Privacy policy

What this policy covers

This policy covers the website swingersplaylive.com and the SwingersPlayLive Android app (com.swingersplaylive.app) on Google Play. The app is the same website, shown full screen by Chrome on your phone: it has no code of its own that collects data, asks for no device permissions, uses no advertising ID and contains no analytics or crash-reporting software. Everything described here happens on our servers, exactly as on the website. If you upload a photo in the app, Chrome’s own file picker is used; the app itself has no access to your files or camera. If you pay for a plan in the app, you pay in Google Play’s own payment screen (see “Payments” in section 2).

On your phone the app keeps only Chrome’s site data for swingersplaylive.com: the login cookies sp_session, sp_li and sp_rf, the sp_lang cookie when you choose a language (it remembers your language), the sp_app marker in session storage (it tells our pages that they are shown in the app; when you sign up or use the membership page in the app, our pages also tell our server that it happened in the app, for the statistics in section 3) and the sp_adult entry in local storage (it records that you confirmed you are 18 or over when you first opened the app). Where the app offers Google Play payments, it also keeps sp_play_sync in local storage (when it last checked your Google Play purchases) and, when you pay for a plan, sp_play_pending (a random reference for that purchase until our server has it). None of them holds your e-mail address, your profile or your messages; see our cookie policy. You can remove them by clearing the app’s storage in Android’s settings (it opens Chrome’s settings for the site) or Chrome’s site data for swingersplaylive.com.

This policy also covers the SwingersPlayLive iPhone app (com.swingersplaylive.app) on the App Store. The iPhone app talks only to our servers, apart from Apple’s App Store when it shows the plans’ prices and takes a payment, the push services named in section 5 when you turn on notifications, and the pages it opens in its browser (for example the verification provider’s pages when you choose to verify your age). It contains no advertising, analytics or crash-reporting software and uses no advertising identifier. On your phone it keeps your login token and its own settings in the iPhone’s Keychain. The pages of our website that the app opens in its browser (for example our terms and this policy) may keep cookies in that browser: the sp_lang cookie, which remembers the app’s language, and our login cookies if you log in there (see our cookie policy).

The iPhone app asks for access to your photos or your camera only when you add a photo or verify your age, and for your location only when you search near you: the app rounds your location to about 1 km before sending it, and our server uses it for that search only and does not save it with your account or in our database (like every request, it passes through our hosting provider’s request logs, see section 7). Notifications are sent only if you turn them on: we then keep your phone’s push token, and a notification says only that you have a new message (and who wrote it, if you choose so), never the message text.

When you sign up in the iPhone app or use its Membership screen (when you open it, tick a plan’s renewal terms or close the App Store payment window without paying), the app tells our server, for the statistics in section 3. If you pay for a plan in the iPhone app, you pay in Apple’s own payment screen (see “Payments” in section 2).

1. Who is responsible

The controller of your personal data is THE BOILING ROOM SRL (“we”). Contact for privacy questions and requests: contact@swingersplaylive.com.

• Registered office: Str. Drumul Pescarilor nr. 16A, Olimp 905503, Romania

2. What we collect

3. Why we use it, and our legal bases (GDPR)

• Providing SwingersPlayLive (account, profile, search, messaging, memberships) — performance of our contract with you (Art. 6(1)(b)).
• Sensitive data in your profile and activity — your explicit consent (Art. 9(2)(a)), which you give when you create your profile or claim your SwingersPlay network profile. You can withdraw it at any time by deleting your profile; this does not affect processing before withdrawal.
• Safety and moderation (screening photos and texts, handling reports, preventing fraud and abuse, protecting minors) — our legitimate interests and those of our members in a safe service (Art. 6(1)(f)), and legal obligations where they apply (Art. 6(1)(c)), for example under the EU Digital Services Act and US child-protection law.
• Age and identity verification — legal obligations where age assurance is required by law, and otherwise your consent when you choose to verify.
• Transactional e-mails (security, messages you receive, membership notices) — contract and legitimate interests. Marketing e-mails only with your consent.
• Legal claims and compliance (accounting, responding to authorities) — legal obligations and legitimate interests.
• Internal statistics (for example how many people join or delete their account each day, on the website or in our apps, and how many open the membership page, pick a plan, start a payment or buy) and short reports to our administrators (each morning, and one for each new purchase). They count people by member type, age band, city and country, and they may describe a person without naming them: member type, ages, city, country, the member types they are looking for, where and when they joined, whether their e-mail address is confirmed and whether they have Premium, and what they did on the membership page or bought (the plans, the time, whether they paid or why not, how many earlier orders) — never by name, username, e-mail address, messages or photos. Our legitimate interest in running and improving the service (Art. 6(1)(f)).

Automated moderation. We use automated tools to screen photos and texts before they are shown. Photos you upload are approved or rejected by these tools alone, and photo decisions cannot be appealed (you can go to court). Texts they flag are hidden or routed to a person; decisions to suspend an account are reviewed by a person, and you can ask for human review of other automated decisions and appeal them (see our content policy).

Artificial intelligence. Photos are checked by Sightengine, our image-moderation provider. Before anyone can see a photo you upload, we send it to Sightengine without its location or other metadata, and Sightengine’s artificial intelligence analyses it for nudity, signs that someone in it may be under 18, violence, weapons, drugs, self-harm and offensive symbols, and for text or QR codes in the image (for example contact details). Texts are checked by our own rules on our own servers. No other outside artificial-intelligence service receives your photos, texts or messages.

4. Profiles from our network of sites

We also operate the SwingersPlay network of lifestyle websites. If you created a profile on a network site and have not claimed it on SwingersPlayLive, it is shown here only as described below. Because we are established in the European Union (Romania), the GDPR applies to our handling of every network profile, wherever you live (Art. 3(1)).

• Public pages (visible to anyone, including search engines): your profile is listed, like the profile of a member who joined here, unless one of the following is true:
  • your profile’s home is in a country where sex outside marriage or same-sex relations are criminalised (Afghanistan, Algeria, Antigua & Barbuda, Bahamas, Bahrain, Bangladesh, Barbados, Belize, Brunei, Burkina Faso, Burundi, Cameroon, Chad, Comoros, Dominica, Egypt, Eritrea, Eswatini, Ethiopia, Gambia, Ghana, Grenada, Guinea, Guyana, Indonesia, Iran, Iraq, Jamaica, Jordan, Kenya, Kiribati, Kuwait, Lebanon, Liberia, Libya, Malawi, Malaysia, Maldives, Mali, Mauritania, Morocco, Myanmar (Burma), Niger, Nigeria, Oman, Pakistan, Palestinian Territories, Papua New Guinea, Philippines, Qatar, Samoa, Saudi Arabia, Senegal, Sierra Leone, Solomon Islands, Somalia, South Sudan, Sri Lanka, St. Kitts & Nevis, St. Lucia, St. Vincent & Grenadines, Sudan, Syria, Tanzania, Togo, Tonga, Trinidad & Tobago, Tunisia, Turkmenistan, Tuvalu, Uganda, United Arab Emirates, Uzbekistan, Yemen, Zambia and Zimbabwe), or we do not know its country. Profiles in those countries are never listed publicly, even after their owner takes them over; a profile whose country we do not know is listed only if its owner takes it over and chooses so;
  • you told us not to list it (with the link in our e-mails, or by writing to us), or our e-mails to your address bounced or were reported as spam;
  • your username is not suitable for public pages, for example because it contains an explicit word.
  We list these profiles without waiting for an e-mail from us first. We may still e-mail you about it, and you can take your profile off public pages at any time, as described below.
• What a public listing shows. If your profile is listed publicly, public pages show your username, member type, ages, home city, a rounded distance, how recently you were active and your profile text — the text only if our moderation approved it and it contains no explicit words and no contact details. Your profile page (/u/ followed by your username) is then public too, and search engines may index it when that text is at least 80 characters long. Public pages never show your photos, your e-mail address, your exact location or your messages.
• While your profile is not listed publicly, logged-in SwingersPlayLive members with a confirmed e-mail address can find your profile in search and open it, but they see only your username, member type, ages, city and how recently you were active. They do not see the profile text or headline from the network site, your preferences (“looking for”, interests, experience), the date you joined the network or your photos. Visitors who are not logged in, and members who have not confirmed their e-mail address, do not see your profile at all. A profile whose home is in a country where sex outside marriage or same-sex relations are criminalised is shown to nobody; it only counts in site-wide totals.
• This lasts until you claim your profile here or it is listed publicly as described above. From then on, logged-in members with a confirmed e-mail address see the full profile: texts only after our checks, and approved photos according to each photo’s visibility — photos for “all logged-in members” to every logged-in member, photos for “verified members” only to members who completed age verification and have Premium. The profile pictures we brought over from the network site were each checked by a person before anyone can see them, and they are shown only to logged-in members, never on public pages.
• Never shown to other members: your e-mail address and your exact location.

We use your e-mail address only to tell you about messages sent to you here, how to claim or remove your profile, and about changes like the one above. You can keep your profile off public pages or remove it from SwingersPlayLive at any time, without logging in, using the link in any of our e-mails, or by writing to contact@swingersplaylive.com; this does not affect your account on the original site. You can also enter the e-mail address of your network profile on our login page (the “Is this your profile from the SwingersPlay network?” link on a profile page leads there): we e-mail you a link to claim the profile, and then you can hide it from public pages or delete it. If a report about the profile is still being reviewed, it is hidden at once and deleted when the review is finished (see section 7).

Rolling replacement. Network profiles are gradually retired as new members join in each city: a new member’s sign-up retires at most one network profile, once per person. To enforce this, when you create your profile we keep a keyed hash of your e-mail address (a code from which the address cannot be read back; we do not store the address for this) and keep it even after you delete your account, so that deleting the account and signing up again does not retire another profile.

Legal basis. We rely on the consent you gave on the network site, whose current terms describe a member database shared across the operator’s sites (GDPR Art. 6(1)(a) and, because a lifestyle profile reveals information about your sex life, Art. 9(2)(a)). If you joined under an earlier version of those terms, or simply do not want your profile here, remove it at any time as described above. Withdrawing your consent does not affect processing before withdrawal.

5. Who we share data with

• Other members: your profile and approved photos, according to the visibility you choose. Public pages show only the username, member type, ages, city, a rounded distance, the activity period and the profile text (only if it contains no explicit words and no contact details) of members who are listed publicly — never photos, e-mail addresses or exact locations. Members who joined here choose whether they are listed; for network profiles see section 4.
• Service providers acting on our instructions (processors): hosting and databases, e-mail delivery, image moderation (Sightengine, see section 3), child-safety scanning services, age/ID verification providers, the delivery of the iPhone app’s notifications (Expo) and our payment provider. A current list is available on request.
• Google, if you pay for a plan in our Android app: to check, confirm or stop that purchase we send Google only the purchase reference Google gave us.
• Apple, if you pay for a plan in our iPhone app: Apple sends us signed records of the purchase and of its renewals, cancellation and refunds, and the app passes on the record Apple gave it. We send Apple nothing about you: for each purchase the app gives Apple’s payment screen only a random reference that we create, which Apple returns with the purchase so that we can link it to your account.
• Expo and Apple, if you turn on notifications in our iPhone app: Expo’s push service and Apple’s push notification service deliver them to your phone. For each notification they receive your phone’s push token, the text (that you have a new message, and who wrote it if you choose so, never the message text), a reference to the conversation so that a tap opens it, and your number of unread messages for the app icon. When notifications are on, the app also registers your phone directly with Expo’s push service: it sends Expo Apple’s push token for your phone, a random ID that the app creates once and keeps on your phone and our app’s identifiers (and, like any request over the internet, your phone’s IP address), and Expo returns the push token that we keep. The app renews this registration only while you are logged in with notifications on in the app: each time you open it, and when Apple gives your phone a new push token.
• Search engines: when your profile is listed publicly and its page may be indexed, we tell search engines that use the IndexNow protocol (for example Bing) the address of that page, so that they update their copy. We send only the address.
• Authorities, when the law requires it or to protect someone in danger — for example reports of apparent child sexual abuse material to NCMEC. See our law-enforcement page and our child safety standards.

We do not sell your personal data and we do not share it for cross-context behavioural advertising. We do not use advertising trackers.

6. International transfers

Some of our providers are located outside the European Economic Area, in particular in the United States. We transfer data only with appropriate safeguards: the EU-US Data Privacy Framework where the recipient is certified, or the European Commission’s Standard Contractual Clauses, with additional measures where needed. Ask us for a copy of the relevant safeguards.

7. How long we keep data

• Account, profile and messages: while your account exists. When you delete your account we delete or anonymize them, except where we must keep something longer as described below.
• Favorites, blocks, private-photo permissions and travel plans: until you remove them or delete your account.
• Profile views: 90 days (the period members can see their visitors), then deleted.
• Login sessions: 90 days from your last visit, renewed while you use the site; a session that has ended or expired is deleted 30 days later.
• Links we e-mail you (to confirm your address, log in or reset your password): deleted 7 days after they were used or expired.
• Copies of the e-mails we sent you (they contain your address): deleted 90 days after sending.
• What you did on the membership page (opened it, picked a plan, started or left a payment): 90 days. The reports to our administrators name no one; our copy of them is deleted 90 days after sending.
• Your phone’s push token (iPhone app): until you turn notifications off in the app or delete your account, and at most 180 days after the app last registered the phone (it does so each time you open it while you are logged in with notifications on). When you log out, the phone stops getting notifications for your account at once, and its token is deleted when the next notification for your account would have been sent, or at the end of that period. If you turn off the app’s notifications in iPhone Settings, the app removes the registration the next time you open it while you are logged in.
• Our hosting provider’s request logs (the address requested, including what you searched for, your IP address, your browser or app type and the time): kept for a short time to run and secure the service, then deleted automatically.
• Anti-abuse counters (no e-mail address): 2 days.
• Club and place suggestions: your e-mail address and the keyed hash of your IP address are erased 365 days after our decision; the venue details may stay on the site.
• Rejected or removed photos: kept for up to 183 days after the decision, then deleted.
• Material reported to NCMEC: preserved for at least 366 days as required by US law (18 U.S.C. 2258A(h)), in restricted storage.
• Records of reports and moderation decisions: as long as needed to handle complaints, legal claims and our legal obligations. Reports you made stay when you delete your account, without your e-mail address.
• Records an authority lawfully asks us to preserve (for example a profile and its login records as they were at the time of the request): for the preservation period, then deleted.
• If you ask us to delete a profile while a report about it, its photos or its messages is still open, or while material must be preserved for a child-safety report or at the lawful request of an authority, we hide the profile at once but delete it only when that review or preservation period is over, and we tell you so. The law allows this delay where data is needed for a legal obligation or for legal claims (GDPR Art. 17(3)(b) and (e)). For your own account this happens by itself: you are logged out at once, and the account is deleted automatically as soon as the review allows.
• The keyed hash of your e-mail address used for the rolling replacement (section 4): kept after your account is deleted; it contains no address.
• Payment records: as long as tax and accounting law requires.

8. Your rights

Depending on where you live you can ask to access, correct, delete or export your data, to restrict or object to processing, and to withdraw consent. Write to contact@swingersplaylive.com from your account’s e-mail address; we will answer within one month (GDPR) or 45 days (California), and may need to verify your identity. You can also complain to a data-protection authority — in Romania the ANSPDCP, or the authority where you live or work.

Deleting your account. You can delete your account yourself at any time, in the app or on the website (Account → Settings → Delete account), or by e-mail without logging in. Our account deletion page explains the steps, what is deleted and what we keep, and for how long.

9. US state privacy disclosures (including California CCPA/CPRA)

• In the last 12 months we collected the categories listed in section 2 (identifiers, customer records, commercial information, internet activity, approximate location, and sensitive personal information) for the purposes in section 3, from you and from your use of the service.
• We do not sell or share personal information, and we have no actual knowledge of selling or sharing data of anyone under 16 (our service is 18+ only).
• We use sensitive personal information only as needed to provide the service you request, for security and integrity, and as otherwise permitted by the California regulations — not to infer characteristics about you.
• You have the right to know, delete and correct your personal information, and not to be discriminated against for exercising these rights. An authorized agent may submit requests on your behalf with your signed permission.

Consumer health data (Washington, Nevada and similar laws). We do not ask for health information. If you choose to write about your sexual health (for example STI testing) in your profile or messages, it may be “consumer health data” under Washington’s My Health My Data Act. We use it only to show it to the members you choose, with your consent, never sell it, and you can delete it at any time by editing your profile or deleting your account.

10. Security

We use encryption in transit, hashed passwords, access controls, and we strip location metadata from photos. Photos are never public files: every view is checked against your visibility settings.

11. Children

SwingersPlayLive is for adults only. As soon as we learn that someone is under 18, we suspend the account and take the profile off the site. A person on our team then reviews it and deletes the account, keeping only what the law requires us to keep (for example material we must report to the authorities).

12. Cookies

We use only strictly necessary cookies, and in our apps only the strictly necessary storage described in What this policy covers. See our cookie policy.

13. Changes

We will tell you about significant changes to this policy before they take effect.