Privacy Policy

Discretion Management Limited ("Discretion"), a company incorporated and registered in England and Wales, United Kingdom, is the controller of personal data processed through the Platform. You can contact us about any privacy matter, including to exercise your rights, at info@discretion.vip.

You provide to us

• Account data: email, username, password (stored hashed), account type.
• Profile data: display name, location, photographs, descriptions, services, and rates.
• Communications: messages, booking requests, reviews, and support enquiries.
• Payment data: processed by our payment provider; we store transaction records, not full card numbers.

Collected automatically

• Usage and device data: pages viewed, actions taken, IP address, browser, and device type.
• Cookies and similar technologies, as described in our Cookie Policy.

From third parties

• Identity and age verification results from our provider: a pass or fail result and verified attributes such as age confirmation. We do not store copies of identity documents.
• Content moderation signals from our screening provider.

We process personal data to provide and secure the Platform, to verify age and identity, to process payments and payouts, to moderate content and keep users safe, to communicate with you, to comply with legal obligations, and to improve the service.

Lawful bases

• Performance of a contract: to provide the services you sign up for.
• Legal obligation: age verification, record keeping, and reporting of unlawful content.
• Legitimate interests: safety, fraud prevention, and service improvement, balanced against your rights.
• Consent: for optional marketing, which you can withdraw at any time.

Given the nature of the Platform, some data may reveal information about your sex life or sexual orientation. We process such data only where necessary to provide the service you have requested, with your explicit consent where required, and with heightened security.

We do not sell your personal data. We share data only with service providers acting on our instructions, and with authorities where legally required, as set out in the sub-processors section below.

We use carefully selected service providers (sub-processors) to operate the Platform. Each is bound by data protection terms and may only process data on our instructions. Categories include:

• Payment processing.
• Identity and age verification.
• Content moderation and safety screening.
• Cloud hosting, database, and file storage.
• Email and notification delivery.
• Privacy conscious analytics.
• Security, fraud prevention, and bot protection.

A current list of sub-processors is available on request from info@discretion.vip.

We maintain records of our processing activities. In summary:

• Account and profile data: to operate accounts and profiles; basis contract; retained for the life of the account and a short period after.
• Verification outcomes: to confirm age and identity; basis legal obligation and contract; retained as required by law.
• Content and consent records: to publish content lawfully; basis legal obligation and contract; retained for the period required by law.
• Transactions: to process payments and meet accounting duties; basis contract and legal obligation; retained for 6 to 7 years.
• Safety and moderation records: to keep users safe and meet legal duties; basis legal obligation and legitimate interests; retained as required by law.

We use automated tools for content moderation, age assurance, and fraud prevention. These do not produce legal or similarly significant effects on you without human review. You may contact us to request a human review of an automated decision that affects you.

We retain personal data only as long as necessary for the purposes set out here or as required by law. Specific periods are in our Data Retention Policy. Certain records, such as age verification outcomes and content consent records, are retained for extended periods to meet legal and safety obligations, including after account closure.

Subject to conditions, you have the right to access, rectify, erase, restrict, and port your data, to object to processing, and to withdraw consent. If you are in Australia, you have equivalent rights under the Australian Privacy Principles. You can exercise most rights in your account settings or by contacting info@discretion.vip. We respond within statutory timeframes.

You may export or delete your data from your account. Deletion does not remove records we are legally required to keep.

We use technical and organisational measures including encryption in transit and at rest, hashed passwords, access controls, optional two factor authentication, automated moderation, and regular reviews. No system is completely secure, and we cannot guarantee absolute security.

We maintain procedures to detect, investigate, and respond to personal data breaches, and will notify the relevant supervisory authority and affected individuals where required by law.

Where data is transferred outside the UK or your country of residence, we rely on appropriate safeguards such as adequacy decisions or standard contractual clauses, and take steps to ensure an equivalent level of protection.

The Platform is strictly for adults aged 18 and over. We do not knowingly process data of anyone under 18 and will delete such data if discovered. See our Age Verification Policy and Child Protection and Anti-Exploitation Policy.

We use cookies as described in our Cookie Policy.

We may update this policy and will notify users of material changes. The effective date above shows the latest revision.

If you have concerns, contact info@discretion.vip. You also have the right to complain to the Information Commissioner's Office (ico.org.uk) in the UK, or to the Office of the Australian Information Commissioner (oaic.gov.au) in Australia.