PRIVACY AND COOKIES POLICY

The Basics

We are committed to protecting the privacy and security of all Users. As the data controller, Winchester Consultancy Ltd is here to assist with any data or privacy inquiries through our contact form.

  1. SIMPLE: We utilize your data for core functions, such as creating your profile, using the site, and enhancing your experience.

  2. SECURE: Having used the site for over a decade, we prioritize safety and security for all data.

  3. NO SPAM: We do not send marketing messages. Email notifications, such as message alerts, are strictly opt-in, allowing you control over your preferences.

  4. WHEN YOU'RE GONE, YOU'RE GONE: Deleting your account is irreversible. All associated data is securely deleted in accordance with our legal obligations.


The Golden Rule

Guard your privacy carefully. Do not share, post, or add anything online (including on Freeswingers) that you would be upset about if misused or made public. This includes account details, photos, videos, webcam feeds, messages, and any content labeled as "private." By using the site, you agree to adhere to this rule.


The Details

Purpose of This Policy

This policy outlines what to expect when we collect your personal information. Please only use our service if you fully agree with this policy.

Changes to the Policy

This policy may change. Continued use of the site after any changes signifies your acceptance of the new version.

Information We Collect

  • User-Provided Information: Data uploaded or given during registration or profile completion, which may include “special category data” (e.g., details about race, sexual orientation).
  • Automated Information: Includes IP address, browser type, device information, unique reference numbers, and clickstream data.
  • Age Verification: We may store an "18+ verified" flag for users who upgrade or perform actions verifying their adult status, without storing additional details.
  • Location Information: If opted into “Who Is Near,” we collect GPS coordinates from your smartphone for proximity features, which can be turned off at any time.

Legal Basis for Information Collection

  • Necessary for service provision under our contract with you.
  • Based on your explicit consent for special category data.
  • In our legitimate interests, including managing and improving our service and preventing fraud.

Cookies

Cookies and tracking technologies are utilized on our website. A cookie is a small file sent to your computer. Rejecting cookies may limit website functionality. The website may use session cookies, log-in cookies, and Google Analytics cookies for tracking and service improvement.

By using our website, you consent to the use of cookies as described.


Use of Personal Information

We may use personal information for:

  • Providing our services (e.g., creating profiles, processing payments).
  • Age or other verification purposes.
  • Notifying you of new messages (if opted in).
  • Recognizing you upon return visits to enhance user experience.

Data Retention

We delete personal information upon account deletion. All data is permanently removed in line with legal guidelines. Accounts may also be deleted after a period of inactivity or due to Terms and Conditions breaches.


Sharing Personal Information

  • With Other Users: Personal information in your public profile or posts.
  • With Law Enforcement: Upon request or if a criminal act may have occurred.
  • During Business Transactions: In the case of sale or merger of our business.
  • With Payment Partners: Payment details go directly to our partners; we do not handle this information.

Payment Details

Payment information is handled by our partners, who may share data with credit reference and fraud prevention agencies.

Data Transfers

Your personal information is stored within the EU and is not transferred outside the EU.


User Rights

You have rights under legal requirements to:

  • Access your personal information.
  • Rectify any inaccuracies.
  • Delete, restrict, or object to the use of your information.
  • Request data portability.

For complaints regarding our handling of personal information, contact us via the contact form. If unsatisfied, you can escalate to the Information Commissioner’s Office (ICO).

For further details about your rights, visit the ICO’s website: www.ico.org.uk.


Changing Your Settings

You can adjust your privacy settings anytime via the privacy page when logged in.


This structured approach should enhance clarity and accessibility for users while maintaining the necessary legal coverage. Let me know if you need further adjustments or additional sections!