Privacy Policy (Part 1)

Xxtra is a social network for sex-positive people, where users can express their true sexual selves, connect with and date like-minded and open-minded people, get tickets for sex-positive adult events and join chat groups as a safe and fun space to share with the sex-positive community.

Xxtra Limited (“Xxtra”, “we”, “us”, “our”) is the operator of the Xxtra [iOS and Android] mobile application (“App”) and website at https://xxtra.co.uk (“Site(s)”) (collectively, our “Platform”) and provides the Xxtra services available through our Platform. In this Privacy Notice, we refer to our Platform and the Xxtra services collectively as our “Services”.

The Xxtra iOS and Android mobile application (“App”) and website at https://xxtra.co.uk (“Website”) are provided to you by Xxtra Ltd (“Xxtra”, “us”, “we” or “our”). Our registered office is at 54 Hexham Street, Towcester, Northamptonshire, NN12 6UD and our registered number is xxxxxxxxx.

For the purposes of UK and EU data protection laws, we are the data controller responsible for your personal data.

This Privacy Notice (“Privacy Notice”) sets out how we process your personal data in connection with our Services. We are committed to protecting the privacy of all users of our Services and we aim to provides a safe and secure environment for your personal data.

This Privacy Notice is intended to assist you in making informed decisions when using our Services and should be read in conjunction with our Cookie Notice. Please take a moment to read and understand these documents. We recommend that you pay particular attention to the sections that explain Your rights as a data subject and how you can exercise those rights.

Please note that your access to and use of our Services, including any secure area of our Platform, is also subject at all times to our Terms of Use.

This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services. This includes, for example, where you follow links to third-party websites over which we have no control, or you purchase goods or services from those third parties.

If you purchase event tickets through our Platform, our Ticket Terms will also apply to you. These terms apply to your use of the ticket sale functionality we make available to you on our Platform, but they do not apply to the event itself. All events advertised on our Platform are organised by third parties (not Xxtra). We only act as agent for the event organiser in making tickets available for sale and we are not responsible for such events. Our Platform allows event organisers to connect with our community and sell tickets to those who are interested in attending their events. When you purchase an event ticket you are purchasing the ticket from the third-party event organiser (not Xxtra) and you will be required to agree to the terms and conditions of the relevant third-party as a condition of making the ticket purchase.

We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the “last updated” date at the bottom of this page.

If you have any questions about this Privacy Notice or want to exercise Your rights as a data subject, you can contact us using the following methods:

4.1 Email - Send us an email at: support@ehaviour.co.uk

4.2 Post - Write to us at: ehaviour Ltd, 54 Hexham Street, Towcester, Nortamptonshire, NN12 6UD

In providing our Services, we may collect and process different types of personal data about you for different processing purposes. When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. The types of personal data we collect depends on who you are and how you use our Services. It will include the following:

• Identity Data First name.
• Contact Data Email address; telephone number; billing and/or delivery address.
• Registration Data Account username; password; first name; date of birth; gender; country; nationality; location; any other personal data that you may provide when you register an account with us.
• Verification Data Your image/photograph, telephone number and any other personal data that we may request from you that you provide in connection with the verification of your account.
• Profile Data Personal data provided by you for your membership profile, including: your image/photograph; description of yourself; description of your body; sexual preferences and interests; profession; relationship status.
• Message Data Any personal data about you contained in messages sent and received by you and other Xxtra users within our Platform.
• Transaction Data Details about purchases you have made from us, including details of any subscriptions and ticket purchases, and payments made in respect of those purchases.
• Financial Data Bank account details; partial payment card details.
• Observed Data Data that is observed about your use of our Platform or interaction with our emails and/or data that we infer through your use of our Platform. This data may include details of when your current or previous sessions started; the referrer URL (web page that you were on when you clicked a link that sent you to our Site); information about the pages of our Site that you have visited and Services that you have purchased or shown an interest in.
• Technical Data IP address; browser type and operating system; general geolocation derived from your IP address, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
• Recruitment Data Date of birth; gender; country; nationality; CVS; work experience; dietary requirements; any other personal data you may provide in advance of/during your supply of services to us.
• Communications Data Marketing communication preferences; service communication preferences.

Our Meetup group is a great way to connect with other Xxtra enthusiasts in your area. You'll have the opportunity to learn from others, share your own knowledge and experiences, and make new friends.

Our Meetup group is a great way to connect with other Xxtra enthusiasts in your area. You'll have the opportunity to learn from others, share your own knowledge and experiences, and make new friends.

Our Meetup group is a great way to connect with other Xxtra enthusiasts in your area. You'll have the opportunity to learn from others, share your own knowledge and experiences, and make new friends.

6. HOW WE COLLECT AND RECEIVE PERSONAL DATA

We collect and receive personal data using different methods:

• Personal data you provide to us You may give us your personal data directly, for example, when you provide your Registration Data to register an account; provide your Contact Data as part of a survey; purchase event tickets and other Services via our Platform; contact us with enquiries; complete forms on our Platform; subscribe to receive our marketing communications; or provide feedback to us.
• Personal data we collect using cookies and similar technologies When you access and use our Site, we will collect certain Observed Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the Insight and Analysis section for more information).
• Personal data received from third parties We may receive personal data about you from third parties, including our analytics providers, data brokers and third party directories.
• Publicly available personal data From time to time, we may collect personal data about you (Identity Data and Contact Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example, through posts on social media platforms).

Our Meetup group is a great way to connect with other Xxtra enthusiasts in your area. You'll have the opportunity to learn from others, share your own knowledge and experiences, and make new friends.

We collect and process personal data from the following people:

• Site visitors If you browse our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
• Registered users If you register an account on our Platform, including where you sign up for a paid subscription or purchase tickets, we will collect and process your personal data in connection with the provision of our Services to you.
• People who contact us with enquiries If you contact us with an enquiry, submit a complaint or provide any feedback, we will collect and process your personal data in connection with your interaction with us and our Platform.
• People who work for our suppliers If you work for one of our suppliers and have responsibility for administering your organisation’s account with us or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation’s relationship with us.
• Visitors to our physical locations If you attend one of our offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when asking us to assist you in finding accommodation or transportation suitable for your needs, or when signing in as a guest. CCTV footage may also be collected for security purposes.
• Job applicants If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.

If we use cookies to help us personalise our Platform and to understand more about users of our Platform

We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) or may otherwise collect Observed Data through your use of our Platform and any emails that you receive from us. 

Please see our Cookie Notice for further information, including details of our third-party partners.

We and our third-party partners use Observed Data and Transaction Data to personalise your experience on our Platform and to personalise the content that we deliver to you through our advertising and marketing activities referred to in the Advertising and Marketing section.

In addition, we and our third-party partners may use Observed Data and Transaction Data on an aggregated basis, or in a way that does not directly identify you, for the following purposes:

• to count users who have visited our Platform or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Platform and our Services and the effectiveness of our emails;
• to measure the effectiveness of our content;
• to learn what parts of our Platform are most interesting to our users and what kind of features and functionalities our users like to see;
• to help us understand the type of marketing content that is most likely to appeal to our clients and potential clients;
• to help us with the selection of future service lines, website design and to remember your preferences; and
• to understand the causes of errors and crashes in relation to our Platform for troubleshooting and support purposes.
• In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Where your data is collected through the use of non-essential Cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.

In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Platform, it is in our legitimate interest to use your personal data in the ways described above to improve our Services.

If we process any special (or “sensitive”) categories of data, such as data concerning your health, sex life or sexual orientation, we will only process that personal data where we are able to do so under applicable legislation (for example, where you have chosen to make that information public) or with your explicit consent.

This section describes how we may use your personal data to send our advertising to you (including to decide what advertising to send you). It also explains how we and our third-party advertising partners may use your personal data to display our advertising to you when you visit or use other websites and/or online services. In some cases, we may be joint controllers with third parties in respect of these activities – please see the Joint Controller Activities section below for further information on this relationship.

If we send you marketing communications by email and/or SMS

We use your Identity Data, Contact Data and Communications Data to send you marketing communications by email and/or SMS. Our marketing will include press releases and information about us, our Services and the offers and promotions we offer from time to time.

Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you from Identity Data, Contact Data, Registration Data, Observed Data and Transaction Data. Non-personalised marketing is marketing that is not tailored to you.

Where we are sending you personalised marketing, we may also use Identity Data, Contact Data, Registration Data, Observed Data and Transaction Data to help us decide what sort of personalised marketing to send you. Please see the Insight and Analysis section for more details about how we may collect Observed Data.

It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.

We will only send marketing communications to you by email and/or SMS where we have permission to do so. For example, you may have opted in to receiving marketing on our Platform or we may have collected permission to send you marketing when you enquired about or purchased our Services. In certain circumstances, we may rely on our legitimate interest to send marketing by email and/or SMS to those who have purchased or requested our Services.

If we process any special (or “sensitive”) categories of data, such as data concerning your health, sex life or sexual orientation, we will only process that personal data where we are able to do so under applicable legislation (for example, where you have chosen to make that information public) or with your explicit consent.

In addition, please see the Insight and Analysis section to learn about the legal basis that we rely on to collect Observed Data via the use of Cookies.

If we carry out any online advertising through third-party advertising tools

Our third-party advertising partners may provide tools that we can use to display our ads to people who we think are more likely to be interested in our Services.

For example, an advertising partner may have determined that you are someone who is likely to be interested in dating services, using data that they have collected about you (which we do not receive). If we want to display our advertising to people interested in such services on third-party websites that use the services of our advertising partner, we may ask our advertising partner to display our advertising to you.

If you are someone who has seen this advertising, it is in our legitimate interest that the relevant third-party advertising partner uses the data that you have provided to it to advertise our Services, although please note that we do not receive this data and you should exercise your data subject rights in accordance with the privacy notice of the relevant online service that displays our advertising to you.

If we carry out any online advertising through Observed Data

We and our third-party partners may also use Observed Data and other data that is collected through your use of and interaction with third-party websites and services to provide you with, and analyse the effectiveness of, personalised and non-personalised advertising when you visit or use those other websites and services. In some cases, we do this as described in the Customer Match Advertising section below.

By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our Platform or which we or our third-party partners think you otherwise might be interested in based on Observed Data. Our third-party partners may use the data that is collected to show personalised ads for products and services offered by third parties.

Please see the Insight and Analysis section to learn about the legal basis that we rely on to collect data via the use of Cookies.

Where we use your personal data to display personalised online advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interest to promote our Services to you.

If we process any special (or “sensitive”) categories of data, such as data concerning your health, sex life or sexual orientation, we will only process that personal data where we are able to do so under applicable legislation (for example, where you have chosen to make that information public) or with your explicit consent.

Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. For more information, please read the privacy notice of the relevant third-party provider (see our Cookie Notice for details).

If we carry out “customer match” advertising

We may share your Contact Data (usually your email address, in an encrypted or ‘hashed’ form) with third-party providers of social media platforms such as Facebook and other similar platforms (“Social Media Platforms”), so that the Social Media Platform can try to “match” your data with the registration data of their registered users.

Where there is a successful “match” (i.e., because you are a registered user of the relevant Social Media Platform), our advertising will be displayed to you when you use the relevant Social Media Platform (e.g., on your Facebook newsfeed). This is known as “customer match” or “custom audience” advertising because we “customise” the audience that we want to reach on the relevant Social Media Platform.

In some cases, we may also share your hashed Contact Data with Social Media Platforms in order to exclude you from seeing our advertising (because we are trying to reach people who are not yet users of our Services).

Some of the advertising that you see may be personalised to you. The data that we use to personalise our advertising, such as your Technical Data and Observed Data, will not be provided to the third-party providers of the Social Media Platforms. Please see the Insight and Analysis section to learn more about how we personalise advertising to you.

This activity is also subject to the privacy choices you have elected to make on the relevant Social Media Platforms.

We will only share your personal data with Social Media Platforms for the above purpose where you have provided your consent or where it is otherwise in our legitimate interest to do so to promote our Services.

If we process any special (or “sensitive”) categories of data, such as data concerning your health, sex life or sexual orientation, we will only process that personal data where we are able to do so under applicable legislation (for example, where you have chosen to make that information public) or with your explicit consent.

If we carry out “lookalike” advertising on Social Media Platforms

Where we have displayed our advertisements to people on Social Media Platforms through Customer Match Advertising (as described above), we may also ask the relevant Social Media Platforms to find other people that share similar interests and characteristics to those persons, which will be based on information that the Social Media Platforms have collected about you and those similar persons (which we do not receive).

This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” our customers and users, and other persons that are likely to be interested in our advertising based on having similar characteristics or interests.

If you are someone who has seen our “lookalike” advertising on a Social Media Platform, this is because the Social Media Platform has determined that you “look like” our customers. Please note that this activity is based on data that you have provided to the relevant Social Media Platform (which we do not receive) and is also subject to the privacy choices you have elected to make on such third-party services. If you wish to opt out of receiving this form of advertising, you will need to update your preferences on the relevant Social Media Platform.

It is in our legitimate interest to share your personal data with the Social Media Platforms so that we can advertise our Services to other individuals that use those Social Media Platforms and share similar interests and characteristics with you. You can opt out of our sharing of your personal data with the Social Media Platforms by exercising your rights as a data subject as explained in the Your rights as a data subject section below.

If we process any special (or “sensitive”) categories of data, such as data concerning your health, sex life or sexual orientation, we will only process that personal data where we are able to do so under applicable legislation (for example, where you have chosen to make that information public) or with your explicit consent.

If you are someone who has seen our “lookalike” advertising on a Social Media Platform, it is in our legitimate interest that the relevant Social Media Platform uses the data that you have provided to it to advertise our Services, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with the privacy notice of the relevant Social Media Platform that displays our advertising to you.

If we use your personal data in connection with our recruitment activities

We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

The personal data we process may include your Identity Data, Contact Data, Recruitment Data and any other personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Where we use your personal data in connection with our recruitment activities, it will be in connection with us taking steps at your request to enter into a contract with you, or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.

We will not process any special (or “sensitive”) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

If we have engaged you or the organisation you represent to provide us with products or services

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer that is relevant to our relationship with you or the organisation you represent.

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in the ways described above to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Services to others, in an effective way.

You have certain rights in relation to the personal data we hold about you. Please note that many data subject rights are not absolute and the extent to which they apply may vary depending on the circumstances and any exemptions that may apply. If you would like to exercise any of these rights, or wish to obtain further information on your rights, please contact us using the details set out in the How to Contact Us section above.

Your right of access

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.

Your right to erasure

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

Your right to restrict processing

You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to data portability

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.

Your right to object

You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.

Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the How to Contact Us section or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the How to Contact Us section. You can also report any issues or concerns to a national supervisory authority in the country of your residence or the place of the alleged infringement. As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk. You can find a list of contact details for EU supervisory authorities at https://edpb.europa.eu/about-edpb/about-edpb/members_en

We have several events coming up, including workshops, guest speakers, and social gatherings. Check our calendar to see what's coming up!

This version was last updated on 3rd August 2023