Privacy Policy

1. Who are we

Thank you for visiting our website and considering the use of our services. Lulu Black is an introduction agency that arranges meetings between the client (you) and a self employed worker listed on the Lulu Black website (the “Companion”). Your privacy is important to us and it is our policy to respect your privacy across our service.

This document describes the information we collect, how we use it, how we store it and whom it is shared with. If you have any issues, questions or concerns with our Privacy Policy, please email hello@lulublack.co.uk.

2. What information do we collect?

We will process your personal information fairly and in a transparent matter. We collect and process information about you to a) keep the Companions we list safe and b) to reduce the risk of financial fraud.

There are three basic ways we collect information:

• information you choose to give us;
• information we get automatically when you contact our services;
• information we get from third parties.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We do not keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.

Information you choose to give us

When you interact with our service, we collect the information that you choose to share with us. Initially this is only your:

• name;
• phone number; and/or
• email address.

When we progress from initial enquiry into arranging a meeting, we will also have access to your:

• government ID; or
• linkedin profile;
• your home address (if the meeting is to be there);
• any other personal information you may have shared with us.

We do not collect any identifiable information about how you use our website, how often you visit, from what device and so on. Google analytics does collect this information, but it is anonymised and not linked to your personal data.

3. Information we keep short-term

We keep your government ID and/or linkedin data and/or home address on a short-term basis only. We keep it from the date you provide it to us, until the day after your meeting has taken place with the Companion.

Once the Companion has left your meeting safely and securely, and without any problems or mistreatment occurring, your government ID and/or linkedin data and/or home address is permanently deleted from our storage.

4. Information we keep medium-term

We keep your name, your phone number and/or email address in our contact list for 2 years from the date of your last booking with us. This contact list is secured with 2FA technology.

Many of our clients book multiple times, and storing basic information about you in this way allows us to continue to serve you without requesting fresh government ID/linkedin data on each occasion you reach out.

If you want your name/phone number/email address deleted from the above records sooner, please email us at hello@luluback.co.uk – we will action the request promptly. Alternatively, you can message us on 07858 502249.

5. Information we keep long-term

Every time you arrange a meeting through our service, we take a deposit by bank transfer. Our bank account does not make any reference to Lulu Black or introduction/escort agency – it is discreetly named.

We do not have paper bank statements delivered to our offices and all financial records remain accessible via online banking only, secured via various banking technologies.

We cannot ever delete your deposit records from our bank statements, and we are obliged to keep such financial records for a number of years to comply with our financial obligations.

The only personal data of yours that will appear in our financial records long-term is your bank account name, from which you made the transfer to us.

6. Disclosure of personal information to third parties

We share your name, phone number and the meeting address (which may be your home address) with the Companion you have asked to meet. We do not provide the Companion with your identity verification data such as your government ID. The Companion is not an employee of Lulu Black, and we cannot accept responsibility or liability for their respective privacy practices.

We do not routinely share data with any other third parties with the following exception:

If you do something that causes harm to the Companion or our service (this can be harm to physical health, mental health or financial harm), your data may be shared with the Police, and/or sex worker harm reduction services.

7. Controlling your personal information

Choice and consent: By providing personal information to us of your own free will, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under the age of 18, you are not permitted to use this website. We do not direct or advertise our Services to anyone under the age of 18 and the age of majority. Hence we do not knowingly collect personal information from anyone under 18 and the age of majority.

Information from third parties: If we receive personal information about you from a third party (for example, a reference from another sex worker which you instigate), we will protect it as set out in this privacy policy.

Restrict: You may choose to restrict the storage of your personal information. If you have previously agreed to us storing your personal information in our contact list, you may change your mind at any time by contacting us using the details below.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would not include your data among the assets transferred to any parties who acquire us with or without consent.

9. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

10. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. Your continued use of our service after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

Privacy Contacts

Our Data Controller Officer and Data Protection Officer can be reached through hello@lulublack.co.uk or via +447858502249.