This Privacy Policy describes how Briture Highland Media Ltd (Briture Highland Media Ltd, NaughtyBritain.com, “we”, “us” or “our”) collects, uses, discloses and protects your personal data when you visit or use our website NaughtyBritain.com (“the Website”) and related services (“the Service”).
Your privacy is important to us. We process personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and any other applicable data protection laws.
By accessing or using the Website and/or Service, you acknowledge that you have read and understood this Privacy Policy and our Terms & Conditions. If you do not agree with this Privacy Policy, you should not use the Website or the Service.
Who we are and how to contact us
We operate an adult fantasy chat service that allows users to exchange messages with fictional profiles and animators in a controlled online environment.
The party responsible for the processing of your personal data (the controller) is:
Briture Highland Media Ltd trading as NaughtyBritain.com
Office 7, Unit 3, 8 Bessell Lane
NG9 7BX, Stapelford, Nottingham
United Kingdom
CRN: 14783242
If you have questions, requests or concerns about this Privacy Policy or our data practices, you can contact our data protection officer (DPO) at: dpo@NaughtyBritain.com
For general support enquiries you can contact: :support_email
To whom does this Privacy Policy apply?
This Privacy Policy applies to:
- Visitors to the Website;
- Users who create an account and use the Service;
- Individuals who contact us by email, contact form or other electronic communication;
- Individuals who interact with our advertising and applications on third-party websites or services.
Some parts of the Website can be used without registering, but you must create an account to access the full functionality of the Service.
Important information about the Service
NaughtyBritain.com is an adult fantasy chat platform. When you use our chat service:
- You interact with fictional profiles and/or animators (human or ai operators);
- Profiles, conversations and personalities are curated and may be scripted or moderated;
- It is not possible to arrange physical meetings with profiles you interact with via the Service.
We make this explicit so that you understand the nature of the Service when deciding whether to share personal data with us.
Categories of personal data we collect
Depending on how you use the Website and Service, we may process the following categories of personal data:
Identification and contact data
- Email address
- Username
- Password
- Region/approximate location
- IP address and device identifiers
Profile and account data (optional)
- Gender, date of birth, age
- Sexual preferences and interests
- Body type, eye colour, hair colour, height
- Photos and other images you upload
- Self-descriptions, hobbies, personal characteristics
- Chat preferences and visibility settings
Usage and technical data
- Log-in dates and times
- Device type, operating system and browser
- IP address and general geographic location
- Pages visited, features used, clicks and interactions
- Messages and chat history within the Service
- Cookie identifiers and similar technologies
Transactional data
- Date, time and amount of purchases (credits, subscriptions)
- Type of product purchased
- Payment status and payment method (via third-party payment providers)
Customer service data
- Information you provide when you contact us (e.g. nature of your question, complaint or claim)
- Account information relevant to your request
Marketing and communications data
- Your email address and marketing preferences
- Email engagement data (e.g. opens, link clicks)
- Data used for profiling and personalised offers (where you have consented)
Some of the information you choose to add to your profile or share in chats may reveal special categories of personal data, such as information relating to sex life or sexual orientation. We only process such data where you voluntarily provide it and where you give explicit consent.
Purposes, legal bases and retention periods
Below we explain for what purposes we process your personal data, on what legal basis and for how long we generally retain the data. Where possible we summarise by “data stream”.
Registration and account creation
When you register for an account, we ask you for:
- Email address
- Username and password
- Gender
- Date of birth
- Region or approximate location
- Chat preferences
Purposes
- To create and manage your account;
- To verify your age (see section 8);
- To enable you to log in and use the Service;
- To tailor the Service to your preferences and region;
- To prevent fraud and abuse (e.g. IP/domain checks, fraud screening).
Legal basis
- Performance of a contract (Article 6(1)(b) UK GDPR) - to provide the Service to you;
- Compliance with legal obligations (Article 6(1)(c) UK GDPR) - e.g. age restrictions and financial regulations;
- Legitimate interests (Article 6(1)(f) UK GDPR) - e.g. fraud prevention and service security.
Retention
- For as long as your account is active;
- After deactivation or deletion of your account we generally retain core account data for up to 12 months, unless we are required by law to retain data longer (e.g. for tax or anti-fraud purposes).
Profile creation and management
Once your account is active, you can complete your profile and add optional information, including:
- Age, body type, appearance characteristics;
- Preferences, interests, sexual preferences;
- Photos and other media;
- Personal descriptions and hobbies.
Purposes
- To tailor the Service to your interests;
- To provide chat suggestions and matching;
- To display your profile to other users according to your visibility settings;
- To monitor the Service for illegal or unauthorised content and to enforce our Terms & Conditions.
Legal basis
- Consent (Article 6(1)(a) UK GDPR) - for optional profile fields;
- Explicit consent (Article 9(2)(a) UK GDPR) - for special categories of personal data (e.g. sex life or sexual orientation);
- Performance of a contract (Article 6(1)(b) UK GDPR) - to provide core profile and chat functionality;
- Legitimate interests (Article 6(1)(f) UK GDPR) - service integrity, moderation and protection of our users and platform.
Retention
- For as long as your account and profile remain active;
- After deleting your profile, we may retain profile-related data (including limited chat history) for up to 12 months for fraud detection, chargeback handling and legal purposes, unless a longer retention is legally required or permitted.
Use of the Service and chats
When you use the Service, we process:
- Username, profile details, preferences;
- Messages you send and receive in chats;
- IP address, device and technical data;
- Activity data (log-ins, features used, time on site).
Purposes
- To operate the chat platform and enable you to exchange messages with fictional profiles and animators;
- To personalise suggestions and content based on your settings and behaviour;
- To monitor for illegal or harmful conduct and enforce our Terms & Conditions;
- To improve the quality and performance of the Service, including training, quality control and optimisation.
Legal basis
- Performance of a contract (Article 6(1)(b) UK GDPR);
- Legitimate interests (Article 6(1)(f) UK GDPR) - to maintain a safe and high-quality platform, prevent abuse and improve the Service;
- Explicit consent for special categories of personal data (Article 9(2)(a) UK GDPR) where applicable.
Retention
- Chat and usage data are generally kept for the lifetime of your account;
- After account deletion we may retain limited logs and chat records for up to 12 months for security, fraud, chargebacks and legal purposes, unless a longer retention period is required by law.
Payments and transactions
To use certain parts of the Service you need a paid subscription or credits. Payments are handled via third-party payment service providers.
We process:
- Username and account reference;
- Date, time, amount and type of order;
- Payment status and transaction identifiers;
- Limited information received from payment providers (we do not store full card details on our own systems).
Purposes
- To process and complete payments;
- To send purchase confirmations and invoices;
- To manage chargebacks, refunds and disputes;
- To comply with tax and accounting obligations.
Legal basis
- Performance of a contract (Article 6(1)(b) UK GDPR);
- Compliance with legal obligations (Article 6(1)(c) UK GDPR) - tax, accounting and financial regulations;
- Legitimate interests (Article 6(1)(f) UK GDPR) - fraud prevention and dispute resolution.
Retention
- Transaction and billing data are generally retained for 7 years in line with tax and bookkeeping requirements.
Customer service and communications
If you contact us (e.g. by email or contact form), we process:
- Your contact details (e.g. email address, username);
- Content of your message (questions, complaints, claims);
- Relevant account and transaction information.
Purposes
- To handle your questions, requests and complaints;
- To investigate technical issues, payment problems or abuse reports;
- To improve our customer support.
Legal basis
- Performance of a contract (Article 6(1)(b) UK GDPR);
- Legitimate interests (Article 6(1)(f) UK GDPR) - efficient customer service and service improvement.
Retention
- Typically kept for up to 1 month after your request or complaint has been resolved, unless we need to retain records longer in connection with disputes, fraud investigations or legal obligations.
Marketing, emails and profiling
We may send you emails and other electronic messages regarding our services, promotions and updates.
Data processed
- Email address and username;
- Gender, region and preferences;
- Account activity and interaction with our emails (open and click rates);
- Behaviour on the Website where this is used for profiling (with consent).
Purposes
- To send service-related notifications (e.g. technical notices, security alerts, account information);
- To send marketing communications about our services, offers, campaigns and events;
- To personalise offers and recommendations (profiling) where you consent.
Legal basis
- Legitimate interests (Article 6(1)(f) UK GDPR) - direct marketing to our users;
- Consent (Article 6(1)(a) UK GDPR) - where required, including for certain profiling activities and cookies;
- You can unsubscribe from marketing emails at any time via the link provided in each email or by contacting us.
Retention
- We retain your email address for marketing purposes for as long as you are subscribed;
- After you opt-out, we keep a minimal record of your email address only to ensure you are not sent further marketing messages (suppression list).
Website analytics, cookies and remarketing
We use cookies and similar technologies on the Website for:
- Basic functionality (e.g. keeping you logged in, security);
- Analytics (e.g. understanding how the Website is used);
- Personalised content and advertising (remarketing).
Data processed
- IP address and general location;
- Device type, operating system, browser;
- Pages visited, actions taken, time and date of visits;
- Cookie identifiers and advertising identifiers.
Purposes
- To ensure the Website functions correctly and securely;
- To analyse and improve our Website and Service;
- To show relevant advertisements and offers on our Website and on third-party sites (with your consent).
Legal basis
- Legitimate interests (Article 6(1)(f) UK GDPR) - essential cookies and basic analytics;
- Consent (Article 6(1)(a) UK GDPR) - non-essential cookies, advanced analytics and remarketing.
Retention
- Cookie lifetimes vary; see our separate Cookie Policy for more details.
- Analytics and remarketing data are typically retained for up to 12 months, unless a different period is indicated in the Cookie Policy.
Security and fraud prevention
We may process all categories of personal data described in this Privacy Policy if necessary to:
- Secure our systems and platform;
- Detect and prevent fraudulent transactions and misuse;
- Investigate violations of our Terms & Conditions;
- Meet legal and regulatory requirements;
- Establish, exercise or defend legal claims.
Legal basis
- Legitimate interests (Article 6(1)(f) UK GDPR) - security and business interests;
- Compliance with legal obligations (Article 6(1)(c) UK GDPR) where applicable.
Retention
- Security logs and fraud-related records are kept as long as reasonably necessary for the purposes set out above and to comply with legal obligations.
Consent and withdrawal of consent
Where we rely on your consent (for example, for certain profile data, special categories of personal data, marketing and non-essential cookies), you have the right to withdraw your consent at any time.
You can do so by:
- Adjusting your profile and privacy settings in your account;
- Changing your cookie preferences via the Website (where available);
- Clicking the unsubscribe link in marketing emails; or
- Contacting us at dpo@NaughtyBritain.com or :support_email.
Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Confidentiality
Our employees and contractors who have access to personal data are subject to confidentiality obligations. They may only process your personal data in accordance with this Privacy Policy and our internal policies, except where disclosure is required by law or regulation.
Children’s privacy and age restriction (18+)
The Service is intended only for adults.
- You must be at least 18 years old, or older if the age of majority in your place of residence is higher, to register, create an account, or use the Service.
- We do not knowingly collect personal data from anyone under 18.
- If we become aware that we have collected personal data from a minor, we will take reasonable steps to delete such data and, where appropriate, close the account.
We may process your date of birth and related information to verify that you meet the minimum age requirements.
Sharing of personal data with third parties
We do not sell your personal data. We may share your personal data with third parties in the following situations:
Service providers (processors)
We use third-party service providers who process personal data on our behalf and under our instructions, such as:
- Hosting and cloud service providers;
- IT and security providers;
- Analytics providers;
- Payment service providers and anti-fraud tools;
- Customer service and moderation providers;
- Email and marketing tools.
These parties are bound by contracts that require them to process personal data only in accordance with our instructions and to implement appropriate security measures.
Independent controllers
In some cases, third parties process your personal data as independent controllers, for example:
- Payment service providers and banks (for processing payments and handling disputes);
- Legal and tax advisors, auditors or debt collection agencies;
- Potential buyers or successors in the event of a merger, acquisition, restructuring or sale of assets;
- Public authorities, regulators and law enforcement agencies where we are legally required to provide data or where this is necessary to protect our rights or the rights of others.
We encourage you to review the privacy notices of these third parties for more information about their data practices.
International data transfers
We may store and process your personal data on servers located in the UK, the European Economic Area (EEA) and other countries.
Where personal data are transferred to countries outside the UK or EEA that do not provide an adequate level of data protection, we will ensure that appropriate safeguards are in place, such as:
- Standard contractual clauses approved by the European Commission and/or UK authorities;
- Other appropriate technical and organisational measures.
You can contact us for more information about the safeguards used for international transfers.
Your rights under the UK GDPR
Under the UK GDPR, you have the following rights in relation to your personal data:
- Right of access - to obtain confirmation as to whether we process your personal data and to receive a copy of such data.
- Right to rectification - to have inaccurate or incomplete personal data corrected.
- Right to erasure (right to be forgotten) - to request deletion of your personal data in certain circumstances (e.g. when data are no longer necessary for the purposes for which they were collected or where you have withdrawn consent).
- Right to restriction of processing - to request limitation of the processing of your personal data in certain cases.
- Right to data portability - to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller where the processing is based on consent or contract and carried out by automated means.
- Right to object - to object to processing based on our legitimate interests, including profiling. We will stop such processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms or where processing is necessary for legal claims. You always have the right to object to processing for direct marketing purposes.
- Right to withdraw consent - where processing is based on your consent, you can withdraw this consent at any time.
- Right not to be subject to automated decision-making - you have rights in relation to decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.
You can exercise your rights by contacting us at dpo@NaughtyBritain.com. We will respond without undue delay and in any event within one month of receiving your request. This period may be extended by a further two months where necessary, taking into account the complexity and number of requests. If we extend the period, we will inform you accordingly.
If we decide not to act on your request, we will inform you of the reasons and of your right to lodge a complaint with the supervisory authority.
Complaints and supervisory authority
If you believe that we do not process your personal data in accordance with applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority.
In the United Kingdom, this is the:
Information Commissioner’s Office (ICO)
You can find contact details on the ICO website.
We would however appreciate the opportunity to address your concerns first, so we encourage you to contact us before approaching the ICO.
Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. These measures include, where appropriate:
- Encryption, firewalls and access controls;
- Hashing of passwords;
- Logical separation of systems and data;
- Regular security assessments.
Despite our efforts, no online service can be completely secure. You are responsible for keeping your login credentials confidential and for restricting access to your devices. Any activity carried out under your account is your responsibility.
Cookies
We use cookies and similar technologies on our Website. Some cookies are necessary for the Website to function; others are used for analytics, personalisation and advertising.
Details about the cookies we use, their purposes and how you can manage your cookie settings are described in our Cookie Policy, which forms part of this Privacy Policy by reference.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time, for example to reflect changes in our Service, laws or regulatory guidance.
- The most recent version will always be published on the Website;
- Where changes are material or significantly affect you, we will make reasonable efforts to inform you directly (for example by email or via the Website).
We encourage you to review this Privacy Policy regularly to stay informed about how we process your personal data.
