Privacy Policy

The data controller responsible for personal data processed through Sweetly is Tinklab Ltd, a company registered in England and Wales under company number 16468278, with its registered office at First Floor Office, 3 Hornton Place, London, W8 4LZ, United Kingdom.

We collect different categories of personal data depending on whether you use Sweetly as a Member or a Performer, and depending on the features you use.

• Account data: username, email address, password (stored in hashed form), date of birth, country, and language and theme preferences.
• Identity and age verification data (Performers only): copies of government-issued identification documents, self-portrait or liveness-check images used to match the Performer to their documents, and any supporting information submitted during the application process.
• Payment data: billing name, billing address, and transaction records; full card numbers are collected and processed directly by our third-party payment processors and are not stored on our servers.
• Content data: photos, videos, live-stream recordings, profile information, and messages that you upload, publish, or exchange on the Platform.
• Usage and device data: log data, IP address, browser type, device identifiers, pages viewed, features used, approximate location derived from IP address, and similar technical data collected automatically, including through cookies as described in our Cookie Policy.
• Support communications: the content of messages you send to our support team, including any attachments.
• Financial and tax data (Performers only): payout account details and, where required by law, tax identification information.

We rely on the following legal bases, as applicable, to process personal data:

• Performance of a contract: to create and administer your Account, process Token purchases, Fan Club subscriptions, PPV unlocks, and Payouts, and provide the features you request.
• Legal obligation: to verify age and identity, to comply with record-keeping obligations such as 18 U.S.C. §2257 and equivalent requirements, anti-money-laundering and tax rules, and to respond to lawful requests from authorities.
• Legitimate interests: to secure the Platform against fraud and abuse, to moderate Content, to improve our services, and to enforce our Terms of Service, provided these interests are not overridden by your rights.
• Consent: for optional cookies and similar technologies (see our Cookie Policy) and for optional marketing communications, which you may withdraw at any time.

• To operate your Account and authenticate your access to the Platform.
• To verify that Performers are at least 18 years old and are who they claim to be, before approving their Account and before publication of Content.
• To process payments, Token purchases, tips, Fan Club subscriptions, PPV unlocks, advertising banner purchases, and Performer Payouts.
• To display Content to the appropriate audience according to each Performer's free, Fan Club, and PPV settings.
• To enable live streaming, chat, and private sessions between Members and Performers.
• To detect, investigate, and prevent fraud, chargebacks, underage use, and violations of our Terms of Service, including reviewing content reports.
• To provide customer support and respond to your requests.
• To comply with applicable law, including responding to lawful requests by public authorities.
• To send you service communications and, where you have consented, marketing communications, which you can opt out of at any time.

We do not sell personal data. We share personal data with the following categories of recipients, each acting under contractual obligations of confidentiality and security:

• Payment processors, to process Token purchases, subscription billing, and Performer Payouts.
• Identity and age verification providers, to confirm a Performer's age and identity before Account approval.
• Hosting, content delivery network (CDN), and cloud storage providers, to store and deliver Content and platform data.
• Analytics providers, to help us understand usage of the Platform and improve it, as described in our Cookie Policy.
• Professional advisers, auditors, and insurers, where necessary for our legitimate business purposes.
• Law enforcement, regulators, or other third parties, where required by law, in particular in relation to suspected child sexual abuse material, which we report to the National Center for Missing & Exploited Children (NCMEC) and/or other competent authorities as required.
• A successor entity, in the event of a merger, acquisition, reorganization, or sale of assets, subject to equivalent protection of personal data.

Public-facing profile information and published Content are, by design, visible to other users according to the access level (free, Fan Club, or PPV) chosen by the Performer. Identity verification documents are never published, displayed, or made visible to any other user of the Platform.

Sweetly and its service providers may process personal data outside the United Kingdom or the European Economic Area, including in the United States, where certain hosting, payment, and verification providers are located. Where we transfer personal data internationally, we rely on appropriate safeguards recognized under UK GDPR and, where applicable, EU GDPR, such as the UK International Data Transfer Addendum or the European Commission's Standard Contractual Clauses, or transfers to jurisdictions covered by an applicable adequacy decision.

We retain personal data only for as long as necessary for the purposes described in this Policy, taking into account legal, accounting, and regulatory requirements.

• Account data is retained for as long as your Account remains active, and for a limited period afterward to handle disputes, enforce our Terms, and meet legal obligations.
• Identity and age verification documents are retained for the period required by applicable record-keeping laws, including 18 U.S.C. §2257 and equivalent requirements in the jurisdictions where we operate, and are subject to strict access controls; they are deleted or anonymized once no longer required by law.
• Transaction and payment records are retained for the period required by applicable tax, accounting, and anti-money-laundering laws.
• Content is retained for as long as the Performer keeps it published, plus any period necessary to comply with legal holds, investigate reports, or enforce our Terms; a Performer may request deletion of Content they control, subject to these exceptions.
• Support communications are retained for a reasonable period to resolve your request and for quality and legal purposes thereafter.

Subject to applicable law and any exceptions or limitations, you have the following rights regarding your personal data:

• Access: to obtain confirmation of whether we process your personal data, and a copy of it.
• Rectification: to have inaccurate or incomplete personal data corrected.
• Erasure: to request deletion of your personal data, subject to our legal retention obligations, in particular for identity verification and financial records.
• Restriction: to request that we limit the processing of your personal data in certain circumstances.
• Portability: to receive certain personal data you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible.
• Objection: to object to processing based on our legitimate interests, or to direct marketing at any time.
• Withdrawal of consent: to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
• Complaint: to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk, or with your local supervisory authority if you are located in the European Economic Area.

To exercise any of these rights, contact us using the details in Section 13. We may need to verify your identity before acting on your request, and we will respond within the timeframe required by applicable law.

Sweetly is intended exclusively for adults aged 18 and over. We do not knowingly collect personal data from, or permit registration by, anyone under 18. Age is verified at registration and, for Performers, through the identity verification process described in Section 2. If we become aware that we have collected personal data from a person under 18, we will take immediate steps to delete that data and terminate the associated Account.

If you believe a minor has registered an Account or appears in Content on the Platform, please report it immediately through the in-platform reporting tool using the "underage person involved" category, or contact us directly using the details in Section 13. Such reports are treated as a critical priority and are handled in accordance with our zero-tolerance policy for content involving minors.

We implement technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encryption in transit, access controls restricting who within our organization can view identity verification documents, and regular security reviews of our systems and third-party providers.

No system is completely secure, and we cannot guarantee absolute security. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO and, where required by law, affected individuals, without undue delay and in accordance with applicable data protection law.

Sweetly uses cookies and similar technologies for authentication and preferences and, only with your consent, for analytics through Google Analytics. We do not use advertising or profiling cookies. The full list, with the purpose, duration and controller of each cookie, and how you can manage your preferences are set out in our Cookie Policy, which forms part of this Privacy Policy by reference.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the revised policy on the Platform with an updated "Last updated" date, and, for material changes, provide additional notice such as an in-platform notification or an email to registered users.

For any question about this Privacy Policy or to exercise your data protection rights, contact our privacy team through the in-platform help center, by email at [email protected], or in writing to Tinklab Ltd, First Floor Office, 3 Hornton Place, London, W8 4LZ, United Kingdom, for the attention of the Data Protection contact.