Privacy Policy

VelvetList Classified (the "Company", "we", "us", or "our") is the data controller responsible for your personal data collected through this website (the "Platform"). We are committed to protecting your privacy and handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

If you have any questions about this Privacy Policy or our data practices, you may contact our Data Protection Officer at development@adultcreative.com. Our registered address is: Oxford Street, London, United Kingdom.

This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and what rights you have in relation to your data. Please read this policy carefully alongside our Terms and Conditions.

Personal data you provide directly: When you register for an account, we collect your name, email address, and password. When you create a listing, we collect the content you provide, including descriptions, photographs, location information, and service details. When you contact us, we collect the content of your messages and any attachments. When you make a payment, your payment card details are processed directly by Stripe and are not stored on our servers; however, we do receive and store transaction reference numbers, amounts, and billing addresses.

Usage data collected automatically: When you access the Platform, we automatically collect certain technical data, including your IP address, browser type and version, operating system, device type, referring URL, pages visited, time spent on pages, click patterns, and the date and time of your visits. This data is collected through server logs and analytics tools to help us understand how Users interact with the Platform and to improve our services.

Cookie data: We use cookies and similar tracking technologies (such as local storage) to collect and store information about your preferences and browsing activity. For full details about the cookies we use, please see Section 9 (Cookie Policy) below.

Under Article 6 of the UK GDPR, we process your personal data on the following legal bases: (a) Contract performance -- processing that is necessary for the performance of our contract with you, including providing account functionality, processing listings, facilitating messaging between Users, and processing payments for subscriptions and tokens; (b) Legitimate interests -- processing that is necessary for our legitimate interests, including improving and securing the Platform, preventing fraud and abuse, analysing usage patterns, and sending service-related communications, provided that such interests are not overridden by your fundamental rights and freedoms.

(c) Consent -- where you have given us your explicit consent to process your data for a specific purpose, such as receiving marketing communications or enabling non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal; (d) Legal obligation -- processing that is necessary for compliance with a legal obligation to which we are subject, including responding to lawful requests from law enforcement authorities, complying with tax and accounting requirements, and fulfilling our obligations under applicable UK legislation.

We use the personal data we collect to: create and manage your account; publish and display your listings; facilitate communication between Users through our messaging system; process payments for subscriptions and token purchases; verify your identity through our verification programme; send you transactional emails such as account confirmations, password resets, and payment receipts; and provide customer support in response to your enquiries.

We also use your data to: monitor and enforce compliance with our Terms and Conditions; detect, prevent, and address fraud, abuse, security issues, and technical problems; analyse Platform usage to improve our services, features, and user experience; generate aggregated, anonymised statistics about Platform usage; and, where you have opted in, send you marketing communications about new features, promotions, or services that may be of interest to you.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects on you. If we ever intend to use your data for purposes materially different from those described in this policy, we will notify you and, where required, seek your consent before doing so.

We do not sell, rent, or trade your personal data to third parties for their marketing purposes. We may share your data with the following categories of recipients, solely to the extent necessary for the purposes described in this policy: (a) Stripe -- our payment processor, which handles all payment card transactions securely in accordance with PCI DSS standards; (b) Analytics providers -- such as Google Analytics, which help us understand Platform usage through aggregated and anonymised data; (c) Hosting and infrastructure providers -- who store and process data on our behalf under strict contractual data protection obligations.

We may also disclose your personal data: (a) to comply with any court order, legal obligation, or governmental request; (b) to enforce our Terms and Conditions and other agreements; (c) to protect the rights, property, or safety of the Company, our Users, or the public; or (d) in connection with a merger, acquisition, or sale of all or a portion of our assets, in which case you will be notified via email or a prominent notice on the Platform of any change in ownership or use of your personal data.

All third-party service providers are required to process your data in accordance with applicable data protection law and our written instructions. We conduct due diligence on all processors and enter into appropriate data processing agreements that include obligations regarding confidentiality, security, and the handling of personal data.

Your personal data is primarily stored and processed within the United Kingdom and the European Economic Area (EEA). However, some of our third-party service providers may process data in countries outside the UK and EEA. Where we transfer personal data to a country that has not been deemed to provide an adequate level of data protection by the UK government, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the Information Commissioner's Office (ICO) or reliance on the recipient's participation in a recognised certification framework.

You may request further information about the safeguards we have put in place for international data transfers by contacting our Data Protection Officer at the email address provided in Section 1 above.

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. Account data is retained for the duration of your active account and for a period of twelve (12) months following account deletion to comply with legal obligations and to resolve any disputes. Listing data is retained for six (6) months after a listing is removed or expires. Transaction records are retained for seven (7) years in accordance with UK tax and accounting requirements.

Messages are retained for the duration of your account and deleted within thirty (30) days of account deletion. Server logs containing IP addresses and usage data are retained for a maximum of ninety (90) days. When personal data is no longer required, it is securely deleted or anonymised so that it can no longer be associated with you.

Under the UK GDPR, you have the following rights in relation to your personal data: (a) Right of access -- you have the right to request a copy of the personal data we hold about you and to receive information about how it is processed; (b) Right to rectification -- you have the right to request that we correct any inaccurate or incomplete personal data; (c) Right to erasure -- you have the right to request that we delete your personal data where there is no compelling reason for its continued processing; (d) Right to restriction -- you have the right to request that we restrict the processing of your personal data in certain circumstances.

(e) Right to data portability -- you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller; (f) Right to object -- you have the right to object to processing based on legitimate interests or for direct marketing purposes; (g) Right to withdraw consent -- where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at development@adultcreative.com. We will respond to your request within one (1) month, as required by law. In certain circumstances, we may extend this period by up to two (2) additional months, in which case we will inform you of the extension and the reasons for it. There is generally no charge for exercising your rights, although we may charge a reasonable fee for manifestly unfounded or excessive requests.

Essential cookies: These cookies are strictly necessary for the operation of the Platform. They include session cookies that maintain your login state, CSRF protection tokens that ensure form submission security, and preference cookies that store your selected theme or language. These cookies cannot be disabled as the Platform cannot function properly without them.

Analytics cookies: We use analytics cookies (such as those provided by Google Analytics) to collect anonymised information about how Users interact with the Platform, including pages visited, time on site, and navigation paths. This data helps us improve the Platform's performance and user experience. Analytics cookies are only placed with your consent. Functional cookies: These cookies enable enhanced functionality such as remembering your recently viewed listings and personalising your browsing experience. They may be set by us or by third-party providers whose services we use.

You can manage your cookie preferences at any time through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling essential cookies may prevent you from using certain features of the Platform. For more information about cookies and how to manage them, visit www.allaboutcookies.org.

The Platform is intended solely for individuals aged eighteen (18) years and over. We do not knowingly collect, store, or process personal data from anyone under the age of eighteen. If we become aware that we have inadvertently collected personal data from a child under eighteen, we will take immediate steps to delete that data from our systems and terminate the associated account.

If you believe that we may have collected personal data from a person under the age of eighteen, please contact us immediately at development@adultcreative.com so that we can investigate and take appropriate action. We cooperate fully with law enforcement and child protection authorities in relation to any concerns regarding minors.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. These measures include: encryption of data in transit using TLS/SSL; secure password hashing using industry-standard algorithms; regular security audits and vulnerability assessments; access controls that restrict access to personal data to authorised personnel on a need-to-know basis; and regular backups to prevent data loss.

While we strive to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your data. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account. If you suspect any unauthorised access to your account, please contact us immediately.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the features of the Platform. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or through a prominent notice on the Platform.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Your continued use of the Platform after any changes to this policy constitutes your acceptance of the updated terms. If you do not agree with any changes, you should stop using the Platform and contact us to request the deletion of your account and personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal data, please contact our Data Protection Officer using the following details:

Email: development@adultcreative.com

Address: Oxford Street, London, United Kingdom

Contact page: https://velvetlist-classified.apww.dev/contact

We aim to respond to all data protection enquiries within two (2) business days. For formal data subject access requests, we will respond within the statutory period of one (1) month.

If you are not satisfied with how we handle your personal data or your data subject rights request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection. We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113
Website: https://ico.org.uk