Privacy Notice
Privacy Notice
How SULTRAFIED collects, uses, protects and shares Account, profile, verification, sensitive, location, messaging, safety, commercial, Club, Event and Creator information.
SULTRAFIED handles information that can be highly sensitive in context.
Participation in an adult social community may reveal information about relationships, sex life, sexual orientation, preferences or other private matters. SULTRAFIED therefore treats privacy, purpose limitation, restricted access and appropriate security as fundamental requirements of the Service.
Who is responsible for your information?
SULTRAFIED is the service and trading identity used for the adult community described in this Notice. The legal entity operating SULTRAFIED and identified in the SULTRAFIED Terms & Conditions is the controller for personal information where it determines why and how that information is processed.
SULTRAFIED’s privacy principles
Purpose
Use information for identified and lawful purposes.
Minimisation
Do not collect more information than is reasonably needed for the relevant purpose.
Access
Restrict sensitive information according to role, purpose and legitimate need.
Accountability
Document important processing decisions and maintain appropriate safeguards.
Purpose and scope
1.1 This Privacy Notice explains how SULTRAFIED handles personal information in connection with sultrafied.com and SULTRAFIED services.
1.2 It applies to information concerning Members, prospective Members, Creators, Couple Profile participants, Club managers, Event organisers, ticket purchasers, attendees and other persons whose information SULTRAFIED processes.
1.3 Some processing is explained in greater detail in specialist SULTRAFIED policies.
1.4 In particular, this Notice should be read together with the Privacy / Special Category & Biometric Data Policy where relevant.
1.5 This Notice concerns personal information. Separate contractual rules govern ownership and licensing of Member Content.
What happens if you do not provide information?
2.1 Some information is necessary to create, secure or operate an Account.
2.2 Depending on the feature, required information may include:
2.3 If required Account, age, verification or payment information is not provided, SULTRAFIED may be unable to provide the relevant service.
2.4 Other profile fields may be optional.
2.5 Choosing not to provide optional information may affect matching, discovery or other features that depend on that information, but should not be treated as agreement to provide unrelated data.
Information you provide directly
Username, email address, mobile number where supplied, Account settings, Account status and authentication information.
Date-of-birth or age information, profile type, gender information where supplied, location, interests, preferences, biography and information you choose to display.
Profile photographs, galleries, videos, Creator Content and other media uploaded to the Service.
Identity-document information, selfies, liveness information, age evidence and verification submissions where required.
Messages sent to SULTRAFIED, support enquiries, reports, complaints and other communications.
Creator applications, Club-management requests, Event information, payout details and information necessary for paid services.
Information created when you use SULTRAFIED
4.1 SULTRAFIED may create or record information as part of operating the Service.
4.2 The precise information generated depends on which SULTRAFIED features you use.
Information obtained from other sources
5.1 SULTRAFIED may receive information about you from third parties where appropriate.
5.2 Information obtained from another source is not automatically treated as accurate merely because it was supplied by a third party.
5.3 SULTRAFIED may assess reliability, relevance and proportionality before using information for a significant purpose.
Technical and security information
6.1 SULTRAFIED may process technical information needed to operate, secure and diagnose the Service.
6.2 Some technical identifiers can constitute personal information even though they do not directly state a person’s name.
Adult-community information may reveal particularly sensitive matters
7.1 UK data-protection law gives additional protection to certain categories of personal information.
7.2 Depending on what a Member chooses to provide and how SULTRAFIED uses it, information may reveal or concern:
7.3 Not every photograph, preference or interaction is automatically special-category information.
7.4 Context, purpose and the way information is processed determine whether special-category rules apply.
7.5 SULTRAFIED must identify both an ordinary lawful basis and an applicable additional special-category condition before carrying out processing that falls within those rules.
7.6 More information is available in the Special Category & Biometric Data Policy .
Age assurance and identity verification
8.1 SULTRAFIED may process information to establish eligibility for an adults-only Service, verify identity, prevent impersonation and protect Account integrity.
8.2 Depending on the process implemented, information may include:
8.3 A photograph or selfie is not automatically biometric special-category information simply because it shows a face.
8.4 Where specific technical processing is used to allow or confirm unique identification, the biometric provisions of applicable data-protection law may apply.
8.5 Verification providers may process information on SULTRAFIED’s behalf or, depending on the arrangement, under their own legal responsibilities.
8.6 Verification information should not be made publicly available to ordinary Members.
8.7 See the Age Assurance Statement and Verification & Background Check Disclaimer .
Location information
9.1 SULTRAFIED may process location information to provide local discovery, search and Event features.
9.2 Depending on the feature, this may involve:
9.3 A displayed distance should not automatically be interpreted as disclosure of another Member’s exact residential address.
9.4 Where a future feature requests precise device location, the applicable permission and transparency requirements should be provided before that feature is used.
Messages and private communications
10.1 Messages exchanged through SULTRAFIED are intended for the participants in the relevant conversation, subject to applicable Platform functionality.
10.2 SULTRAFIED may process message information as necessary to:
10.3 SULTRAFIED does not represent ordinary private messages as publicly visible profile information.
10.4 However, “private” does not mean that SULTRAFIED can never process a message for legitimate security, complaint, moderation or legal purposes.
10.5 Members should not assume that deleting a message from their own interface necessarily erases a copy already received by another Member.
Private and restricted Content
11.1 SULTRAFIED may offer access controls for photographs, videos or other Content.
11.2 Visibility settings determine ordinary access through SULTRAFIED but do not make digital copying technically impossible.
11.3 SULTRAFIED may process restricted Content for technical delivery, storage, security, moderation, reported-content review and other lawful Service purposes.
11.4 Access by staff or service providers should be restricted according to role and legitimate need.
11.5 More information is available in the Privacy / Anti-Copy Technology Disclaimer .
Friends, blocks, Hotlists and other interactions
12.1 SULTRAFIED may process records concerning how Accounts interact.
12.2 This may include:
12.3 Blocking information may be retained for as long as reasonably necessary to enforce the block and prevent circumvention or abuse.
12.4 A block may also cause existing friendship, Hotlist or private-access relationships to be removed in accordance with Platform rules.
Couple / Shared Profile information
13.1 A Couple Profile may contain information relating to two separate individuals.
13.2 Each person has their own data-protection rights in relation to information concerning them.
13.3 One participant cannot automatically exercise every privacy right on behalf of the other merely because they share a Couple Profile.
13.4 Joint verification information may be processed to establish that both adults are genuinely participating.
13.5 Following separation, information may need to be restricted, separated, preserved or removed depending on the circumstances and applicable rights.
13.6 See the Couple / Shared Profile Terms .
Creator onboarding, Content and payouts
14.1 Additional information may be processed when a Member applies for or uses Creator functionality.
14.2 This may include:
14.3 Creator financial information should not be made publicly visible merely because a Member has Creator status.
14.4 Additional requirements are contained in the Creator Terms & Conditions .
Performer identity and compliance records
15.1 Explicit Creator Content may involve additional age, identity, performer and consent information.
15.2 SULTRAFIED may request or process supporting evidence where reasonably necessary for Creator compliance, age assurance, consent, rights verification or applicable record-keeping requirements.
15.3 Performer identity documents are highly sensitive and should not be exposed to ordinary Members or purchasers.
15.4 Retention may differ where an independent statutory record-keeping requirement applies.
15.5 See 2257 / Explicit Creator Content Compliance .
Commercial and transaction information
16.1 SULTRAFIED may process transaction information for memberships, Content, gifts, Event tickets, Creator orders and other paid features.
16.2 This may include:
16.3 Full payment-card credentials should ordinarily be handled by the applicable specialist payment provider rather than stored in full by SULTRAFIED.
16.4 SULTRAFIED may receive limited card or account metadata from the provider where necessary for transaction administration.
16.5 See the Payments, Memberships & Subscription Terms .
Safety, moderation and complaint information
17.1 SULTRAFIED may process information when Content, an Account, message, Club or Event is reported.
17.2 Safety information may include:
17.3 SULTRAFIED may preserve evidence after public Content has been removed where reasonably necessary for safeguarding, fraud, enforcement, legal claims or compliance.
17.4 Reporters’ identities should not automatically be disclosed to the person reported.
17.5 Disclosure may nevertheless occur where required by law or genuinely necessary for a fair legal process.
Reports may sometimes contain allegations of criminal conduct
18.1 Safety reports, fraud investigations or legal communications may include information concerning suspected or alleged criminal activity.
18.2 Criminal-offence information is subject to additional legal restrictions.
18.3 SULTRAFIED must identify an ordinary lawful basis and any additional legal authority or statutory condition required before processing such information.
18.4 Where required, SULTRAFIED should maintain an appropriate policy document covering relevant sensitive or criminal-offence processing.
18.5 SULTRAFIED does not maintain a general public criminal-conviction register of Members.
18.6 A Member report is not itself proof that a criminal offence occurred.
Lawful bases used by SULTRAFIED
19.1 SULTRAFIED must identify an appropriate lawful basis before processing personal information.
19.2 The basis depends on the specific purpose.
19.3 SULTRAFIED does not rely on “contract” merely because processing has been written into Terms.
19.4 Contractual necessity requires the processing to be genuinely necessary for the relevant contractual service.
19.5 Where SULTRAFIED relies on legitimate interests, it must identify the interest, assess necessity and consider the impact on the individual’s rights and freedoms.
Special-category processing requires more than an ordinary lawful basis
20.1 Where SULTRAFIED processes special-category information, an Article 6 lawful basis alone is not sufficient.
20.2 SULTRAFIED must also identify an applicable special-category condition.
20.3 Depending on the processing, that may include explicit consent or another condition available under applicable law.
20.4 SULTRAFIED must not claim that merely accepting the ordinary Terms automatically constitutes explicit consent to every possible use of sensitive information.
20.5 Where explicit consent is relied upon, the consent process should clearly identify the relevant sensitive information and purpose.
Where SULTRAFIED relies on consent
21.1 Consent should be freely given, specific, informed, affirmative and capable of being withdrawn.
21.2 Where explicit consent is required, SULTRAFIED should use a clear express statement appropriate to the sensitive processing concerned.
21.3 Withdrawal of consent does not automatically make processing carried out lawfully before withdrawal unlawful.
21.4 Where a particular optional feature genuinely depends on consent, withdrawing that consent may mean the feature can no longer operate.
21.5 SULTRAFIED should not respond to withdrawn consent by retrospectively changing the same processing to a different lawful basis merely to avoid the withdrawal.
Who SULTRAFIED may share information with
22.1 SULTRAFIED may share the minimum information reasonably necessary with appropriate recipients.
22.2 A supplier acting as SULTRAFIED’s processor should process information according to applicable contractual and data-protection obligations.
22.3 Some third parties may act as independent controllers for their own processing.
22.4 Their independent privacy responsibilities are not converted into SULTRAFIED processing merely because a transaction began through SULTRAFIED.
Profile and Content visibility
23.1 Information you deliberately publish to your profile may be visible to other eligible Members according to the relevant visibility settings.
23.2 Content marked as Friends-only, restricted or private should be made available according to the applicable access-control rules.
23.3 Visibility settings do not prevent SULTRAFIED from processing information where reasonably necessary for legitimate operational, moderation, security or legal purposes.
23.4 Members must not use Content visibility as authority to redistribute another person’s private information contrary to the Community Rules or law.
No unrestricted advertising use of private sensitive data
24.1 SULTRAFIED does not treat verification documents, private messages or private intimate media as unrestricted advertising inventory.
24.2 SULTRAFIED should not sell or license Member-specific special-category information to advertisers for unrelated behavioural advertising without a valid legal basis, applicable special-category condition and any required consent.
24.3 Optional marketing or attribution technologies are subject to the Cookies & Storage Technologies Policy .
Transfers outside the United Kingdom
25.1 SULTRAFIED may use service providers located in, or capable of accessing information from, countries outside the United Kingdom.
25.2 Where this constitutes a restricted international transfer, SULTRAFIED must ensure that the transfer is covered by an applicable lawful mechanism.
25.3 Depending on the recipient and country, this may include:
25.4 Where appropriate safeguards are used, SULTRAFIED should conduct the legally required assessment of protection and supplementary measures.
25.5 You may contact Legal@sultrafied.com for information about the transfer mechanism relevant to your information where applicable.
Retention is purpose-based
26.1 SULTRAFIED does not intend to retain personal information indefinitely merely because it may be useful someday.
26.2 Retention periods or criteria depend on:
26.3 Verification documents and sensitive verification media should be retained only for the period justified by the particular verification, fraud, safety or legal purpose.
26.4 Moderation or enforcement information may need to be retained after Account closure where necessary to prevent serious abuse, enforce a lawful ban, preserve evidence or meet legal obligations.
26.5 Transaction records may be retained after the Member Account closes where required for accounting, tax, refunds, chargebacks or legal claims.
Deleting an Account does not always mean every record disappears instantly
27.1 Closing an Account should stop ordinary Account use and public presentation in accordance with the applicable closure process.
27.2 Some information may remain for a limited period in:
27.3 Backup copies should not ordinarily be restored into active use for unrelated purposes after deletion.
27.4 The right to erasure is important but is not absolute. Applicable law may permit or require continued retention in particular circumstances.
Protecting personal information
28.1 SULTRAFIED must implement technical and organisational measures appropriate to the risks associated with its processing.
28.2 Measures selected according to risk may include:
28.3 No online service can guarantee absolute security.
28.4 That limitation does not remove SULTRAFIED’s duty to implement appropriate security for the risks it controls.
28.5 Where a personal-data breach occurs, SULTRAFIED will assess regulatory and Member-notification obligations and make required notifications in accordance with applicable law.
28.6 High-risk processing should be subject to a Data Protection Impact Assessment where required.
Recommendations, fraud tools and automated decisions
29.1 SULTRAFIED may use automated processing to support functions such as:
29.2 Not every automated recommendation or risk score is a legally or similarly significant automated decision.
29.3 Where SULTRAFIED makes a significant decision based solely on automated processing, applicable safeguards must be provided.
29.4 Depending on applicable law, safeguards may include information about the decision, the ability to make representations, challenge the outcome and obtain meaningful human intervention.
29.5 Stricter rules apply to significant solely automated decisions based on special-category information.
29.6 SULTRAFIED should provide more specific information about the logic, significance and likely consequence where a feature falls within these significant automated-decision rules.
Communications, cookies and marketing preferences
30.1 SULTRAFIED may send operational communications that are reasonably necessary to administer an Account or transaction.
30.2 These may include:
30.3 Promotional marketing is different from essential service communication.
30.4 SULTRAFIED will use consent or another lawful route only where electronic-marketing rules permit it.
30.5 Marketing communications should provide an appropriate unsubscribe or preference-management route.
30.6 Cookies, local storage and similar technologies are explained separately in the Cookies & Storage Technologies Policy .
Your rights
31.1 Depending on the circumstances and applicable law, you may have rights including:
31.2 These rights are not all absolute and their availability can depend on SULTRAFIED’s lawful basis, the information involved and applicable exemptions.
31.3 SULTRAFIED may need to verify identity before fulfilling a rights request.
31.4 Where clarification is reasonably necessary to respond to a request, SULTRAFIED may seek that clarification in accordance with applicable law.
Your right to object
Where you exercise this right, SULTRAFIED should stop using the relevant personal information for direct marketing subject to the limited processing necessary to maintain a suppression record.
32.1 You may also have a right to object where SULTRAFIED relies on legitimate interests.
32.2 That right is considered according to the applicable legal test and may operate differently from the absolute objection right for direct marketing.
How to make a privacy request
33.1 Privacy and data-protection requests can be sent to:
33.2 Please provide enough information for SULTRAFIED to understand the request.
33.3 SULTRAFIED may request additional information where reasonably necessary to verify identity or clarify the scope of a request.
33.4 SULTRAFIED will respond within the timeframe required by applicable data-protection law.
33.5 Rights requests will ordinarily be handled without a fee, except where applicable law expressly permits a fee or other response to a manifestly unfounded or excessive request.
You can complain directly to SULTRAFIED
34.1 If you believe SULTRAFIED has infringed applicable data-protection law in connection with your personal information, you may make a data-protection complaint.
Contact Legal@sultrafied.com and explain the privacy concern.
SULTRAFIED will acknowledge a qualifying data-protection complaint within 30 days of receipt.
Appropriate enquiries will be made without undue delay.
The complainant will be informed of the outcome without undue delay and updated on progress where appropriate.
34.2 A privacy complaint is different from a general Member-support complaint, although a single communication may involve both.
34.3 SULTRAFIED should route the privacy aspect through the appropriate data-protection complaints process.
Your right to complain to a supervisory authority
35.1 UK individuals have the right to raise a complaint with the Information Commissioner’s Office (ICO), the UK’s data-protection supervisory authority.
35.2 SULTRAFIED encourages Members to contact SULTRAFIED first where appropriate so the issue can be investigated and, where necessary, corrected.
35.3 Contacting SULTRAFIED first does not remove your right to approach the ICO.
35.4 If you are located in another jurisdiction, you may also have the right to complain to another competent data-protection authority.
SULTRAFIED is not intended for children
36.1 SULTRAFIED is an adults-only service for persons aged 18 or over.
36.2 Persons under 18 must not create or use a SULTRAFIED Account.
36.3 If SULTRAFIED reasonably identifies an Account operated by a person under 18, access may be immediately restricted.
36.4 Personal information associated with an underage Account will be handled according to applicable safeguarding, evidence-preservation, reporting and deletion requirements.
36.5 SULTRAFIED will not retain unnecessary information about a child merely because an attempted registration occurred.
Lawful disclosures
37.1 SULTRAFIED may disclose personal information where required or permitted by applicable law.
37.2 Circumstances may include:
37.3 SULTRAFIED should assess the apparent legal basis, scope and proportionality of a request before disclosure where it has discretion to do so.
37.4 SULTRAFIED may be prohibited from notifying the affected person about a particular lawful request.
Corporate restructuring or transfer
38.1 Personal information may be transferred as part of a legitimate merger, acquisition, restructuring, financing or sale of all or part of the SULTRAFIED business.
38.2 Any such processing remains subject to applicable data-protection requirements.
38.3 A corporate transaction does not automatically permit the recipient to use sensitive Member information for unrelated new purposes.
38.4 Additional notice or other steps will be taken where legally required.
Privacy practices evolve with the Service
39.1 SULTRAFIED may update this Notice to reflect changes in:
39.2 The Last Updated date will change when this Notice is genuinely updated.
39.3 The Last Updated date does not change automatically simply because a calendar year changes.
39.4 Where a new use of information requires new consent or additional notice, SULTRAFIED will take the required step before carrying out that processing.
Contact SULTRAFIED about your personal information
SULTRAFIED aims to use personal information for defined purposes, limit unnecessary processing and give Members meaningful privacy controls and legal rights.