Privacy and Cookies Policy

FIRST SEEN 2026-07-29 · VERSION 20260729_rev01 · COMPARED WITH 20250709_rev01

Full text changes — 20250709_rev01 to 20260729_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 ## PRIVACY AND COOKIES POLICY
+Effective Date: May 2025
+Effective Date: June 2026
+Last updated: June 2026
 ## The Basics
 We're absolutely committed to protecting the privacy and security of all Users. We use this site too. The controller is Winchester Consultancy Ltd and you can contact us [using this form with any data/privacy queries](https://fabswingers.com/contact).
 \. **SIMPLE**: We use your data for core functions like creating your profile, using the site, and improving your experience.
+\. **SECURE**: We use the site ourselves and have our own data on here and we've been keeping it safe and secure for over 10 years.
+\. **SECURE**: We use the site ourselves and have our own data on here and we've been keeping it safe and secure for over 15 years.
+\. **NO SPAM**: We don't send any marketing messages. Email notifications for stuff like message notifications are all opt-in only (you can control from [email notifications page](https://fabswingers.com/my/email_notifications)).
+\. **NO SPAM**: We don't send any marketing messages. Email notifications for things like message notifications are all opt-in only and you can control them from the [email notifications page](https://fabswingers.com/my/email_notifications).
+\. **WHEN YOU'RE GONE, YOU'RE GONE**. If you delete your account, it's not recoverable from the instant you hit the Delete button. All data is securely and automatically deleted in line with our legal obligations.
+\. **WHEN YOU'RE GONE, YOU'RE GONE**. If you delete your account, we remove it permanently and promptly. Your profile, content, messages and images are securely deleted in line with GDPR.
 ## The Golden Rule
+Guard your privacy carefully and NEVER share, post or add ANYTHING ANYWHERE online (including on Fab) which you would be UPSET about if it was misused or made public (either intentionally e.g. maliciously by another user, or accidentally). This goes for any type of content including but not limited to account details, photos, videos, webcam, messages etc. including content described as "private". By using the site, you agree to follow The Golden Rule.
+Guard your privacy carefully and NEVER share, post or add ANYTHING ANYWHERE online, including on our Service, which you would be UPSET about if it was misused or made public, whether intentionally, for example maliciously by another User, or accidentally.
+This goes for any type of Content including, but not limited to, account details, photos, videos, webcam, messages and anything described as "private". By using the Service, you agree to follow The Golden Rule.
 ## The Details
+**What's the point of this policy?**
+**What is the point of this policy?**
+It tells you what to expect when we collect your personal information. Please only use our service if you are completely happy with this policy.
+It tells you what to expect when we collect your personal information. This policy explains how we handle your information. Please read it carefully before using the Service.
 Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.
 **Might the policy change?**
+Yes. We will give you notice of the new version by posting it on our service and will assume you agree to the new version of the policy if you use the site after its effective date. Please keep a close eye on this policy.
+Yes. We may update this policy from time to time. The updated policy will apply from the effective date shown. Where a change is material, we will take reasonable steps to bring it to your attention. Where we need your consent for new or changed processing, we will ask for it.
 **What do we collect?**
+Information which you upload to our service or otherwise give us when registering with us or completing your profile, which may include your gender, dob, postcode (first part), town, sexuality, height/weight, tattoos, alcohol/smoking habits, ethnicity as well as your sexual/partner preferences. Some of this information will be "special category data" such as details about your race/racial origin, sex life and/or sexual orientation.
+We may collect and process the following information.
+Information which you upload to our Service or otherwise give us when registering with us or completing your profile. This may include your gender, date of birth, postcode first part, town, sexuality, height/weight, tattoos, alcohol/smoking habits, ethnicity, and your sexual or partner preferences. Some of this information will be "special category data", such as details about your race or racial origin, sex life and/or sexual orientation.
 Account information such as your username and password, and your contact or other account preferences.
+Information (including text, photos, videos) that you include in posts or otherwise provide for display on our service or that you include in private messages sent to other users via our service and/or in communications with us.
+Information, including text, photos and videos, that you include in posts or otherwise provide for display on our Service, or that you include in private messages sent to other Users via our Service and/or in communications with us.
+If you upgrade by text from an 18+ registered phone or upgrade by using a credit card that is only available to adults 18+, we may store an 18+ verified flag as part of your account data (to clarify, we do not store or are passed any other details about the upgrade). This will not be visible as part of your public profile. We may also store an 18+ verified flag if you perform other actions on the site that conform to relevant regulations and prove you are an adult 18+. We may make use of this 18+ data at our discretion or if required by law in a particular country.
+Information used for age assurance, identity verification, photo verification, safety, security and moderation. This may include images you submit for verification, information derived from those images, verification results, 18+ flags, records of whether a check was completed, passed or failed, and records of any review or appeal.
+Location based information: If you opt in to "Who Is Near", we store GPS coordinates from your smartphone in order to show live information on who is near based on their GPS coordinates. You can turn this off at any time.
+If you submit Content that depicts someone else, or if we ask you to provide evidence of consent or age ID for someone shown in your Content, we may process the consent documents, age ID information and related communications you provide. You must make sure you have the right to provide that information to us.
+Automated browsing information such as the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device-identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, the site from which you arrived at our service, details of your activity with date/time stamps including pages you visited and your searches / transactions.
+If you upgrade by text from an 18+ registered phone or upgrade by using a credit card that is only available to adults 18+, we may store an 18+ verified flag as part of your account data. To clarify, we do not receive or store payment-card details or full payment information from that upgrade. We may also store an 18+ verified flag if you perform other actions on the site that conform to relevant regulations and prove you are an adult 18+. We may make use of this 18+ data at our discretion or if required by law in a particular country.
+**What's our legal basis for collecting the information?**
+Location-based information: If you opt in to "Who Is Near", we store GPS coordinates from your smartphone in order to show live information on who is near based on their GPS coordinates. You can turn this off at any time.
+Because it's necessary to provide you with our services under our contract with you.
+Automated browsing information such as the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device-identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, the site from which you arrived at our Service, and details of your activity with date/time stamps including pages you visited and your searches or transactions.
+Because you've specifically agreed, in the case of "special category data" (see above), for example in the context of setting up your profile page whereby you are displaying details of your sex life to others. You can withdraw your consent at any time by deleting your account.
+**Automated processing, verification and facial analysis**
+Because it's in our "legitimate interests", e.g., managing and improving our service including tracking usage patterns and preventing or detecting fraud or abuse. This may include reviewing private messages, which we are only likely to do if there is a complaint or report or police request.
+To help keep our Service safe, keep under-18s out, enforce our Terms and Conditions and prevent unlawful or abusive use, we use automated systems, including artificial intelligence, machine-learning tools, rule-based systems, third-party verification providers and human review.
+Because it's necessary to comply with legal or regulatory obligations.
+These systems may help with content moderation, report triage, fraud and abuse prevention, spam and scam detection, security, age assurance, identity verification, photo verification, liveness checks, detecting or reducing unlawful Content, Intimate Image Abuse Content, Childlike or Minor-Presenting Sexualised Content, underage access, fake or duplicate accounts, ban evasion, prohibited Commercial Use and other activity that may breach our Terms and Conditions or create risk.
+**What about cookies?**
+As part of identity verification, photo verification, liveness checks and age assurance, an image or video you provide may be analysed automatically, including automated analysis of facial features. This may be used to assess whether a person appears to be present and live, compare images submitted by you, check images against our requirements, estimate age range, support age verification, support photo verification, detect misuse of images, or protect Users and the Service. This analysis may be carried out by a service provider acting on our behalf.
+We and/or other companies use cookies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your browser.
+This may involve two types of information. First, we process ordinary personal data such as your account details, submitted images, verification status, technical information, and records of checks, reviews or appeals. Secondly, where automated facial analysis creates biometric data used to identify or verify you, that generated biometric data is special category data.
+Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (how long will depend on the lifetime of the specific cookie). Our website's functionality will be limited if you configure your browser to reject cookies.
+We do not build or retain a general biometric identification database, and we do not retain a full biometric template, faceprint or biometric identifier for the purpose of generally identifying you after the relevant check is complete. However, our verification and age assurance checks may generate biometric data for a limited purpose, for example to detect whether the same person is attempting to verify more than once or to bypass, manipulate, repeatedly retry or otherwise abuse these processes. Where this happens, we process that biometric data under Article 9(2)(g) UK GDPR (substantial public interest), as set out further below in this section, and this processing is governed by our Appropriate Policy Document. We retain only the limited information needed for this purpose, and we do not retain it for more than 30 days, after which it is deleted.
+The only cookies used on this website are those that are necessary to enable the site to function correctly. These include "load-balancing" cookies placed by our host for stability of our website. We do not use "non-essential" cookies, e.g., for analytics/advertising.
+Before we carry out automated facial analysis, we ask you to confirm that you understand and agree to the check. We do not rely on your agreement as our UK GDPR lawful basis or, where biometric data is involved, as our special-category condition.
+For ordinary personal data involved in age assurance, identity verification, photo verification, safety, security and moderation, our Article 6 lawful basis is one or more of the following, depending on the context: that the processing is necessary to comply with legal obligations that apply to us; that it is necessary to perform our contract with you, including operating a private membership service in accordance with our Terms and Conditions; and/or that it is necessary for our legitimate interests in keeping the Service safe and secure, preventing fraud and abuse, verifying that Users meet our requirements, enforcing our Terms and Conditions, and protecting Users, us and others.
+Where facial analysis generates biometric data used for identity, photo or age verification, we rely on Article 9(2)(g) of the UK GDPR because the processing is necessary for reasons of substantial public interest. The relevant conditions in Schedule 1 to the Data Protection Act 2018 may include preventing or detecting unlawful acts, safeguarding children and individuals at risk, and preventing fraud, depending on the purpose of the particular processing. We document the Schedule 1 condition or conditions that apply to this processing and have an Appropriate Policy Document in place governing it.
+Although we ask for your agreement before carrying out this analysis, our basis is not consent. Where the law gives you a right to object to this processing, you may object.
+Where reasonably practicable and where required by applicable law, we may offer an alternative verification method that does not use automated facial analysis. Any alternative method may take longer, may require different evidence, may not be available for all features, countries, risk scenarios or abuse-prevention cases, and must still satisfy our verification requirements. If you do not complete any verification method that we reasonably require, or if the method used does not verify that you meet our requirements, we may have to decline or restrict your access to all or part of the Service.
+If a verification or moderation decision significantly affects you, we will not make that decision solely by automated processing without the possibility of human review where such review is required by applicable law. Where required by law, you may request human intervention, make representations or contest the decision by [contacting us using this form](https://fabswingers.com/contact). A member of our team with authority to review the decision will consider the relevant information, including any additional information you provide, and may uphold or change the decision.
+Where this analysis is carried out, the image may be processed on our service provider's infrastructure located outside the UK. See "Do we send your information outside the UK?" below.
+**What is our legal basis for collecting the information?**
+Because it is necessary to provide you with our services under our contract with you.
+In the case of "special category data" that you choose to display on your public profile, for example details of your sex life, sexual orientation or ethnicity, our condition for processing is that you have manifestly made that information public by choosing to publish it to other Users of the Service (Article 9(2)(e) UK GDPR). You can stop this processing at any time by removing the information or deleting your account.
+Separately, in the case of biometric data generated by facial analysis for identity, photo and age verification, we ask for your agreement before carrying out the check, but our basis is not consent. We rely on the substantial public interest condition described in "Automated processing, verification and facial analysis" above. Different rights apply to that processing, which may include a right to object as explained in that section.
+Because it is in our legitimate interests, for example managing and improving our Service, tracking usage patterns, keeping the Service safe and secure, preventing or detecting fraud, spam, scams, abuse, prohibited Commercial Use, underage access, non-consensual Content, Intimate Image Abuse Content, Childlike or Minor-Presenting Sexualised Content, fake or duplicate accounts, ban evasion, and other misuse of the Service.
+This may include automated processing of private messages to help detect or prevent spam, scams, prohibited Commercial Use, fake or duplicate accounts, ban evasion and similar misuse of the Service. Manual review of private messages is only likely to occur where there is a complaint, report, law enforcement request, legal or regulatory requirement, safety concern, suspected breach of our Terms and Conditions, or other specific moderation, security or abuse-prevention reason.
+Because it is necessary to comply with legal or regulatory obligations. Where automated processing of private messages is necessary to detect, prevent or remove illegal content, to protect children, or to comply with our duties under online safety laws and other legal or regulatory obligations, we carry out that processing because it is necessary to comply with a legal obligation, and, where special category or criminal-offence data is involved, on the basis of substantial public interest under Article 9(2)(g) UK GDPR and the relevant conditions in Schedule 1 to the Data Protection Act 2018.
+**What about cookies?**
+We and/or our service providers use cookies and similar technologies only where necessary to enable the Service to function correctly. These include session cookies and necessary technical cookies used for login, security, load-balancing, stability, remembering essential settings and operating the Service. Our website's functionality will be limited if you configure your browser to reject cookies.
+We do not use cookies or similar technologies for analytics, advertising, cross-site tracking or behavioural profiling. The cookies and similar technologies we use are limited to those necessary to operate the Service securely and reliably.
 **How long do we keep it?**
+We will delete your personal information when you choose to delete your account, using the [remove account page](https://fabswingers.com/my/remove). Your account including all personal information is permanently deleted and will not be recoverable from around the time you delete it. We may permanently delete your account / personal information after a period of inactivity or in accordance with Terms and Conditions, e.g., if they are breached). We will in any case comply with legal timescale guidelines / requirements for deletion of personal information.
+We will delete your personal information when you choose to delete your account using the [remove account page](https://fabswingers.com/my/remove). When you delete your account, it is removed and we do not reinstate deleted accounts. We may permanently delete your account and personal information after a period of inactivity or in accordance with our Terms and Conditions, for example if they are breached. We will in any case comply with legal timescale guidelines and requirements for deletion of personal information.
+In limited cases, we may retain or preserve certain information where we are required by law, court order, law enforcement preservation request or other legally binding requirement to do so.
+We do not build or retain a general biometric identification database, and we do not retain a full biometric template, faceprint or biometric identifier for the purpose of generally identifying you after the relevant check is complete. Where our verification and age assurance checks generate biometric data for a limited purpose, such as detecting whether the same person is attempting to verify more than once or to abuse those processes, we retain only the limited information needed for that purpose, under Article 9(2)(g) UK GDPR and our Appropriate Policy Document, for no more than 30 days, after which it is deleted.
+If you provide consent documents or age ID relating to another person shown in your Content, we retain those documents only for as long as reasonably necessary to check compliance with our Terms and Conditions, deal with reports or complaints, protect Users or others, comply with law enforcement or regulatory requests, or establish, exercise or defend legal claims.
 **To whom do we send or make available your personal information?**
+To other users of our service, if you enter personal information into your public profile or otherwise include it in a post, comment or other public action on our service. Please note:
+To other Users of our Service, if you enter personal information into your public profile or otherwise include it in a post, comment or other public action on our Service. Please note the following.
+Viewing another user's profile will be notified to the profile-owner unless you have opted out on your privacy page.
+Viewing another User's profile will be notified to the profile-owner unless you have opted out on your privacy page.
+Public actions by you (for example, but not limited to, entering a chat room, making a forum post, updating your status, uploading a public photo, broadcasting via cams or participating in a chat) may be listed in newsfeeds of other users or shown elsewhere on the site. If you hide your profile from your privacy page, your activities won't be shown in newsfeeds but may still be visible in the place where you took the action or elsewhere on the site (for example, but not limited to, your forum posts).
+Public actions by you, for example entering a chat room, making a forum post, updating your status, uploading a public photo, broadcasting via cams or participating in a chat, may be listed in newsfeeds of other Users or shown elsewhere on the site. If you hide your profile from your privacy page, your activities will not be shown in newsfeeds but may still be visible in the place where you took the action or elsewhere on the site, for example your forum posts.
+Please be aware that cams are viewable by any registered user of the site. Although we show the EYE icon to indicate which users in your own room are viewing your cam, you should be aware that other users who have left the room could still be viewing your cam from elsewhere on the site without you knowing. (This still applies if you opt to block your cam from site supporters who have view-only access to full rooms.) Please also be aware that other users may maliciously record your cam session e.g., on their smartphones or with software that records streaming that is available on the internet, which is outside of our control. Please remember the GOLDEN RULE (see above) and don't ever show on cam anything you would be uncomfortable with if it became public.
+Please be aware that cams are viewable by any registered User of the site. Although we show the EYE icon to indicate which Users in your own room are viewing your cam, you should be aware that other Users who have left the room could still be viewing your cam from elsewhere on the site without you knowing. This still applies if you opt to block your cam from site supporters who have view-only access to full rooms. Please also be aware that other Users may maliciously record your cam session, for example on their smartphones or with software that records streaming that is available on the internet, which is outside of our control. Please remember the GOLDEN RULE above and do not ever show on cam anything you would be uncomfortable with if it became public.
 Certain of your activities are displayed on your profile page including date joined and date last logged in. This information can be removed only by hiding your profile.
+NB Your "special category data" (e.g., details you have entered on your profile about your race / racial origin, sex life and/or sexual orientation) will be included in the profile information displayed to other users.
+Your "special category data", for example details you have entered on your profile about your race or racial origin, sex life and/or sexual orientation, will be included in the profile information displayed to other Users.
+If you opt in to "Who Is Near", we only show approximate distances e.g., "within quarter of a mile", "within 3 miles". "very near, 2 minute walk", etc. Your exact location is never shown or displayed.
+If you opt in to "Who Is Near", we only show approximate distances, for example "within quarter of a mile", "within 3 miles" or "very near, 2 minute walk". Your exact location is never shown or displayed.
+To our moderators.
+To our moderators and authorised staff, where needed to operate, moderate, protect, verify, secure or enforce the Service.
 To regulators, the police or other law enforcement or official authorities on request or to protect us or others, or if a criminal act may have been committed or to help deal with fraud or abuse, or where required by law.
+To the service providers who carry out automated processing and verification on our behalf, as described in "Automated processing, verification and facial analysis" above.
+To service providers who host, support, secure, maintain, operate, analyse or improve our Service on our behalf.
+To payment providers, card processors, fraud-prevention providers and chargeback or dispute handlers.
 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.
+To buyers (actual or potential) so far as reasonably necessary in the case of a proposed or completed sale or merger or business combination involving all or the relevant part of our business.
+To buyers, actual or potential, so far as reasonably necessary in the case of a proposed or completed sale, merger or business combination involving all or the relevant part of our business.
+You can find options to control privacy aspects of the site [on your privacy page](https://fabswingers.com/my/privacy). However, you should be aware that, although we make reasonable efforts to ensure that the privacy controls work as expected, we cannot guarantee this and because of bugs, errors or omissions or the actions of malicious users or external actors, they may not work as anticipated.
+You can find options to control privacy aspects of the site [on your privacy page](https://fabswingers.com/my/privacy). However, you should be aware that, although we make reasonable efforts to ensure that the privacy controls work as expected, we cannot guarantee this and, because of bugs, errors, omissions or the actions of malicious Users or external actors, they may not work as anticipated.
 **What happens to your payment details?**
+These go direct to our payment partners. We do not receive such information. To ensure your details are not being used without consent, our payment partners may send your personal information to relevant third parties including credit reference and fraud prevention agencies.
+Payment-card details go directly to our payment partners. We do not receive or store your full card details.
+We may receive and store limited payment-related information, such as payment status, transaction reference, payment provider, payment method type, amount, date, refund status, chargeback or dispute status, and any 18+ verification flag or other verification result provided through the payment process.
+To help prevent fraud, abuse, unauthorised payments and misuse of our Service, our payment partners may process your personal information and may share information with relevant third parties, including credit reference agencies, fraud prevention agencies, banks, card schemes, payment processors, regulators or law enforcement where appropriate. Please check the relevant payment partner's privacy policy for more information about how they process your data.
 **Do we send your information outside the UK?**
+No.
+We store and process personal information primarily in the United Kingdom and the European Economic Area. Some service providers acting on our behalf may also process limited personal information outside the UK and EEA, including in the United States and other locations where our hosting, security, content delivery, anti-abuse, verification, communications or technical service providers operate.
+In particular, the automated image analysis described in "Automated processing, verification and facial analysis" above may be carried out on a service provider's infrastructure located outside the UK. This processing is carried out only to perform the relevant verification or age-assurance check. We do not use it to build a general biometric identification database. Where biometric data is generated for the limited purpose of detecting or preventing abuse of these processes, such as the same person attempting to verify more than once, it is retained for no more than 30 days under Article 9(2)(g) UK GDPR and our Appropriate Policy Document.
+Wherever we or our service providers transfer personal information outside the UK, we take steps designed to ensure it is protected by appropriate safeguards required by UK data protection law. Depending on the destination and provider, this may include relying on UK adequacy regulations or, where the destination is not covered by adequacy, on standard contractual protections such as the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any additional measures needed. Where a provider is certified under the UK extension to the EU-US Data Privacy Framework, we may also rely on that framework, but we maintain alternative safeguards so that transfers remain protected if that framework ceases to be available.
 **What rights do you have?**
+If the legal requirements are met: To ask us for access to your personal information (which we will respond to by sending you a link to our secure self serve GDPR portal), to rectify it if there are mistakes, to delete or restrict its use in certain circumstances or to "data portability" or to withdraw any consent you've given. Remember, you can remove all the personal information in your account at any time by deleting it via the [remove account page](https://fabswingers.com/my/remove).
+If the legal requirements are met, you have the right to ask us for access to your personal information, which we will respond to by sending you a link to our secure self-serve GDPR portal.
+You may also have the right to object to use of your personal information in certain circumstances.
+You may also have the right to ask us to rectify your personal information if there are mistakes, to delete it or restrict its use in certain circumstances, to data portability, or to withdraw any consent you have given where we rely on consent. Withdrawal of consent does not affect processing carried out before withdrawal or processing based on another lawful basis.
+Remember, you can remove all the personal information in your account at any time by deleting it via the [remove account page](https://fabswingers.com/my/remove).
+You may also have the right to object to use of your personal information in certain circumstances, including the facial analysis described above.
+Where a verification or moderation decision significantly affects you, you may ask us to provide information about the decision, make representations, obtain human intervention and contest the decision, as described in "Automated processing, verification and facial analysis" above.
 If you have a complaint about how we are dealing with your personal information, please contact us via the contact form. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you can complain to the Information Commissioner's Office (ICO).
+For more information about your rights, visit the ICO's website: [www.ico.org.uk](https://www.ico.org.uk/).
+For more information about your rights, visit the ICO's website: [ico.org.uk](https://ico.org.uk/).
 **Changing your settings**
+You can change your privacy settings at any time with the [privacy page](https://fabswingers.com/my/privacy) if you are logged in. You can change your [email notifications here](https://fabswingers.com/my/email_notifications).
+You can change your privacy settings at any time with the [privacy page](https://fabswingers.com/my/privacy) if you are logged in.
+You can change your [email notifications here](https://fabswingers.com/my/email_notifications).
 You can remove yourself and all your data from the site at any time using the [remove page](https://fabswingers.com/my/remove).