1. We ask that you read this privacy policy (Privacy Policy) carefully as it contains important information on who we are, how and why we collect, store, use and share personal information via on EscortNeed, all associated sub-domains, web-apps and mobile apps (Platform), your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

2. Defined terms not defined in this Privacy Policy are defined in the Terms of Use.

WHO WE ARE

3. This Platform is operated by Japan, trading as EscortNeed. We are a software services provider.

4. We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA). We are responsible as `controller` of that personal information for the purposes of those laws.

OUR PLATFORM

5. This Privacy Policy relates to your use of our Platform.

6. Throughout our Platform, EscortNeed or Providers may link to websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party platforms, please consult their privacy policies as appropriate.

OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION

7. We collect personal information about you when you access our Platform, register an account with us, contact us, send us feedback, purchase services via our Platform, post material to our Platform and/or complete customer surveys or participate in promotions via our Platform.

8. We collect this personal information from you either directly, such as when you register with us, contact us or purchase services via our Platform or indirectly, such as your browsing activity while you are using our Platform.

9. The personal information we collect about you depends on the particular activities carried out through our Platform. This information includes:

• your name, location and contact details;
• date of birth;
• bank account and payment details;
• details of any feedback you give us by phone, email, post or via social media;
• information about the Platform Services we provide to you; and
• your account details, such as username, login details.

10. We use this personal information to:

• create and manage your account with us;
• verify your identity and that you are over 18 years old if you are a Punter and 21 years old if you are a Provider;
• provide Platform Services to you;
• Manage your Subscription(s) in the case of Providers;
• customise our Platform and its content to your particular preferences;
• notify you of any changes to our Platform or to our services that may affect you; and
• improve the Platform Services.

11. This Platform is not intended for use by anyone under the age of 18 under any circumstances and we do not knowingly collect or use personal information relating to children.

OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

12. When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

13. The legal bases that we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose;
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations); and
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third-party (unless there is a good reason to protect your personal information, which overrides our legitimate interests).

FURTHER INFORMATION – THE PERSONAL INFORMATION WE COLLECT, WHEN AND HOW WE UWHO WE SHARE YOUR PERSONAL INFORMATION WITHSE IT

14. We routinely share Punters browsing habits with our software analytics providers in order to optimise the performance of the Platform and fully enable its functionality.

15. We routinely share Providers:

• payment details with our payment providers in order to process payments for Subscriptions; and
• content and page interaction statistics with our software analytics providers in order to analyse the performance of the Provider Listings and share the resulting information with Providers to help improve the popularity of their Listings.

16. Some of those third-party recipients may be based outside the EEA. For further information including on how we safeguard your personal data when this occurs, see `Transfer of your information out of the EEA`.

17. We will share personal information with law enforcement or other authorities if required by applicable law.

18. We will not share your personal information with any other third-party or for any other purposes.

WHETHER INFORMATION HAS TO BE PROVIDED BY YOU, AND IF SO WHY

19. We require Providers to provide:

• Verification of your age, identity and your contact details in order to register for an account with us; and
• your payment information to enable us to facilitate payments on your behalf and process refunds.

20. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

THE IMPACT OF OUR USE OF YOUR PERSONAL INFORMATION

21. Our use of your personal information will allow us to provide services to you and will result in your data being shared with our third-party service providers who will then be permitted to contact you for marketing purposes should you provide your consent.

TRANSFER OF YOUR INFORMATION OUT OF THE EEA

22. We may transfer your personal information to the following which are located outside the European Economic Area (EEA).

23. Under data protection law, we can only transfer your personal data to a country or international organisation outside the EEA where:

• the EU GDPR applies and the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an `adequacy decision`);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law.

24. These are explained below.

ADEQUACY DECISION

25. We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the `EEA`);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

26. The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

27. Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

TRANSFERS WITH APPROPRIATE SAFEGUARDS

28. Where there is no adequacy decision, we may transfer your personal data to another country we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

29. The safeguards will usually include using legally-approved standard data protection contract clauses. In relation to transfers to our overseas offices or other companies within our group, the safeguards may instead include legally binding rules and policies which have been approved by the European Commission.

TRANSFERS UNDER AN EXCEPTION

30. In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country where an exception applies under relevant data protection law, for example if you have explicitly consented to the proposed transfer after having been informed of the possible risks or the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request.

31. We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

32. If you would like further information please contact us. We will not otherwise transfer your personal data outside of the area comprising the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

COOKIES AND OTHER TRACKING TECHNOLOGIES

33. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our platform. We use cookies on our platform. These help us recognise you and your device and store some information about your preferences or past actions.

34. For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

MARKETING

35. We would like to send you information about our services, competitions and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email, telephone, text message (SMS) or automated call.

36. We would also like to share your information with selected third-parties so that they may send you information about their products and/or services, depending on what you agree with us.

37. We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you make a booking with one of our providers via the platform.

38. If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

• contacting us;
• using the `unsubscribe` link in emails or `STOP` number in texts; or
• updating your marketing preferences in your account settings.

39. It may take up to 7 days for this to take place.

40. For more information on your rights in relation to marketing, see `Your rights` below.

YOUR RIGHTS

41. Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address;
• require us to correct any mistakes in your information which we hold;
• require the erasure of personal information concerning you in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• object at any time to processing of personal information concerning you for direct marketing;
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• object in certain other situations to our continued processing of your personal information; and
• otherwise restrict our processing of your personal information in certain circumstances.

42. For further information on each of those rights, including the circumstances in which they apply, see Rights of the Individual published by the European Data Protection Supervisor.

43. If you would like to exercise any of those rights, please:

• email, call or write to;
• let us have enough information to identify you (e.g. account number, user name, registration details);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates including any account or reference numbers, if you have them.

KEEPING YOUR PERSONAL INFORMATION SECURE

44. We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

45. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

CHANGES TO THIS PRIVACY POLICY

56. This Privacy Policy was published and last updated on 12th October 2021.

57. We may change this Privacy Policy from time to time and when we do, we will inform you the next time you access the Platform.

HOW TO CONTACT US

58. Please contact us if you have any questions about this privacy notice or the information, we hold about you or if you would like this Privacy Policy in another format (for example: audio, large print, braille).