Privacy Policy

Last modified 22nd February 2023

Piper Outsourcing Ltd with its registered office at Unit 10, Brooklands Court, Kettering Park Way, Kettering, United Kingdom, NN15 6FD, is the Agent acting on behalf of the website.

Platform(s)/Website(s)

www.formationdata.co.uk Collectively, all parties and websites identified above are hereafter referred to as “WAT”, “our” or “we”.

Introduction

At WA we regard your privacy as important. We may collect information about you via our Platform/websites. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Platform/websites (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.

1. Important Information and Who We Are

Purpose of this privacy policy This privacy policy aims to give you information on how we collect and process your personal data through your use of this Platform/website, including any data you may provide through this Platform/website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This Platform/website is not intended for use by anyone under the age of 18 years and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and policies and is not intended to override them.

Controller WA is the controller and responsible for your personal data (collectively referred to as “WA”, “we”, “us” or “our” in this privacy policy). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below. support@threepipers.com

Changes to the privacy policy and your duty to inform us of changes We keep our privacy policy under regular review and this policy is subject to change. You should refer to this policy at least once a year to remain updated. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, contact details, photo verification images and photo identification should you choose to ID verify your profile.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card details and (or) third party payment provider email addresses.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses, bio and photos/videos.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data: within the GDPR these include; details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), or any information about criminal offences, alleged or convicted.

If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion, or survey; or
• give us feedback or contact us.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
• analytics providers such as Google;
• advertising networks; and
• search information providers.
• data from ISP (Internet Service Provider)
• contact, financial and transaction data from providers of technical, payment, and delivery services.
• identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Third-Party Processors We use the following categories of third-parties to process your data and deliver services for the purposes shown. All of these processors have access to some of your Personal data as appropriate for the delivery of the purpose specified.

Third-Party Processors

We use the following categories of third-parties to process your data and deliver services for the purposes shown. All of these processors have access to some of your Personal data as appropriate for the delivery of the purpose specified.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data: We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by email at support@threepipers.com Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please click here to see our cookie policy for more information.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by email at support@threepipers.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table 'Purposes for which we will use your personal data' above.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We may share or transfer your personal data outside of the European Economic Area (EEA). Please contact us if you want further information on the specific mechanism used by us if/when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention - How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Below is a list of individual rights under GDPR:

• Right to Erasure: Every individual has the right to be forgotten upon request. The data controller must remove your Personal data from its systems and request the same of any third-party systems of that controller.

If you wish to exercise any of the rights set out above, please contact us in the following ways:

• Revoke your consent: In accordance with the GDPR, to revoke consent for processing of your Personal data send an email with the word “Revoke” in the subject field to support@threepipers.com.
• Data Subject Access Request (DSAR): In accordance with the GDPR, you may exercise any of the 8 rights shown above by emailing a DSAR to support@threepipers.com.

No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may also need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Under the GDPR we are obliged to respond to any DSAR within 30-days. It could take us longer than a month if your request is particularly complex or you have made a number of requests. In such cases, we will notify you and keep you updated.

What is Lawful Basis?

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

For any questions relating to your personal data, or to submit a Data Subject Access Request ‘DSAR’, please contact our Data Protection Department:

In full, The company’s agent WAT is the controller of the Platform(s)/website(s) and all information collected and/or provided via the Platform(s)website(s), not the directors, legal officer(s), managers, advisers, officers, consultants or employees. WAT is governed under/by the jurisdiction of England and Wales.

Where this policy says ‘user’, that means anyone who uses the Platform(s)/website(s) and includes but is not limited to members, non-members, you, users, escorts, entertainers, and advertisers. The headings are for ease of use and do not necessarily mean they are incorporating the whole subject matter of the section they are representing/heading.

By entering the website, you are agreeing that you have read the whole of the privacy policy and all relevant documentation and have not relied in full or in part on the headings. By entering our Platform(s)/website(s), you are saying that you have read and agree and will abide by the privacy policy, terms and conditions, Services Agreement(s) and any other documentation that is referred to or referenced or makes up your agreement in full or in part. If you don’t agree with any part of this privacy policy, Services Agreement(s) or our terms and conditions or any other document that forms or could form or might form part of our agreement with you, or if you don’t agree in part or full with this or any other document that has been referenced by our privacy policy, or our terms and conditions, then please do not enter our platform(s)/website(s), as we do not grant you permission to access or to enter our Platform(s)/site(s) and please do not submit any personal data.

Main Reasons for Data Collection

• To provide quality content.
• To provide the services you sign up for, such as subscriptions.
• To carry out marketing analysis, we track site behavior.
• When permitted by law.
• When we have your permission, send you communications.
• To enable us to show advertisements on our site.

Policy Application

It applies only to information collected from our Platform(s)/website(s) unless otherwise stated. It applies:

• When you visit and/or use the Platform(s)/website(s).
• When you complete our registration form.
• When you upload or post material.
• When you report a problem to us.
• When you voluntarily take part in surveys and/or competitions.
• When you contact us by any means which includes email or post.

Privacy Exclusions

This privacy policy does not cover any information we may receive from or about you through other channels. This includes any third parties that may be accessible via our Platform(s)/website(s) via links or advertisements. Our privacy policy only applies to our platform(s)/website(s), so unless expressly stated and a link is supplied directly to our privacy policy, we do not have any control over third party platform(s)website(s)/advertisement(s)link(s) and therefore not responsible for their privacy policies/statements. Clicking on third party Platform(s)/ websites/advertisements/links or enabling those connections, may allow third parties to collect or share data information about you.

Privacy Policy Contents

This privacy policy explains:

• Who this privacy policy is directed at?
• An overview of what data we collect.
• How we will use your data.
• How we collect your data.
• How to contact the appropriate authorities.

Target Audience

It is directed to all users of the Platform, who must be aged eighteen (18) years and over, or must have reached the age of majority in their respective jurisdiction/own country (whichever is the greater). It is strictly forbidden for anyone who does not meet these criteria to access, view or check out, in any way shape or form the contents of the Platform(s)/website(s). We do not knowingly seek, collect, gather or ask for any personal information from persons who have not attained the age of eighteen (18) as they are not allowed to access our Platform(s)/website(s). Please contact us immediately at support@threepipers.com putting ‘urgent minor accessing website’ in the subject bar, if you think your child has accessed our website and we will immediately terminate their account.

Data Collection

The data we collect from non-members will not include identifiable personal data but will include all other details (please see below). The data we collect from members and all other users are as follows:

• Personal data: which includes name, username or similar identification, passwords, email, mobile and/or phone, contact details, members accounts and all details and uploads within, members photo, all methods that you use to communicate with us and your preference of communication with us and third-parties and how we communicate with you written and/or verbal.
• Usage data which includes: Browser information, URL’s, locations such as country, regions, city, towns. This shows us how you use our Platform, products and services you searched and viewed, how long it took for the Platform to respond, what was viewed and how many times it was viewed, any errors occurring, links clicked on. Information received from cookies and other similar technology and your choice of preferred contact method.

Types of Data Collected

Our platform collects various types of data to better serve our users:

• Technical Data: This encompasses device information, IP address, browser types and versions, browser language, plug-in types and versions, location and time zone settings, network details for mobile phones, operating system details, platform specifics, and the technology used on all devices accessing our Platform.
• Marketing Data: This includes your preferences for receiving marketing communications from us and third-party advertisers.
• User Submitted Data: Information you've provided via surveys, competitions, or for specific purposes, and all consents/preferences you've granted.
• User Data: Covers interests, feedback, survey responses, texts, messages, blogs, emails, comments, images, preferences, and all content you've uploaded or produced on the Platform.
• Unidentifiable Data: Aggregate data related to specific groups or demographics. This can encompass average age, profession, etc. This data doesn't directly identify you.

Purpose of Data Collection

How do we utilize the data we collect from you?

• To process orders and manage your account.
• Send you emails, newsletters, and offers on products/services you might be interested in. Note: We only send these if you've opted in.
• Use data in collaboration with credit reference agencies to prevent fraudulent purchases.
• To troubleshoot and enhance our platform, ensuring a user-friendly experience.
• Analyze the popularity and trends of different categories on our platform.
• Meet legal obligations and protect our rights and those of third parties.
• Ensure compliance with the law, especially concerning fraud, intellectual property rights, and more.
• Protect against illegal activities that we might need to investigate or litigate.
• Manage system upgrades, risk management, governance, and ensure overall security.
• Identify any breaches of our Terms and Conditions, Privacy Policy, or other related documentation.

Utilizing the Data

The data we collect helps us to:

• Offer multilingual support to our users.
• Improve, maintain, monitor, and protect our data, services, communications, and solutions.
• Provide and enhance our services to users.
• Develop new services or upgrade existing ones.
• Defend against and prevent threats like cyber-attacks, breaches in network security, and viruses.
• Support marketing initiatives.
• Monitor and assess the performance, quality, and efficiency of our services and platform.
• Provide customer support, manage accounts, and communicate important notifications.
• Process actions where we have your explicit consent.

Data Collection Methods

We gather data in several ways, including:

• When you visit or use our platform.
• Upon registration or when you update your profile.
• When you upload content or post on our platform.
• Participation in surveys, competitions, or promotions.
• Reporting issues or contacting us through various communication methods.

Marketing

Our marketing initiatives aim to enhance your experience on our platform by offering content relevant to your interests. We only send marketing materials when you grant us permission. If you wish to opt out, simply email us at support@threepipers.com. Note that communications from our advertisers are separate and not under our jurisdiction.

Your Data Protection Rights

It's imperative that you're aware of your rights concerning data protection:

• Right to Access: Request copies of your personal data from our company. We may charge a small fee for this service.
• Right to Rectification: Request correction of inaccurate data or completion of incomplete data.
• Right to Erasure: Under certain conditions, you can ask for your data to be deleted. This applies if we no longer need your data, if you withdraw consent, or if your data wasn't used lawfully.

Your Data Protection Rights

We ensure you are informed about your data protection rights. These include:

• Right to Restrict: Under specific conditions, you can ask us to limit how we process your data. This may impact some platform functionalities.
• Right to Object: You can object to us processing your data for purposes like public tasks, legitimate interests, direct marketing, and research.
• Right to Data Portability: In certain situations, you can request data transfer to another entity or yourself. Their privacy policy will apply once the data is transferred.

Cookies

For information regarding how we utilize cookies, please click here to view our cookie policy.

Profile, Data, and Uploads

Member profiles remain private, but escorts can view them upon contact. Users control and bear the responsibility for all uploaded information.

Security of Your Data

Our platform employs a 256-bit SSL security system. Only specific personnel can access your data for specific business purposes. Beware of links leading you outside our platform; these may have different security measures and policies.

Data Retention Duration

Your personal data stays with us only as long as necessary. Once its purpose is served, we delete the data. In some cases, legal or technical reasons may require us to retain it longer.

Privacy Policies of Other Websites

Our platform might link to other third-party websites. Remember, our privacy policy only covers our platform. Ensure you read the policies of other websites before interacting with them.

Do We Share Your Information?

We respect your privacy and will only share your information under specific conditions:

• Legal obligations or regulatory requirements.
• Provide services under this privacy policy.
• Under suspicions of potential legal violations.
• Engagements with professional or legal consultants.
• Business restructuring, sale, or mergers.
• With your explicit written consent.

We may also share non-identifiable data for business analyses, improvements, and collaborations with third parties.

Changes to Our Privacy Policy

Our privacy policy might be updated periodically. Users should review it regularly to remain informed. Continued use of our platform indicates agreement with any changes.

How to Contact Us and Time Limits

For inquiries, concerns, or requests related to this privacy policy, contact us at support@threepieprs.com. Mark your communication with 'data protection enquiry'. We strive to respond within a month, though complex matters might take up to three months.

How to Contact the Appropriate Authorities

If you're unsatisfied with our response to your complaints, you can contact your country's data protection authority. For the UK, this is the Information Commissioner's Office (ICO). They can be reached at ico.org.uk or by phone at 00303 123 1113.