1. Data Controller

The data controller for SugarBowl.ie is [Company Legal Name], registered in Ireland with registered office at [Registered Address, Ireland]. For all privacy enquiries, contact [email protected].

2. Information We Collect

We collect information you provide directly:

Account information (email address, password hash).
Profile information (name, age, gender, location, photos, bio, interests).
Messages and communications with other users.
Age & identity verification data, selfie verification images, and for paid-gallery sellers, government-issued ID for KYC and age (18+) verification.
Limited billing information, name, billing country, last 4 digits of card; full card numbers are processed by our PCI-DSS compliant payment processor and never stored by us.
Support requests and correspondence.

We automatically collect:

Device and browser information.
IP address and approximate location.
Usage data and interactions with the Platform.

3. How We Use Your Information

We use your information to:

Provide and maintain our services.
Create and manage your account.
Enable connections between consenting adult members.
Process payments and subscriptions (via our payment processor).
Verify that members are 18+ and detect fraud, abuse and trafficking.
Send service-related communications.
Ensure safety, integrity and security of the Platform.
Comply with legal obligations, including reporting requirements.

4. Information Sharing

Your profile information (excluding email and billing data) is visible to other verified members. We do not sell your personal information. We may share information with:

Service providers (cloud hosting, payment processor, transactional email, identity verification) bound by data-protection agreements.
Law enforcement and regulators when required by law, including reporting suspected child sexual abuse material or trafficking.
Other users, only as necessary to facilitate their interaction with you on the Platform.

5. Card & Payment Data

All card payments are processed by our PCI-DSS compliant payment processor. We never see, transmit or store full card numbers, CVV or PIN. We retain only a non-sensitive token used to identify your subscription and the last four digits of the card for your reference.

6. Age & Identity Verification

Selfie-verification images are stored securely and used solely to confirm that the account holder matches their profile photos. KYC documents collected from paid-gallery sellers are used solely to confirm identity and age (18+) and are stored securely.

We retain verification data only as long as the related account is active, plus a reasonable additional period to defend legal claims and meet legal obligations under Irish and EU law. You may request deletion at any time, subject to those legal obligations.

7. Data Security

We implement appropriate technical and organisational measures, including encryption in transit and at rest, role-based access controls, and audit logging, to protect your personal information. However, no method of transmission over the Internet is 100% secure.

8. Your Rights (GDPR)

Under the GDPR and the Irish Data Protection Act 2018, you have the right to:

Access your personal data.
Correct inaccurate data.
Delete your account and data ("right to erasure").
Export your data ("data portability").
Object to or restrict processing.
Withdraw consent at any time.
Lodge a complaint with the Irish Data Protection Commission (dataprotection.ie).

To exercise these rights, contact us at [email protected].

9. International Transfers

Some of our service providers may process data outside the European Economic Area. Where they do, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses to ensure your data remains protected to EU standards.

10. Data Retention

We retain your information for as long as your account is active or as needed to provide services. If you delete your account, we delete your personal information within 30 days, except where retention is required by law (for example, tax, billing, fraud prevention, or law-enforcement cooperation).

11. Cookies

We use essential cookies to maintain your session and preferences. We do not use cross-site advertising cookies or sell user data. See our Cookie Policy for details.

12. Children's Privacy

Our Platform is strictly for adults 18 and over. We do not knowingly collect personal information from minors. If we learn that we have collected information from a person under 18, we will delete it immediately and report as required by law.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email or in-app notice. Continued use after the effective date constitutes acceptance.

14. Contact

For privacy questions, contact us at [email protected].