AdultWork.com

Proprietors

Websites

We operate the following websites;

www.adultwork.com
developers.adultwork.com
AdultWork.com "My Adult Sites"
platform.adultwork.com (Unified Login)
www.accessaw.com
www.awlists.com
www.awork.co.uk

All parties and websites mentioned above are hereafter referred to as "AW".

Purpose of this Policy

This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of the AW site(s), including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition. It will also inform you as to how we look after your Personal Data when you visit our website(s), regardless of where you visit it from, and tells you about your privacy rights and how the law protects you. At AW, we understand that your privacy is very important and treat it accordingly; we are committed to protecting your Personal Data.

This website is not intended for use by anyone under the age of 18 years and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other policies we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we use your data. This policy supplements other notices and policies and is not intended to override them.

If there are any provisions in this policy that you would like further clarification on, or to exercise your privacy rights, please get in contact via privacy@adultwork.com

AW Privacy Policy

1. Important Information and Who We Are

Controller

AW is the Data Controller and is responsible for your Personal Data (collectively referred to as "AW", "we", "us" or "our" in this policy).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about the policy, including any requests to exercise your legal rights, please contact the DPO via email to the address above.

Changes to the Privacy Policy and your duty to inform us of changes

We keep this policy under regular review and it is subject to change. You should refer to this policy at least once a year to remain updated.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements, policies or procedures. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Public Domain

Any information and content you provide via your public profile (Advertisers only), will be deemed as public information. Whilst in the public domain, your data can be copied, cached and stored by third parties and displayed on their site or search engine. This data may continue to exist on these sites, systems and search engines for a period even after you instruct us to remove it from our systems.

2. The Data We Collect About You

Personal Data, or personally identifiable information, 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).

Data Categories

We may collect, use, store and transfer different kinds of Personal Data about you, please see the various categories and some examples of data in those categories below:

Identity Data - First name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data - Billing address, delivery address, email address and telephone numbers.
Financial Data - Bank account and payment card details.
Transaction Data - We collect details of transactions you carry out through our website and of the fulfilment of your orders and regulatory obligations. Including but not limited to, details about payments to and from you and other details of products and services you have purchased from us.
Technical Data - Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data - Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data - Information about how you use our website, products and services.
Marketing Data - Your preferences in receiving marketing from us and our third parties and your communication preferences.
Communications Data - Records of your communication with us, including support requests and other inquiries.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

Within the General Data Protection Regulation (GDPR) these include; details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, or any information about criminal offences, alleged or convicted.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions - You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions - As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy and the other Policies & Agreements here for further details.
Third parties or publicly available sources - We will receive Personal Data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
  - analytics providers such as Google;
  - advertising networks; and
  - search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
Third-Party Processors - We use the following categories of third parties to process your data and deliver services for the purposes shown. All of these processors have access to some of your Personal Data as appropriate for the delivery of the purpose specified.

Processor Category	Purpose
Management/Moderators	Service management, monitoring & accounting
Technical Management	Website technical & support services
Hosting	Secure data centre & hosting services
Software Development	Service development & improvement
Online Services	Website apps & features for members
Payment Service Providers	Telecom PSP, credit/debit card PSP, banking & other financial services
Marketplace/Official Stores	Toys, supplies, gifts & delivery
Emails Communications/Marketing	Communications, promo offers, informational mailshots & direct marketing

If you, as a User of AW, interact with a Member or Manager of an AW Group, any data available to the Group Member will be accessible to the Group Manager also. By interacting with any such Member, you agree and consent to your information being available to one or both parties.

4. How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Purposes for which we will use your Personal Data

We will only use your Personal Data in conjunction with the lawful basis of processing for which we collected it (see below). We may also process your data for another purpose/on a different legal basis provided that it is in line with the original purpose of processing.

Note: We may process your Personal Data without your knowledge or consent, in compliance with this policy and the law.

Please see below a table describing all of the ways we may use your Personal Data and on which legal bases we do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) 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 and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) 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

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

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)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

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 make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

AW reserve the right to work with partners to provide marketing-related services to you. Our partners, processors, and subprocessors are under our DPA (Data Processing Agreement), which binds them to the same strict level of data protection standards you have agreed to under this privacy policy.

Opting out

We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy here.

5. Disclosures of Your Personal Data

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

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with this policy and our instructions.

6. International Transfers

We may share or transfer your Personal Data outside of the European Economic Area (EEA).

If ever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring we use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.

7. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business 'need to know'. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you keep my Personal Data?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. If we suspend or close your account due to fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data; see your legal rights below for further information.

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

In the event of a law enforcement request involving your account or the data we hold about you on file. We are obliged by law to comply with the request and retain the data until the case has been closed by Law enforcement. Data may be held beyond the deletion request for the basis of complying with law enforcement.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

GDPR: Individual Rights	Description
*Right to Erasure*	Every individual has the right to be forgotten upon request. The Data Controller must remove your Personal Data from its systems and request the same of any third-party systems of that controller
*Right to Access*	Every individual has the right to access their Personal Data held about them upon request.
*Right to Portability*	Every individual has the right to request their Personal Data and use it for other parties they wish to engage with.
*Right to be Informed*	Every individual has the right to be informed about how their Personal Data is being used, which may be provided upon request of the individual, or before the controller changes any use of that data, giving the individual the right to consent or object.
*Right to Objection*	Every individual has the right to object to the use of their Personal Data for any purpose proposed by a controller.
*Right to Rectification*	Every individual has the right to have errors in their Personal Data to be corrected.
*Right to Restrict*	Every individual has the right to restrict the uses of their Personal Data for any specific type of processing.
*Rights on automated decisions & profiling*	Every individual has the right to restrict or object to automated decision-making processes or profiling based on their Personal Data.

If you wish to exercise any of the rights set out above, please contact us via: privacy@adultwork.com.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We have a responsibility to identify you as the data owner when processing any DSAR or similar requests. This may mean requesting specific information from you to help us confirm your identity and assure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

Under the GDPR we are obliged to respond to any DSAR within 30 days. It could take us longer than a month if your request is particularly complex or you have made a number of requests; in this case, we will notify you and keep you updated.

What is a Lawful Basis of use?

- Legitimate Interest - In the interest of our business, in conducting and managing it, to enable us to give you the best service/product and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required/permitted to by law.
- Performance of Contract - Processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
- Compliance with a legal obligation - Processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

Other AW Terms, Policies and Agreements

Other Terms, Policies and Agreements may apply to the supply of any products or services by the AW website(s) guest and/or registered Users.

The full list of Our Terms, Policies and Agreements can be found here.

E&OE: If you notice any errors (spelling, grammar or other) in this Agreement, please feel free to notify Us via the Help Centre.

Email: privacy@adultwork.com