Privacy Policy

This Privacy Policy explains how Juliet Golf Bravo Group Limited, trading as AdultFolio ("AdultFolio", "we", "us" or "our"), collects, uses, stores and shares information about you when you use AdultFolio.

This policy applies to the AdultFolio website, services, features and functionality made available through adultfolio.com.

This Privacy Policy should be read alongside our Terms and Conditions and our applicable Community Guidelines and site rules.

Who we are

AdultFolio is operated by:

Juliet Golf Bravo Group Limited
Company number: 08293675
Registered office: 20-22 Wenlock Road, London, N1 7GU
Email: [email protected]

For the purposes of applicable UK data protection law, including the UK General Data Protection Regulation ("UK GDPR") and Data Protection Act 2018, we are the data controller in respect of the personal data described in this Privacy Policy unless stated otherwise.

Information we collect

Depending on how you use AdultFolio, we may collect information including:

• your name and display name;
• date of birth and age;
• gender and other personal or professional information that you choose to add to your profile;
• email address, telephone number and other contact information;
• town, city, postcode, approximate location and other location information that you provide;
• profile type, experience, interests, preferences, availability and working information;
• photographs, videos and other media that you upload;
• messages, comments, references, castings, calendar information and other content that you create or send;
• account preferences, saved members, saved searches, interactions and other account activity;
• membership, subscription and transaction information;
• information connected with reports, moderation, complaints, disputes and enforcement of our rules;
• age and identity verification information, including verification images, verification status and associated verification records where required;
• IP address;
• browser type and version;
• operating system and device information;
• dates and times of access, pages viewed, feature usage, security logs and other technical activity;
• information received from third-party services that you choose to use with AdultFolio, including Google. This may include your name, email address, profile image and a unique account identifier depending on the permissions that you grant.

Sensitive and special category information

AdultFolio is an adult modelling and creative networking platform. Some information that users choose to publish or provide may reveal or imply information that can be regarded as particularly sensitive under data protection law.

Depending on how you use the service, this could include information relating to sexual life, sexual orientation, health or other sensitive personal characteristics.

We do not require members to disclose more sensitive information than is necessary to use the relevant features of AdultFolio. Where special category personal data is processed, we do so only where an appropriate legal basis and condition under applicable data protection law applies.

You should carefully consider what sensitive information you choose to publish on your profile or otherwise make available to other users.

How we collect information

We collect information in several ways, including:

• information that you provide directly to us;
• information that you enter when registering or updating your account;
• information that you upload, send or publish through AdultFolio;
• information generated by your use of AdultFolio;
• information collected automatically from your browser or device;
• information supplied by services that you choose to connect to AdultFolio, including Google;
• information provided to us through moderation, verification, reporting or support processes.

Information you provide to us

We may collect personal information directly from you when, for example:

• you create an AdultFolio account;
• you complete or update your profile;
• you upload photographs, videos or other media;
• you send messages or communicate with other members;
• you create or respond to castings;
• you leave comments, references or other feedback;
• you use our calendar or availability features;
• you complete an age or identity verification process;
• you report content or another member;
• you contact support;
• you purchase or renew a paid membership;
• you choose to sign in using a third-party provider.

Information collected automatically

When you access AdultFolio, we may automatically collect information about your visit and use of the service.

This may include your IP address, browser and device information, date and time of access, pages viewed, interactions with content and technical information used for security, fraud prevention, moderation and service operation.

We may also use cookies and similar technologies. Further information is provided in the Cookies section below.

How we use your information

We may use your information for purposes including:

• creating and administering your AdultFolio account;
• authenticating you and keeping your account secure;
• confirming that users meet applicable age requirements;
• providing age and identity verification functionality;
• displaying and managing your profile and portfolio;
• providing networking, discovery and search functionality;
• enabling messaging and communication between members;
• providing casting and collaboration features;
• providing references and reputation features;
• providing calendars, availability and tour functionality;
• processing and administering memberships and purchases;
• providing customer support;
• sending transactional, service, security and account communications;
• sending marketing communications where permitted by law;
• personalising your experience;
• maintaining internal business records;
• measuring and analysing use of AdultFolio;
• improving our services and developing new features;
• protecting the safety, security and integrity of the AdultFolio community;
• detecting and preventing fraud, spam, abuse, impersonation and other harmful activity;
• screening and moderating uploaded content;
• investigating potentially prohibited, stolen or unauthorised content;
• investigating member reports, complaints and disputes;
• enforcing our Terms, Community Guidelines and other platform rules;
• complying with applicable legal and regulatory obligations.

Our legal bases for processing

Depending on the circumstances, we process personal data under one or more of the following legal bases:

• Contract: where processing is necessary to provide AdultFolio services that you have requested or to take steps at your request before entering into a contract.
• Legitimate interests: where processing is necessary for our legitimate interests or those of another party and those interests are not overridden by your rights and freedoms.
• Consent: where we ask for and receive your consent for a particular processing activity.
• Legal obligation: where processing is necessary for us to comply with law.

Where special category information is processed, we will also rely on an applicable condition permitted by UK data protection law.

Age and identity verification

Because AdultFolio provides access to adult content and adult-oriented services, we may require users to complete age or identity verification before accessing certain content or functionality.

Depending on the verification method used, we may process information such as your date of birth, verification photograph or selfie, identity information, verification result, date of verification and related security records.

This information is used for purposes including confirming eligibility to access AdultFolio, preventing fraudulent or duplicate verification, protecting users and complying with applicable legal or regulatory obligations.

Verification data is retained only for as long as reasonably necessary for the purposes for which it was collected or where retention is required for legal, security or compliance reasons.

Google Account and Google API data

AdultFolio allows users to sign in using their Google Account.

Google data we access

When you choose to sign in using Google, Google may provide AdultFolio with information associated with your Google Account depending on the permissions that you grant.

This may include:

• your Google Account email address;
• your name;
• your profile image;
• a unique Google account identifier.

How we use Google data

Google user data is used only for purposes including:

• authenticating you when you sign in;
• identifying or creating your AdultFolio account;
• associating your Google login with your AdultFolio account;
• maintaining account and service security.

AdultFolio does not use Google authentication to access your Gmail, Google Drive, Google Calendar or other Google services unless a separate feature clearly requests and receives your permission to do so.

Google data storage

We may retain information such as your Google account identifier and email address where necessary to associate your Google login with your AdultFolio account.

OAuth credentials or authentication tokens are stored only where required to provide the relevant functionality and are protected using appropriate technical and organisational safeguards.

Google data sharing

AdultFolio does not sell Google user data.

We do not use Google user data for advertising or marketing profiling purposes.

We do not share Google user data with third parties except where necessary to provide AdultFolio, where you have specifically requested or authorised the disclosure, where necessary to maintain security, or where disclosure is required by law.

Google data retention and deletion

Google-derived account information is retained only for as long as reasonably necessary to provide your AdultFolio account and authentication functionality, maintain security or comply with applicable legal obligations.

Where you delete your AdultFolio account, Google-derived information associated with that account will be deleted or anonymised in accordance with our normal account deletion and retention processes, except where particular information must be retained for legal or security purposes.

You can revoke AdultFolio's access to your Google Account at any time through Google Account permissions .

AdultFolio's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy , including the Limited Use requirements.

Content moderation and platform safety

Content uploaded to AdultFolio may be reviewed using a combination of human moderation and automated systems.

We may process uploaded media, account information and associated metadata for purposes including:

• checking compliance with our rules;
• detecting prohibited themes or material;
• detecting potentially unauthorised or stolen content;
• protecting members and the integrity of the platform;
• investigating reports and complaints.

Content may be temporarily restricted or referred for additional review while these processes take place.

Who we share information with

We use selected third-party providers to help operate AdultFolio. Information is shared only where reasonably necessary for the relevant service.

• Amazon Web Services (AWS) – infrastructure, hosting and storage, including images and videos.
• Stripe – payment processing.
• Verotel – payment processing.
• Mailgun – sending transactional and service email.
• Google – where you choose to use Google authentication.
• age or identity verification service providers, where used to provide verification services.
• other infrastructure, security, analytics or service providers where reasonably necessary to operate AdultFolio.

We may also disclose information:

• where required by law or valid legal process;
• where necessary to protect AdultFolio, our users or others;
• in connection with a merger, acquisition, restructuring or sale of part or all of the business;
• where you have specifically requested or authorised us to do so.

Information visible to other users

AdultFolio is a networking and portfolio platform. Certain information that you choose to publish may therefore be visible to other AdultFolio users or, depending on the relevant feature and your settings, visitors to AdultFolio.

This may include your display name, profile information, photographs, videos, portfolio content, working information, references and other content that you choose to publish.

Some content may be restricted based on membership, verification, age-verification or content-viewing settings.

You should not publish personal information that you do not want other people to see.

Messages and private communications

AdultFolio provides messaging and other communication features between members.

We may access, process or review communications where reasonably necessary to:

• provide the messaging service;
• investigate reports or complaints;
• detect fraud, spam, abuse or prohibited behaviour;
• enforce our Terms or Community Guidelines;
• protect users or comply with law.

Keeping your information secure

We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, access, alteration, disclosure or destruction.

Measures may include:

• account authentication and access controls;
• secure server infrastructure;
• restricted administrative access;
• security monitoring;
• procedures for responding to suspected data breaches.

No internet-based service can guarantee absolute security. You are responsible for protecting your account credentials.

If you believe your account or information has been compromised, contact: [email protected] .

Data retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.

This can include the time necessary to provide AdultFolio, maintain business and security records, resolve disputes, enforce agreements and comply with legal, accounting, tax or regulatory obligations.

Different categories of information may have different retention periods.

When information is no longer required, we will delete, anonymise or securely dispose of it where reasonably possible.

Deleted information may temporarily remain within backups until those backups are overwritten or deleted as part of our normal retention processes.

Your rights

Subject to applicable data protection law and the circumstances, you may have rights including:

• Right of access – the right to request information about personal data that we hold about you.
• Right to rectification – the right to ask us to correct inaccurate or incomplete information.
• Right to erasure – the right to request deletion of personal data in certain circumstances.
• Right to restriction – the right to ask us to restrict certain processing.
• Right to data portability – the right, in certain circumstances, to receive information in a structured and machine-readable format.
• Right to object – the right to object to certain processing, including some processing based on legitimate interests.
• Right to withdraw consent – where processing relies on consent, you may withdraw it at any time.

To exercise your rights or ask a privacy-related question, contact: [email protected] .

We may need to verify your identity before fulfilling certain requests.

Account deletion

You may request deletion of your AdultFolio account and associated personal information, subject to any information that we are required or permitted to retain for legal, security, fraud-prevention, dispute-resolution or regulatory purposes.

Some information may remain within backups for a limited period before those backups are overwritten.

Complaints

If you have concerns about how we handle your personal information, please contact us so that we can investigate.

You also have the right to make a complaint to the UK Information Commissioner's Office ("ICO").

Further information is available at ico.org.uk .

International transfers

Some providers that we use may process personal information outside the United Kingdom.

Where personal information is transferred internationally, we take appropriate steps intended to ensure that it receives protection consistent with applicable UK data protection law.

Links and third-party services

AdultFolio may contain links to websites or services operated by third parties.

We do not control those services and this Privacy Policy does not apply to information collected directly by those third parties.

You should review the privacy information provided by the relevant service before providing personal information to it.

Changes of business ownership or control

We may restructure, expand, sell or transfer all or part of our business.

Where relevant, personal information may be disclosed to prospective purchasers, professional advisers or other parties involved in such a transaction.

If ownership or control of AdultFolio changes, information may be transferred to the new owner or controlling party so that the service can continue to operate.

Cookies

AdultFolio uses cookies and similar technologies to operate the Website, authenticate users, remember preferences, protect account security and understand how the service is being used.

Cookies are small files stored by your browser or device.

Type	Purpose
Strictly necessary	Required for authentication, security, account access and core AdultFolio functionality.
Analytics / performance	Used to understand how AdultFolio is used and help us improve the service.
Functionality	Used to remember preferences and personalise your experience.
Advertising / targeting	Where used and permitted, these may help us measure or personalise advertising.

Cookies used by AdultFolio

Cookie	Type	Purpose
ID	Strictly necessary	Used to identify the appropriate account while using AdultFolio.
user_session	Strictly necessary	Used to maintain your session and support account security.
auth	Strictly necessary	Used for authentication and account security.
until	Strictly necessary	Used to determine when your login session expires.
split_test	Analytics / performance	Used to measure and analyse A/B tests.
WorkMode	Functionality	Used to remember your safe-content / nudity display preference.

Your browser may allow you to block or delete cookies. Blocking strictly necessary cookies may prevent parts of AdultFolio from functioning correctly.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to AdultFolio, our processing activities, legal requirements or operational practices.

The latest version will be published on this page and the "Last updated" date will be changed accordingly.

Where appropriate, we may also notify users of significant changes through AdultFolio or by email.

Contact us

Questions regarding this Privacy Policy, your personal information or your data protection rights can be sent to:

Juliet Golf Bravo Group Limited
Trading as AdultFolio
Email: [email protected]
Address: 20-22 Wenlock Road, London, N1 7GU