Privacy Policy

Noir ("we," "us," "our") operates the Noir companion booking platform. We are committed to protecting the privacy of all users, with particular sensitivity to the nature of the services offered on this Platform. Your trust is essential to everything we do, and we take our data protection obligations seriously.

For questions about this Privacy Policy or your personal data, contact our Data Protection Team at: help@noireliteagency.co.uk.

Information You Provide

• Account registration data: name, email address, date of birth, password (hashed).
• Identity verification documents: government-issued ID (collected solely for age and identity verification).
• Profile information (Companions only): photos, biography, service descriptions, availability.
• Booking and transaction details: booking dates, service descriptions, payment information.
• Communications: messages sent through the Platform's internal messaging system.
• Complaint and report submissions.
• Customer support communications.

Information Collected Automatically

• Device identifiers and IP address.
• Browser type, operating system, and device type.
• Pages visited, features used, and time spent on the Platform.
• Referring URLs and search terms used to reach the Platform.
• Cookie and tracking data (see our Cookie Policy).

Information We Do Not Collect

We do not collect, store, or process information relating to the specific content of in-person engagements between Clients and Companions. We do not track physical locations during engagements. We do not sell personal data to third parties.

We use the information we collect to:

• Create and maintain your account.
• Process bookings and facilitate payments.
• Verify your identity and age.
• Communicate with you about bookings, account activity, and platform updates.
• Detect, prevent, and respond to fraud, abuse, and prohibited activities.
• Comply with legal obligations and respond to lawful requests from authorities.
• Improve the Platform through aggregated, anonymized analytics.
• Send optional marketing communications (with your consent, which you may withdraw at any time).

We process your personal data under the following legal bases:

• Contract performance: to provide you with the services you request.
• Legal obligation: to comply with applicable laws, including age verification requirements.
• Legitimate interests: to prevent fraud, maintain platform security, and improve our services.
• Consent: for optional communications and non-essential cookies.

We Share Data With

• Payment processors: to securely process transactions. Payment data is handled in accordance with PCI-DSS standards.
• Identity verification providers: to verify age and identity as required.
• Cloud infrastructure providers: to host and operate the Platform.
• Legal and regulatory authorities: when required by law, court order, or to protect rights and safety.

We Do Not

• Sell your personal data to any third party.
• Share your data with advertisers.
• Share Companion or Client identity information with each other beyond what is necessary for the booking.

All third-party service providers are bound by data processing agreements that require them to protect your information and use it only for the purposes specified.

We retain personal data for as long as your account is active and for a period thereafter as required by law or legitimate business need. Specifically:

• Account data: retained for the duration of the account and for 5 years after account closure.
• Identity verification documents: retained for the minimum period required by applicable law (typically 7 years for financial records).
• Transaction records: retained for 7 years for tax and audit purposes.
• Communications: retained for 3 years.
• Age verification records: retained as required by applicable law.

Upon deletion of your account, we will remove or anonymize personal data except where retention is required by law.

Subject to applicable law, you have the following rights regarding your personal data:

• Right of access: to receive a copy of the personal data we hold about you.
• Right to rectification: to correct inaccurate or incomplete data.
• Right to erasure: to request deletion of your data, subject to legal retention obligations.
• Right to restriction: to request that we limit processing of your data.
• Right to data portability: to receive your data in a structured, machine-readable format.
• Right to object: to object to processing based on legitimate interests.
• Right to withdraw consent: at any time where processing is based on consent.
• Right to lodge a complaint: with the relevant data protection supervisory authority.

To exercise any of these rights, contact help@noireliteagency.co.uk. We will respond within 30 days. We may request identity verification before processing your request.

We implement industry-standard technical and organizational measures to protect your personal data, including:

• Encryption of data in transit using TLS.
• Encryption of sensitive data at rest.
• Access controls limiting data access to authorized personnel only.
• Regular security assessments and penetration testing.
• Incident response procedures for data breaches.

In the event of a data breach that poses a risk to your rights, we will notify you and the relevant supervisory authorities as required by applicable law.

Your data may be transferred to and processed in countries other than your country of residence. We ensure that any such transfers are protected by appropriate safeguards, including standard contractual clauses approved by relevant data protection authorities.

The Platform is strictly for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we discover that we have collected personal data from a minor, we will delete it immediately and close the associated account. If you believe a minor has created an account, contact us immediately at help@noireliteagency.co.uk.

We use cookies and similar tracking technologies as described in our Cookie Policy. You may manage your cookie preferences through your browser settings or our cookie consent tool.

We may update this Privacy Policy periodically. We will notify you of material changes by email or by posting a prominent notice on the Platform. Continued use of the Platform after such notice constitutes acceptance of the revised policy.

For privacy-related inquiries: help@noireliteagency.co.uk

For complaints you may not be able to resolve with us directly, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.