1. INTRODUCTION AND DATA CONTROLLER
1.1 Who We Are
D&P DIGITAL LTD (Company Registration Number: 16435116), a company incorporated under the laws of England and Wales, is the data controller responsible for your personal data when you use the Luxelist.vip platform ("Platform", "Service", "Website").
1.2 Contact Information
Data Controller: D&P DIGITAL LTD
Data Protection Officer: privacy@luxelist.vip
General Contact: admin@luxelist.vip
1.3 Platform Purpose
Luxelist.vip is a connection platform designed for adult individuals seeking companionship services. We facilitate connections between service providers and clients but do not arrange meetings, process payments for services between users, or oversee user interactions.
1.4 Commitment to Privacy
We are committed to protecting your privacy and complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), EU General Data Protection Regulation (GDPR), and the Data Protection Act 2018.
2. INFORMATION WE COLLECT
2.1 Information You Provide Directly
Account Registration Data:
- Full legal name
- Email address
- Date of birth
- Profile information and descriptions
- Profile photographs and media
- Location and geographic preferences
- Payment information (processed by third-party providers)
Verification Information:
- Government-issued identification documents
- Age verification data from third-party providers
- Additional verification documents as required by jurisdiction
Communication Data:
- Messages sent through our platform
- Customer support communications
- Feedback and reviews
- User reports and complaints
Profile Content:
- Service descriptions and pricing information
- Availability and scheduling information
- Profile preferences and settings
- User-generated content and media
2.2 Information We Collect Automatically
Technical Data:
- IP address and device identifiers
- Browser type and version
- Operating system and device type
- Pages visited and time spent on Platform
- Referring and exit pages
- Search queries and interactions
Usage Analytics:
- Platform feature usage
- Click-through rates and engagement metrics
- Profile views and interactions
- Search patterns and preferences
Location Data:
- General geographic location (city/region level)
- GPS coordinates (only with explicit consent)
- Location preferences for service areas
2.3 Information from Third Parties
Age Verification Providers:
- Identity verification results
- Age confirmation data
- Fraud prevention information
Payment Processors:
- Transaction confirmation
- Payment method verification
- Billing information (we do not store full payment details)
Social Media Integration:
- Profile information from connected social accounts (optional)
- Contact lists (only with explicit consent)
3. LEGAL BASIS FOR PROCESSING
We process your personal data under the following legal bases:
3.1 Contractual Necessity
- Account creation and management
- Providing Platform services
- Processing subscription payments
- Customer support and communications
3.2 Legitimate Interests
- Platform security and fraud prevention
- Service improvement and analytics
- Marketing communications (with opt-out options)
- Legal compliance and safety monitoring
3.3 Legal Obligation
- Age verification requirements
- Anti-money laundering compliance
- Tax reporting obligations
- Court orders and legal requests
3.4 Consent
- GPS location tracking
- Marketing communications
- Cookies and tracking technologies
- Third-party integrations
3.5 Vital Interests
- Emergency situations requiring user safety measures
- Prevention of serious harm
4. HOW WE USE YOUR INFORMATION
4.1 Core Platform Services
- Creating and managing user accounts
- Facilitating connections between users
- Displaying profiles and enabling searches
- Processing subscription payments
- Providing customer support
4.2 Safety and Security
- Age verification and identity confirmation
- Fraud detection and prevention
- Content moderation and community safety
- Investigating violations of Terms of Service
- Protecting against unauthorized access
4.3 Service Improvement
- Analyzing Platform usage patterns
- Developing new features and services
- Personalizing user experience
- Conducting research and analytics
- Testing and optimization
4.4 Communications
- Sending service-related notifications
- Marketing communications (with consent)
- Platform updates and announcements
- Customer support responses
- Legal and compliance notices
4.5 Legal and Compliance
- Complying with applicable laws and regulations
- Responding to legal requests and court orders
- Protecting our legal rights and interests
- Maintaining records for regulatory purposes
5. INFORMATION SHARING AND DISCLOSURE
5.1 We Do Not Sell Personal Data
We do not sell, rent, or trade your personal data to third parties for marketing purposes.
5.2 Service Providers and Partners
Age Verification Partners:
- Identity verification services
- Age confirmation providers
- Fraud prevention services
Payment Processors:
- Subscription billing services
- Payment gateway providers
- Financial compliance services
Technical Service Providers:
- Cloud hosting and storage services
- Email and communication platforms
- Analytics and monitoring tools
- Customer support platforms
All third-party providers are bound by strict data protection agreements.
5.3 Legal Requirements
We may disclose personal data when required by law:
- Court orders and legal processes
- Law enforcement requests
- Regulatory investigations
- Protection of rights and safety
- Compliance with legal obligations
5.4 Business Transfers
In the event of merger, acquisition, or sale of assets, personal data may be transferred as part of the transaction, subject to equivalent privacy protections.
5.5 Public Profile Information
Information you choose to make public in your profile is visible to other Platform users and may be indexed by search engines.
6. INTERNATIONAL DATA TRANSFERS
6.1 Transfer Mechanisms
When we transfer personal data outside the UK/EEA, we ensure adequate protection through:
- European Commission adequacy decisions
- Standard Contractual Clauses (SCCs)
- Binding Corporate Rules where applicable
- Explicit consent for specific transfers
6.2 Third Country Transfers
Some of our service providers may be located in countries outside the UK/EEA. We ensure these transfers comply with UK GDPR and EU GDPR requirements through appropriate safeguards.
6.3 Transfer Impact Assessments
We regularly review and assess the impact of international data transfers to ensure continued protection of your personal data.
7. DATA RETENTION
7.1 General Retention Principles
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws.
7.2 Specific Retention Periods
Active Accounts:
- Account data: Retained while account is active
- Profile information: Retained while account is active
- Messages: Retained for 2 years or until account deletion
- Transaction records: Retained for 7 years (legal requirement)
Inactive Accounts:
- Account deletion after 24 months of inactivity
- Data anonymization where possible
- Legal compliance data retained as required
Verification Data:
- Age verification records: Retained for 7 years minimum
- Identity documents: Securely deleted after verification unless legally required
Technical Data:
- Log files: Retained for 12 months
- Analytics data: Retained for 24 months (anonymized)
- Security incident data: Retained for 3 years
7.3 Deletion Procedures
When retention periods expire, we securely delete or anonymize personal data using industry-standard methods.
8. YOUR RIGHTS UNDER GDPR
8.1 Right of Access
You have the right to request:
- Confirmation of whether we process your personal data
- Access to your personal data
- Information about processing purposes and legal basis
- Details of retention periods and sharing arrangements
8.2 Right to Rectification
You can request correction of:
- Inaccurate personal data
- Incomplete personal data
- Outdated information
8.3 Right to Erasure (Right to be Forgotten)
You can request deletion of your personal data when:
- No longer necessary for original purposes
- You withdraw consent (where consent is the legal basis)
- You object to processing (and no overriding legitimate grounds exist)
- Data has been unlawfully processed
- Required for compliance with legal obligations
8.4 Right to Restrict Processing
You can request restriction of processing when:
- You contest the accuracy of personal data
- Processing is unlawful but you prefer restriction over erasure
- We no longer need the data but you need it for legal claims
- You have objected to processing pending verification of legitimate grounds
8.5 Right to Data Portability
You have the right to:
- Receive your personal data in a structured, commonly used format
- Transmit data to another controller where technically feasible
- Request direct transmission between controllers where possible
8.6 Right to Object
You can object to processing based on:
- Legitimate interests (including profiling)
- Direct marketing (absolute right)
- Scientific/historical research or statistical purposes
8.7 Rights Related to Automated Decision-Making
You have rights regarding:
- Automated decision-making and profiling
- Explanation of automated decisions
- Human intervention in automated processes
- Challenging automated decisions
8.8 Right to Withdraw Consent
Where processing is based on consent, you can withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
9. EXERCISING YOUR RIGHTS
9.1 How to Submit Requests
Primary Method: Email privacy@luxelist.vip
Alternative: Contact admin@luxelist.vip
Account Settings: Some rights can be exercised through your account dashboard
9.2 Verification Requirements
To protect your privacy, we may require verification of your identity before processing requests. This may include:
- Account login verification
- Identity document confirmation
- Security question responses
9.3 Response Timeframes
- Standard requests: Within 1 month of receipt
- Complex requests: Up to 3 months (with notification)
- Urgent requests: Expedited processing where possible
9.4 Fees
- Most requests are processed free of charge
- Excessive or repetitive requests may incur reasonable fees
- Fees will be communicated before processing
9.5 Refusal of Requests
We may refuse requests that are:
- Manifestly unfounded or excessive
- Likely to adversely affect others' rights
- Prohibited by applicable laws
- Technically impossible to fulfill
10. DATA SECURITY
10.1 Security Measures
We implement comprehensive security measures including:
Technical Safeguards:
- End-to-end encryption for sensitive data
- Secure data transmission (TLS/SSL)
- Regular security audits and penetration testing
- Multi-factor authentication for administrative access
- Automated threat detection and monitoring
Organizational Safeguards:
- Staff training on data protection
- Access controls and authorization procedures
- Data protection impact assessments
- Incident response procedures
- Regular security policy reviews
10.2 Data Breach Procedures
In the event of a data breach:
- Assessment and containment within 72 hours
- Notification to supervisory authorities where required
- Communication to affected individuals when necessary
- Investigation and remediation measures
- Prevention of future incidents
10.3 Third-Party Security
All third-party service providers must demonstrate adequate security measures and comply with our security requirements.
11. COOKIES AND TRACKING TECHNOLOGIES
11.1 Types of Cookies We Use
Essential Cookies:
- Account authentication
- Security measures
- Platform functionality
- User preferences
Analytics Cookies:
- Usage statistics
- Performance monitoring
- Feature effectiveness
- User behavior analysis
Marketing Cookies (Optional):
- Advertising personalization
- Campaign effectiveness
- Cross-platform tracking
11.2 Cookie Management
You can control cookies through:
- Browser settings and preferences
- Our cookie consent management platform
- Opt-out tools for specific tracking technologies
- Account privacy settings
11.3 Do Not Track
We respect Do Not Track signals and similar privacy preferences where technically feasible.
12. CHILDREN'S PRIVACY
12.1 Age Restrictions
Our Platform is strictly for adults aged 18 and over. We do not knowingly collect personal data from minors.
12.2 Verification Procedures
We implement robust age verification to prevent underage access:
- Mandatory age verification for all users
- Document verification requirements
- Ongoing monitoring and compliance
12.3 Parental Rights
If you believe a minor has provided personal data to us, please contact privacy@luxelist.vip immediately for investigation and removal.
13. CHANGES TO THIS PRIVACY POLICY
13.1 Notification of Changes
We may update this Privacy Policy to reflect:
- Changes in applicable laws
- New Platform features
- Improved privacy practices
- Regulatory requirements
13.2 Communication Methods
Material changes will be communicated through:
- Email notification to registered users
- Prominent notice on the Platform
- Updated effective date
- Summary of key changes
13.3 Continued Use
Continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.
14. SUPERVISORY AUTHORITY CONTACT
14.1 UK Users
Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
14.2 EU Users
Contact your local data protection authority. A complete list is available at: edpb.europa.eu
14.3 Right to Lodge Complaints
You have the right to lodge a complaint with supervisory authorities regarding our processing of your personal data.
15. CONTACT INFORMATION
15.1 Data Protection Inquiries
Primary Contact: privacy@luxelist.vip
Data Protection Officer: privacy@luxelist.vip
General Inquiries: admin@luxelist.vip
15.2 Response Expectations
- Privacy inquiries: Within 48 hours
- Data subject requests: Within 1 month
- Urgent matters: Expedited response
- Complex issues: Regular status updates
15.3 Alternative Contact Methods
If you cannot reach us via email, please contact admin@luxelist.vip with "PRIVACY INQUIRY" in the subject line.
16. SPECIFIC PROVISIONS FOR ADULT PLATFORMS
16.1 Sensitive Data Processing
Given the nature of our Platform, we process data that may be considered sensitive:
- Information about adult services
- Location data for service provision
- Communication between consenting adults
- Profile information of intimate nature
Legal Basis: Processing is based on explicit consent and legitimate interests for Platform operation.
16.2 Enhanced Privacy Protections
We implement additional protections for sensitive data:
- Enhanced encryption for intimate communications
- Strict access controls for sensitive information
- Regular audits of data handling procedures
- Specialized staff training on sensitive data
16.3 Discretion and Confidentiality
We understand the importance of discretion and maintain strict confidentiality regarding:
- User identities and activities
- Service arrangements between users
- Personal communications and interactions
- Location and scheduling information
16.4 Law Enforcement Cooperation
We cooperate with law enforcement only when legally required and will:
- Verify the legitimacy of requests
- Limit disclosure to specifically requested information
- Notify users when legally permitted
- Challenge overbroad or improper requests
This Privacy Policy is designed to provide comprehensive information about our data processing practices while ensuring full compliance with applicable data protection laws. For specific questions about your privacy rights or our practices, please contact our Data Protection Officer.