Legal
Privacy policy
1. Who we are
This website, hornyswingers.co.uk, is operated by Copious Limited, a company registered in England and Wales with company number 11437826, whose registered address is Unit 2A, Crown Business Park, Rochdale, OL11 2PU. Copious Limited is the data controller for the personal data described in this policy and is registered with the Information Commissioner's Office (ICO) under registration number ZA453238.
You can contact us about this policy or your data by email at hello@hornyswingers.co.uk, through our contact form, or by post at the address above.
2. What we collect and why
| Data | Why we collect it |
|---|---|
| First name and last name | To address our newsletter and messages to you and to keep an accurate record of your consent. |
| Email address | To send the newsletter and event news you have asked for. |
| Mobile number | To send event news and reminders by text message, which you have asked for. |
| Comment (optional) | To understand what you are interested in. It is never shared with third parties. |
| Consent records | The date and time you subscribed, the exact wording you agreed to and its version number, and whether you opted in to third-party offers, so that we can prove and honour your choices. |
| Country of connection | A two-letter country code supplied by our hosting provider at the moment you submit the form, used for spam prevention and basic statistics. We do not store your IP address. |
| Contact form and venue submissions | Your name, email address and message, or the venue details you submit, so that we can respond and maintain the venue directory. |
3. Special category data
Because our newsletter is for adults interested in swinging, the fact that you have subscribed may reveal information about your sex life. Under the UK GDPR this is special category data, which deserves extra protection. We only process it with your explicit consent, given by ticking the consent box on our form, and we limit what we collect to what we need.
4. Our lawful basis
We rely on your consent under Article 6(1)(a) of the UK GDPR, and your explicit consent under Article 9(2)(a) for special category data. We send electronic marketing by email and text only with your consent, as required by the Privacy and Electronic Communications Regulations 2003 (PECR). For contact form messages and venue submissions we rely on our legitimate interests in responding to you and running the directory.
5. Sharing with third parties
We will only share your details with third parties for their own marketing if you tick the separate, optional box on our form that allows it. That box is unticked by default and you can subscribe to our newsletter without ticking it.
If you do opt in, we may share your name, email address and mobile number only, with carefully selected partners in these categories:
- adult lifestyle event organisers;
- lifestyle venues;
- travel and holiday companies;
- dating services;
- wellbeing brands.
We will never share or sell your comment, and we will never share the fact of any special category information beyond what is implied by your opt-in. Each partner becomes a separate data controller for the details we give it and must follow the law, including honouring requests to stop marketing. We will keep a record of which partners received your details and when, and will tell you on request. If you withdraw your third-party consent we will stop any further sharing and will ask partners who already hold your details to stop using them.
We also use service providers who process data on our behalf under contract, including our website and database host (Cloudflare) and, when we start sending, our email and text message providers. They may only use your data to provide their service to us. Some providers may process data outside the UK; where they do, we rely on UK adequacy regulations or appropriate safeguards such as the UK International Data Transfer Agreement or Addendum.
We may disclose data where the law requires it, for example to the police or a court.
6. How to withdraw consent or unsubscribe
- Use the unsubscribe link at the bottom of every email we send, or our unsubscribe page.
- Reply STOP to any text message we send.
- Email us at hello@hornyswingers.co.uk or use our contact form.
You can withdraw third-party sharing on its own and keep receiving our newsletter. Withdrawing consent does not affect anything we did lawfully before you withdrew it.
7. How long we keep your data
- Subscriber details are kept while you remain subscribed. When you unsubscribe we delete your name, mobile number and comment straight away and keep only your email address, the date you unsubscribed and your consent history on a suppression list, so that we never contact you again by mistake.
- If you subscribe but we do not send you anything for 24 months, we will delete your details.
- Contact form messages are kept for 12 months, then deleted.
- Venue submissions that are not published are deleted within 6 months.
8. Your rights
Under UK data protection law you have the right to:
- access the personal data we hold about you;
- rectification of anything inaccurate;
- erasure of your data;
- restrict or object to our processing;
- data portability;
- withdraw consent at any time.
To use any of these rights, contact us using the details above. We will respond within one month. We may need to confirm your identity first.
If you are unhappy with how we have handled your data, you have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113. We would appreciate the chance to put things right first.
9. Under 18s
This website and our newsletter are strictly for adults aged 18 or over. We do not knowingly collect data from anyone under 18. If we learn that we have, we will delete it.
10. Security
Your data is stored in an access-controlled database. Access is limited to authorised staff using a long, secret access key, and all connections to this site are encrypted.
11. Cookies
See our cookie note.
12. Changes
We will update this policy if our practices change and will tell subscribers about significant changes. We will never use your data in a new way that needs consent without asking you first.