Privacy Policy

1. About this Privacy Policy

SwingHub takes the privacy, security and protection of our members’ personal information extremely seriously. Given the nature of our community, privacy is a fundamental part of how we operate.

This Privacy Policy explains how SwingHub Limited trading as SwingHub (“SwingHub”, “we”, “us” or “our”) collects, uses, stores, protects, shares and deletes personal information when you access or use SwingHub.

This includes our mobile application, website and any related services, features, communications or other services that link to this Privacy Policy together referred to as the “Services”.

We process personal information in accordance with applicable UK data protection legislation including the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and the Data (Use and Access) Act 2025 where applicable.

By creating an account, accessing or using our Services you acknowledge that you have read and understood this Privacy Policy and agree to the handling of your personal information as described in it where permitted by applicable law.

Where we are required to obtain your specific consent for a particular type of processing we will obtain that consent separately. Accepting this Privacy Policy does not replace any specific consent required by law.

If you do not agree with this Privacy Policy you should not create an account or continue using our Services.

Questions about this Privacy Policy or the way SwingHub handles personal information can be sent to help@swinghub.com.

2. Who we are

SwingHub is a social networking platform intended for adults aged 18 and over.

For the purposes of applicable UK data protection law SwingHub Limited is the controller of personal information processed in connection with the Services except where another organisation is independently responsible for particular processing.

Because of the nature of the SwingHub community some information provided by members may reveal or relate to a person’s sex life, sexual orientation or other information classed as special category data under UK data protection law.

We recognise the particularly sensitive nature of this information and the importance of protecting the privacy of our members.

3. Information we may collect

The information we collect depends on how you use SwingHub and which features you choose to use.

This may include:

• your name
• date of birth and age
• email address
• username
• account identifiers
• profile information
• gender and gender identity where provided
• sexual orientation where provided
• relationship information where provided
• information concerning your sex life where provided
• interests and preferences
• profile photographs
• photographs, videos and other uploaded media
• posts and other content
• messages and communications
• reports and complaints
• information provided to our support or safeguarding teams
• identity and age-verification information
• information concerning subscriptions or purchases
• transaction information
• device information
• operating system and application information
• IP address
• login information
• security and authentication information
• approximate or precise location where a feature requires it and appropriate permission has been provided
• application usage and interaction information
• relevant technical, application and infrastructure logs
• information concerning reports, moderation decisions and investigations
• information you voluntarily provide when communicating with us
• information supplied to us by another person where permitted by law and
• other information reasonably required to operate, protect or administer the Services.

We ask members only to provide information that is accurate and that they are entitled to provide.

4. Special category information

Because SwingHub is an adult social networking service information that members voluntarily provide may reveal information concerning their sex life or sexual orientation.

This is considered special category data under UK GDPR and receives additional legal protection.

Where we process special category information we will identify an appropriate lawful basis under Article 6 of UK GDPR and an applicable condition under Article 9 together with any additional condition required by the Data Protection Act 2018.

Depending on the processing concerned this may include explicit consent or another condition permitted by applicable law.

Where we rely upon consent you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

We apply additional consideration to the security, access, minimisation and retention of information of this nature.

5. Information you choose to make available to other members

SwingHub is a social platform. Some information you add to your account is intended to be viewed by other members depending on your privacy settings and the feature being used.

This may include your username, profile information, photographs and media, interests, posts, profile descriptions, approximate location or distance information where applicable and other information you choose to share.

You should carefully consider what information you choose to publish or disclose to other members.

Privacy settings can reduce who can access certain information but no online service can guarantee that information another person has legitimately viewed will never be copied, photographed, screenshotted, recorded or otherwise retained by that person.

Members must comply with our Terms and Community Guidelines when using information belonging to other members.

6. Identity and age verification

SwingHub is an adults-only platform.

We may require members to complete identity or age-verification procedures to establish that they are eligible to use our Services and to help protect the safety and integrity of the community.

Verification may be performed by SwingHub or by an authorised verification provider.

Depending on the verification method this may involve processing information such as name, date of birth, photograph, identity document information, verification status, verification reference information and other information necessary to complete the verification process.

Where a third-party verification provider processes information it may process information on our behalf or in accordance with its own privacy terms depending on the service provided.

We seek to minimise the amount of verification information retained by SwingHub to what is reasonably necessary for verification, fraud prevention, safeguarding, legal and regulatory purposes.

7. How we use personal information

We may process personal information to:

• create and administer accounts
• provide the Services
• enable members to interact with one another
• provide features requested by members
• personalise and improve the Services
• authenticate members
• verify identity and age
• maintain account and platform security
• prevent fraud, spam, scams and misuse
• enforce our Terms and Community Guidelines
• moderate content
• investigate reports and complaints
• protect members and third parties
• respond to safeguarding concerns
• prevent or investigate unlawful or harmful behaviour
• provide customer support
• communicate important service information
• administer subscriptions and purchases
• maintain technical systems
• diagnose faults and improve performance
• understand how our Services are used
• send marketing where permitted
• establish, exercise or defend legal rights
• comply with legal and regulatory obligations
• cooperate appropriately with law enforcement or regulatory authorities and
• otherwise operate and protect SwingHub and its community.

We will not use personal information for purposes that are incompatible with the purposes for which it was collected unless permitted by law.

8. Our lawful bases for processing

Depending on the purpose and information concerned we may rely upon one or more lawful bases available under UK data protection law.

Contract: where processing is necessary to provide the Services 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 person and those interests are not overridden by your rights and interests. This may include protecting our platform, preventing abuse, maintaining security, investigating complaints, improving our Services and operating our business.

Consent: where you have given valid consent to specific processing.

Legal obligation: where processing is necessary for us to comply with a legal obligation.

Vital interests: in limited circumstances where processing is necessary to protect someone’s life.

Recognised legitimate interests or another lawful basis: where applicable UK law expressly permits processing for a recognised purpose.

Where special category information is involved we will also identify an appropriate condition under Article 9 of UK GDPR and any applicable requirements of the Data Protection Act 2018.

We determine and document the appropriate lawful basis for processing according to the purpose and circumstances concerned.

9. Safeguarding

SwingHub takes safeguarding seriously and maintains safeguarding arrangements appropriate to the nature of our Services.

SwingHub has a designated Safeguarding Lead.

Safeguarding concerns may be reported through the appropriate reporting facilities within SwingHub or by contacting help@swinghub.com.

We may process information where reasonably necessary to assess, manage, investigate or respond to a safeguarding concern.

This may include information contained within accounts, communications, reports, media, technical records and other relevant information.

Where appropriate and lawful we may share relevant information with law enforcement, safeguarding professionals, emergency services, regulators or other appropriate organisations or individuals.

The safety of individuals will be considered alongside privacy and data protection requirements when safeguarding decisions are made.

10. Reports, complaints and investigations

SwingHub may process account information when investigating member reports, complaints, safeguarding concerns, suspected breaches of our Terms or Community Guidelines, fraud or scams, harassment, abuse, impersonation, safety concerns, suspected unlawful activity and conduct which may threaten the safety, security or integrity of SwingHub or its community.

As part of an investigation SwingHub reserves the right where necessary and lawful to discuss or disclose relevant account information with appropriate third parties.

Depending on the circumstances this may include complainants, witnesses, affected individuals, venues, event organisers, service providers, professional advisers, safeguarding professionals, regulators, law enforcement agencies or other persons or organisations reasonably relevant to the investigation.

We will always endeavour to protect the identity and privacy of members involved in an investigation.

Where reasonably practicable we may limit, redact, anonymise or pseudonymise information before sharing it.

However we cannot guarantee anonymity where identifying information is reasonably necessary to properly investigate a matter, protect an individual, establish, exercise or defend legal rights, comply with the law or cooperate with an appropriate authority.

We will seek to limit any disclosure to information that is adequate, relevant and reasonably necessary for the purpose concerned.

11. When we may share personal information

We do not treat member information as something that can be freely disclosed.

We may share personal information where necessary with categories of recipients including service providers acting on our behalf, hosting and infrastructure providers, security providers, identity and age-verification providers, payment processors, communications providers, analytics and technical providers, professional advisers, insurers, law enforcement agencies, courts, regulators, safeguarding organisations or professionals, other members where the nature of a feature requires it, relevant third parties involved in an investigation where lawful and necessary and a purchaser, investor or successor organisation in connection with a legitimate corporate transaction subject to appropriate safeguards.

Service providers acting on our behalf are expected to process information only in accordance with applicable contractual and legal requirements.

We may also disclose information where we reasonably believe disclosure is necessary to comply with law, respond to valid legal process, protect the rights or safety of another person, investigate suspected criminal activity or establish, exercise or defend legal rights.

12. Law enforcement and legal requests

SwingHub may receive requests for information from the police, courts, regulators or other authorities.

We do not automatically disclose information merely because it has been requested.

Where appropriate we may assess the nature, scope, authority and legal basis of a request before disclosure.

Where disclosure is lawful we will seek to provide only information reasonably necessary for the relevant purpose.

Nothing in this Privacy Policy prevents SwingHub from making a proactive disclosure to an appropriate authority where we reasonably consider it necessary and lawful to protect an individual, address a serious safeguarding concern, prevent or detect crime or comply with another applicable legal requirement.

13. Service providers and processors

We use third-party organisations to help us operate SwingHub.

These organisations may provide services including hosting, infrastructure, communications, security, verification, payments, analytics, customer support and other technical functions.

Where an organisation acts as a processor on our behalf we require appropriate data protection arrangements to be in place.

Some providers may act as independent controllers for particular activities. Where this occurs their own privacy information may also apply.

We periodically review the providers and processing arrangements used to operate our Services.

14. International data transfers

Some of the organisations that support SwingHub may process information outside the United Kingdom.

Where personal information is transferred internationally we will take steps required by applicable UK data protection law.

Depending on the destination and circumstances this may include relying upon UK adequacy regulations or implementing appropriate safeguards such as approved contractual protections.

Where required information about applicable safeguards can be requested by contacting help@swinghub.com.

15. Marketing and service communications

We may send communications necessary to operate your account or provide the Services. These may include security messages, account notifications, verification messages, important policy information and service updates.

These are different from optional marketing communications.

Where required we will obtain appropriate permission before sending direct marketing.

You can withdraw from marketing communications through the options provided within the communication or through relevant account settings.

We may retain sufficient information to record that you have opted out so that we can respect your preference.

Withdrawing from marketing does not prevent us from sending essential service or account communications.

16. Location information

Certain SwingHub features may use location information.

Depending on the feature and your device settings this may include approximate or precise location information.

Where device permission is required you can manage location access through your device settings.

We seek to use location information only to the degree reasonably necessary for the relevant feature, safety purpose or other disclosed purpose.

You should understand that changing location permissions may affect the availability or operation of location-based features.

17. Technical information, logs and security data

When you use SwingHub our systems may automatically create technical information necessary to operate, secure and troubleshoot the Services.

This may include IP addresses, device identifiers, application versions, operating system information, login records, authentication events, error information, security events, application activity, timestamps, infrastructure logs and other technical records.

We may use this information for security, fraud prevention, service delivery, troubleshooting, performance, investigations and compliance.

We do not retain identifiable technical information indefinitely merely because it can be retained.

18. Cookies and similar technologies

Our website and Services may use cookies, local storage, software development kits or similar technologies where necessary to provide functionality, maintain security, remember preferences, understand use or support other legitimate purposes.

Where applicable we will provide appropriate information and obtain consent where consent is legally required.

You may be able to control certain technologies through your browser, device or consent settings.

19. Data security

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

Measures may include access controls, authentication, monitoring, encryption where appropriate, restricted administrative access, infrastructure security, staff controls and internal procedures.

Access to personal information is limited according to role and legitimate business need where reasonably practicable.

No internet service or storage system can guarantee absolute security. Members are responsible for protecting their login credentials and should notify us promptly if they believe their account has been compromised.

20. Personal data breaches

Where we become aware of a personal data breach we will assess the circumstances, risks and legal requirements that apply.

Where required we will notify the appropriate UK data protection regulator within the applicable statutory timeframe.

Where a breach is likely to result in a high risk to the rights and freedoms of affected individuals we will notify those individuals where required by law.

We maintain processes for investigating, documenting and responding to suspected personal data breaches.

21. Our general approach to retention

We retain personal information only where there is an appropriate purpose for doing so.

We process personal information in accordance with the UK GDPR storage limitation principle and do not intend to retain identifiable information for longer than is reasonably necessary for the purpose for which it is held.

Retention periods may vary depending on the type of information and the reason it is being held.

Information may be retained where necessary for providing the Services, account recovery, security, fraud prevention, safeguarding, investigation of complaints, regulatory compliance, legal obligations, dispute resolution, establishment, exercise or defence of legal claims and cooperation with appropriate authorities.

Once information is no longer required we will delete, anonymise or otherwise dispose of it in accordance with our applicable processes.

22. Media deleted by a member

When a member deletes media through SwingHub it becomes inaccessible through the normal SwingHub service immediately.

The underlying media may then be held in a secure and restricted retention state for up to three calendar months where necessary for legitimate compliance, regulatory, safeguarding, security, investigation or legal purposes.

Media held solely within this restricted retention state is not publicly accessible and is not available for normal use within SwingHub.

It will not simply continue to be used for marketing, engagement or ordinary business activity.

At the end of the applicable retention period the media will be permanently deleted unless the specific information is subject to a valid legal, safeguarding, regulatory or investigation hold or another lawful requirement requires continued retention.

23. Account deletion

When a member chooses to delete their SwingHub account the account and its content are immediately hidden and inaccessible to other members and removed from normal marketing and engagement activity.

Members have a 28-day recovery period should they change their mind.

During this period the account may be restored by the member through the applicable account recovery process.

After the 28-day recovery period the account is scheduled for permanent deletion.

Personal information covered by our retention processes may remain securely restricted for up to three calendar months.

After the applicable retention period it will be permanently deleted unless there is a legitimate and lawful requirement to retain specific information for longer.

Where specific information must be retained for longer we will seek to retain only the information reasonably required for that purpose rather than maintaining the entire account unnecessarily.

24. Inactive accounts

Accounts with no qualifying activity for six months may enter our account archiving process.

Where reasonably practicable members will be notified in advance and given an opportunity to keep their account active.

Once archived the account will be hidden from other members and removed from normal marketing and engagement activity.

Archiving is different from immediate permanent account deletion and allows us to manage inactive accounts while providing a limited opportunity for restoration.

25. Media belonging to archived accounts

Media belonging to an archived account is scheduled for permanent deletion 28 days after archiving.

If the member restores their account within those 28 days the scheduled media deletion will be cancelled.

Once media has been permanently deleted it cannot subsequently be restored.

Any separate retention required for safeguarding, legal, regulatory, fraud prevention or investigation purposes will be handled in accordance with the restricted retention provisions of this Privacy Policy.

26. Restricted retention

Where information is no longer required for ordinary operation of a member’s account but needs to be retained temporarily for an appropriate purpose we may place it into a restricted retention state.

Information held solely in restricted retention will not be used for ordinary marketing, member engagement or unrelated commercial purposes.

Access will be limited to people or systems with an appropriate reason to access it.

Our general restricted retention period is up to three calendar months unless a specific legal, regulatory, safeguarding or investigation requirement justifies retention of particular information for longer.

27. Legal, safeguarding and investigation holds

There may be circumstances where information that would otherwise be deleted needs to be preserved.

Examples include where information is reasonably necessary in connection with a safeguarding investigation, suspected criminal activity, fraud, an ongoing complaint, threatened or existing legal proceedings, a police request, a court order, a regulatory requirement, establishment, exercise or defence of legal rights or another applicable legal obligation.

Where this occurs deletion may be suspended for the relevant information.

A hold does not mean we may retain an entire account indefinitely without justification.

Where reasonably practicable we will identify and retain only the information necessary for the relevant purpose. Access will be appropriately restricted and the continued need for retention may be reviewed.

When the reason for the hold ends the information will return to the applicable deletion process unless another lawful reason for retention exists.

28. Systems covered by our retention processes

Our retention and deletion processes concern more than information visible within the SwingHub application.

Depending on the information concerned they may include primary stored media, media derivatives, database records, account records, caches, application logs containing identifiable information, infrastructure and security logs, operational systems, backup or recovery systems where applicable and other infrastructure used to operate SwingHub.

Deletion from a member-facing interface does not necessarily mean that every underlying copy is instantaneously removed from every technical system.

Where information remains temporarily within restricted technical systems it remains subject to our security, access and retention controls and is deleted or overwritten in accordance with the applicable retention process.

29. Your rights

Depending on the circumstances and lawful basis concerned, UK data protection law may give you rights including:

• the right to be informed about how your information is used
• the right of access
• the right to rectification of inaccurate information
• the right to erasure in applicable circumstances
• the right to restriction of processing in applicable circumstances
• the right to data portability in applicable circumstances
• the right to object to certain processing
• rights relating to certain automated decision-making where applicable
• the right to withdraw consent where processing is based on consent and
• the right to complain to the UK data protection regulator.

These rights are not all absolute and exemptions or restrictions may apply depending on the circumstances.

30. Accessing your information

You have the right to ask whether we process personal information about you and to receive a copy of that information, subject to any exemptions, restrictions, redactions or other provisions permitted or required by applicable law.

Supplementary information concerning how and why we process personal information including processing purposes, categories, recipients, retention and member rights is provided within this Privacy Policy or alongside the information where required.

If you would like a copy of your personal information or need assistance with the process please contact help@swinghub.com.

31. Formal Subject Access Requests

You may make a formal Subject Access Request at any time in accordance with applicable UK data protection law.

A request does not need to use the words “Subject Access Request” or “SAR” to be valid.

Where we receive a valid request for access to your personal information we will handle it in accordance with applicable UK data protection legislation and regulatory guidance.

We may take reasonable steps to verify your identity where necessary before disclosing personal information.

We will respond without undue delay and within the applicable statutory timeframe.

Information may be withheld, restricted or redacted where permitted or required by law including where disclosure would adversely affect the rights and freedoms of another person.

Requests and questions concerning your right of access can be directed to help@swinghub.com.

32. Right to rectification

You have the right to ask us to correct inaccurate personal information and in certain circumstances to complete information that is incomplete.

Where information can be changed directly within your account we may encourage you to use the available account controls as the quickest way to make the correction.

You may also contact help@swinghub.com.

33. Right to erasure

You may request deletion of your personal information where the right to erasure applies.

Once an erasure request takes effect the relevant information will be removed or restricted from normal use while the deletion process is completed.

Where applicable personal information will be permanently deleted within our retention period of up to three calendar months.

Certain information may need to be temporarily or exceptionally preserved where there is a legitimate and lawful safeguarding, fraud prevention, regulatory, police, investigation or legal requirement to do so.

The right to erasure is not an absolute right and we may retain information where applicable law permits or requires us to do so.

Where only specific information needs to be preserved we will seek to avoid retaining unrelated information unnecessarily.

34. Right to restriction

In certain circumstances you may ask us to restrict the processing of your personal information.

Where processing is restricted we may continue to store the information while limiting other uses as required by applicable law.

35. Right to object

You may have the right to object to processing based on certain lawful bases including processing based on legitimate interests.

We will consider objections in accordance with applicable UK data protection law.

You have the right to object to the use of your personal information for direct marketing at any time.

Where you object to direct marketing we will stop using your personal information for that purpose.

36. Data portability

Where applicable you may have the right to receive certain personal information you have provided to us in a structured, commonly used and machine-readable format and to ask for that information to be transmitted to another controller where technically feasible.

This right applies only in the circumstances provided by applicable law.

37. Withdrawing consent

Where we rely on your consent you may withdraw that consent at any time.

Withdrawal will not affect the lawfulness of processing that occurred before consent was withdrawn.

Withdrawal of consent may mean that certain optional features can no longer be provided where the relevant information is necessary for those features.

38. Automated decision-making

SwingHub may use automated systems to assist with security, fraud detection, moderation, spam prevention, recommendations or the operation of features.

Where we carry out solely automated decision-making that produces legal effects or similarly significant effects we will comply with the applicable requirements of UK data protection law including providing appropriate information and safeguards where required.

Automated tools may also assist human moderators without making the final decision themselves.

39. Information relating to other people

When using SwingHub you may provide information relating to another person including through messages, reports, complaints or safeguarding concerns.

You should only provide information that is reasonably relevant and that you are entitled or justified in providing.

The fact that information has been provided by another member does not mean it will automatically be treated as accurate.

Where appropriate we may assess information alongside other available evidence.

40. Children

SwingHub is intended only for people aged 18 or over.

Children are not permitted to create or operate SwingHub accounts.

If we become aware that a person under 18 is using the Services we may suspend or remove the account and take appropriate steps concerning the information associated with it.

Where there is a safeguarding concern we may preserve or disclose relevant information where necessary and lawful.

If you believe a person under 18 is using SwingHub please report this immediately through our reporting facilities or contact help@swinghub.com.

41. Account security

Members are responsible for taking reasonable steps to keep their accounts secure.

You should use appropriate authentication credentials, avoid sharing login information, keep your device secure, be cautious about information you disclose to other members and contact us if you believe someone has accessed your account without permission.

We may temporarily restrict or suspend an account where reasonably necessary to protect the member, other users or the Services while a security concern is investigated.

42. Business changes

If SwingHub is involved in a merger, acquisition, restructuring, financing, sale of assets or similar business transaction personal information may form part of that transaction.

Any transfer of personal information will remain subject to applicable data protection requirements.

Where required we will provide appropriate notice of a material change in controller or use of personal information.

43. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our Services, technology, legal requirements, regulatory guidance or privacy practices.

The date at the top of this Privacy Policy shows when it was last updated.

Where a change is material we may take reasonable steps to bring it to members’ attention through the application, website, email or another appropriate communication method.

Continued use of the Services following an update means you acknowledge the updated Privacy Policy. Where a change requires specific consent under applicable law we will seek that consent separately.

We encourage members to review this Privacy Policy periodically.

44. Contacting SwingHub

If you have questions, concerns or requests relating to privacy, personal information or this Privacy Policy please contact:

SwingHub Limited
Email: help@swinghub.com

Privacy and data protection requests may be directed to this address.

Safeguarding concerns may also be directed to this address and will be escalated to our Safeguarding Lead where appropriate.

45. Complaints

We encourage you to contact SwingHub first if you have a concern about how your personal information has been handled so that we have an opportunity to investigate and respond.

You can contact us at help@swinghub.com.

You also have the right to raise a complaint with the UK’s data protection regulator.

Exercising your right to complain to the regulator does not prevent you from contacting SwingHub first and you do not have to exhaust our internal complaints procedure before exercising any statutory right to complain.

46. Our privacy commitment

SwingHub takes the privacy, security and protection of our members’ personal information extremely seriously.

Given the nature of our community we recognise that our members place significant trust in us when providing their information.

Our retention processes cover not simply what is visible within the application but the systems supporting SwingHub including stored media and its derivatives, database records, caches, relevant application and infrastructure logs containing identifiable information and other infrastructure where applicable.

We maintain appropriate controls around retained information so that information being held solely for a defined retention purpose cannot simply continue to be used for marketing, engagement or ordinary business activity.

Our approach is straightforward:

We retain personal information only where there is an appropriate purpose for doing so. We restrict its use where necessary and securely delete it when that purpose and the applicable retention period have ended.

We continually review our privacy, security, safeguarding and data-retention practices to help ensure SwingHub remains a safe, secure and privacy-conscious platform for our community.

Published September 26th 2026