site to our Services, or the transfer of information to Swinger Nation from such site. If there is information about your “friends” or people you are associated with in your Social Networking Site account, the information we obtain about those persons may also depend on the privacy settings such people have with the applicable Social Networking Site. You acknowledge and agree that Swinger Nation is not responsible for, and has no control over, any applicable privacy settings on any Social Networking Sites (including any settings related to any messages or advertisements about Swinger Nation that the Social Networking Site may send to you or your friends). You should always review, and if necessary, adjust your privacy settings on Social Networking Sites before getting or using applications such as ours or linking or connecting your Social Networking Site account to the Services.
• Location Data. We do not currently collect and store your precise geolocation or precise latitude or longitude coordinates for you. Some of the information we collect, for example an IP address, can sometimes be used to approximate a device’s location. In some cases, we assign the latitude and longitude of the centre of a city or state on record for you to your profile as a way to improve our analytics and matches for you.
• Information Provided by Others. We may be provided with information relating to you or your conduct on the Services by other users of the Services. For example, we will collect your email address if another user tries to refer Swinger Nation to you. We also collect information that third-party organizations may provide to us, such as contact details, demographic information, credit reference or fraud prevention information. Financial institutions or payment processors may also provide us updated payment information or payment methods related to your paid account or paid subscription and services.

We also collect, use and share aggregated and/or anonymous data (“Aggregated Data”) for any purpose. Examples include aggregated statistical or demographic data or data provided in hashed, non-human readable form. For example, we may aggregate your usage data on how you use the Services (“Usage Data”) to calculate the percentage of users accessing a specific website feature. Aggregated Data may be derived from your personal data but does not directly or indirectly identify you and therefore does not amount to personal data.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where you do not provide the personal data detailed in this Policy, we may not be able to provide you with the Services.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Please Contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new member	Profile Data, such as name, age, sexual orientation, marital status, number of children, and location Contact Data such as email address, phone number, or social media user account, as limited by your privacy settings Data from Social Networking Sites (If you use Facebook or Google to log-in to the Swinger Nation Services), including any interests or other data imported from your Social Networking Sites Technical Data, such as device ID or IP Address, including timestamps	Performance of a contract with you With your consent in the case of sensitive personal data.
To provide the Swinger Nation Services to you, including: Maintaining a profile, answering questions, and providing information about yourself; Analysing your personal data to match you with other users; Allowing you to communicate with other users of Swinger Nation to make a match; Enabling you to purchase subscriptions and premium add-ons to enhance your opportunities to make a match with other Swinger Nation users.	Profile Data, such as name, age, sexual orientation, race, marital status, number of children, and location Contact Data such as email address, phone number, or social media user account ) Data from Social Networking Sites (If you use Facebook or Google to log-in to the Swinger Nation Services), including any interests or other data imported from your Social Networking Sites Transaction Data, including, if applicable depending on your payment mechanism, your credit card, expiration date, name, address, transaction ID, timestamps, email address, bank account, and routing number Communications Data, including the content of messages, the name and ID of the recipients of the communications, the timestamp, IP address and/or Device ID of the parties to the messages Photos, including various analytics and scoring results Usage Data Analytics and other scores used to make matches with other Swinger Nation users Technical Data	Performance of a contract with you With your consent (with regard to your Sensitive Personal Data)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Communicating with you	Profile Data Transaction Data Contact Data Communications Data Photos Usage Data	Performance of a contract with you Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey	Profile Data Contact Data Usage Data Any information, content, or submissions required as set forth in the contest rules when published	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business, the Swinger Nation Services, this website and your personal data (including security, fraud, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Profile Data Contact Data Technical Data Usage Data Communications Data Third Party Data provided to us by trusted partners, including proprietary scores, red flags, demographic information, usage data, and other information used to determine whether a Swinger Nation account is being used improperly, accessed by an unauthorized third party, or represents a security or fraud risk to the Swinger Nation community	Necessary for our legitimate interests (for running our business, provision of administration and IT services, cybersecurity, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Device ID IP Address Location (at country, state, city, or postal code level) Gender Age Technical Data such as OS version, hardware type, software type. Cookies, pixels, or advertising tags Usage Data	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) With your consent for targeted advertising and profiling to serve more accurate advertising content to you.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Profile Data Usage Data Technical Data Communications Data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To respond to requests from law enforcement	Profile Data Transaction Data Usage Data Communications Data Location Data (at country, state, city, or postal code level) Technical Data Any other information we are compelled to provide by law	Necessary to comply with our legal obligations

MARKETING

Where you have interacted with us, we will send you marketing communications from time to time. Such marketing communications are usually sent by email or text (SMS). If you do not want to receive such marketing communications, you have the opportunity to inform us by selecting certain boxes when we collect your personal data.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may choose to opt out of receiving marketing communications from us at any time by contacting us here. You may also select the “unsubscribe” link in the communication we send to you.

When you receive communications from Swinger Nation, including marketing communications, we may share your personal data with third party companies who help us conduct marketing activities. For example, we may use a third party to help us send email messages to you and help us understand how you have interacted with that email.

CHANGE OF PURPOSE

We will generally only use your personal data for the purposes for which we collected it.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will retain your personal data for as long as necessary to fulfil the purposes we collected and/or processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We also retain backups of the Swinger Nation, including your personal data, on a rolling basis according to our internal data retention, disaster recovery, and business continuity policies. Our backups are stored off-site in the United Kingdom and in secure facilities in order to help ensure the protection of your personal data and the Services.

EXCEPTIONS

We retain blacklists of fraudulent activity or security threats indefinitely in order to protect the security of the Swinger Nation and your personal data. We share these blacklists with third party service providers in order to continue to improve the security of our Services and your personal data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, statistical or other purposes in which case we may use this information indefinitely without further notice to you.

MISCELLANEOUS

This Policy does not create rights enforceable by third parties or require disclosure of any personal data relating to users of the Service.

We reserve the right to modify this Policy from time to time. If we make changes to this Policy, we will change the “Last Revision” date below and will post the updated Policy on this page. We may also provide other methods of notice or request your consent depending on the circumstances.

The language of this Policy is English. Where Swinger Nation has provided a translation of the English version of this Policy, you agree that the translation is provided for your convenience only and that the English language version of this Policy will govern your relationship with Swinger Nation. If there is any contradiction between what the English language version of this Policy says and what a translation says, then the English language version will take precedence.

This Policy was last revised on May 21, 2018. For users who registered for the Services prior to May 21, 2018, this Policy will be effective on May 25, 2018.