Privacy policy

NaughtyEscort International of 1 Berkeley Street, London W1J 8DJ, United Kingdom is the controller of the personal data described here. Write to hello@naughtyescort.com for anything covered by this policy, including a deletion request.

This policy covers clients, visitors to this website, companions on our register, and anyone who applies to join it.

When you make an enquiry or a booking

Your name, email address, telephone number, the city, date, time, and duration you asked for, the occasion, and anything you chose to tell us in the free text fields. We also record the time you confirmed your age and accepted the terms.

Technical context attached to that enquiry

The notification sent to our concierge desk also carries the time of submission, your IP address, an approximate location derived from it by our hosting network, your browser and device type, your browser language and timezone, the page you submitted from, the website that referred you, and any campaign parameters in the link you followed. It does not go to your companion and it is not included in the copy we send you.

When you subscribe to the journal

Your email address and the time you gave consent. Nothing else.

When you use this website

Two first-party cookies recording that you confirmed your age and that you have seen the cookie notice. Standard server logs, including IP address, are kept briefly for security and rate limiting.

If you join the register as a companion

Identity documents checked in person, your written consent for the use of your name and photographs, your rates, your working days, your bank details for payment, and the bookings you have accepted.

We do not collect payment card details on this website, and no payment is processed through it. We do not use analytics, advertising, or third-party tracking cookies.

To arrange a booking you asked for

Performance of a contract, or steps taken at your request before one exists. Without a name and a way to reply we cannot arrange anything.

To brief your companion

Performance of a contract. Limited to your first name, the occasion, the venue, and whatever you asked us to pass on.

To keep companions safe

Legitimate interests. We hold the location and timing of a booking, and a record of who accepted it, so that a companion is never somewhere we cannot account for.

To prevent abuse of our forms

Legitimate interests. IP addresses are used to rate limit submissions and are not used to profile anyone.

To answer your enquiry sensibly, and to spot a pattern

Legitimate interests. The technical context above tells a concierge what time it is where you are and what language to reply in. It also lets us recognise repeat submissions from one source after a request has been declined, which matters for the safety of the people on our register. It is not used for advertising or profiling, and no automated decision is made from it.

To send you the journal

Consent, which you gave by ticking the box, and which you can withdraw from any email or by writing to us.

To meet legal obligations

Legal obligation. Accounting records and identity verification records are kept for the periods the law requires.

Inside the agency, your record is visible to the concierge team and to whoever administers the system. It is not visible to companions.

Your companion receives the first name you gave us, the occasion, the venue, and any briefing you asked us to pass on. They do not receive your address, your employer, your telephone number, or your email address unless you specifically ask us to share them.

Outside the agency, we use service providers for hosting, transactional email, and image storage. They process data on our instructions under written terms and may not use it for anything else. We do not sell personal data and we do not share it with anyone for marketing.

We will disclose data where we are legally required to, and where it is necessary to protect someone from harm. If we ever receive a request from law enforcement we will comply with it only to the extent the law requires.

We operate in ten cities across three continents, so arranging a booking can involve moving your details to the country the booking takes place in. Where data leaves the UK or the European Economic Area, we rely on an adequacy decision where one exists, and otherwise on standard contractual clauses with the recipient.

Enquiries that did not become bookings

Twelve months, then deleted.

Booking records

Six years from the date of the booking, because accounting and tax rules require it. After that they are deleted.

Journal subscribers

Until you unsubscribe, then the address is removed within thirty days.

Server logs

Thirty days.

Technical context inside a concierge notification

It lives in the notification email, so it is kept for as long as that email is. Enquiry notifications are deleted with the enquiry at twelve months. Booking notifications are held with the booking record for six years, because accounting rules require the booking itself to be kept. Ask us to delete your record and the notifications go with it.

Companion verification records

For as long as the companion is on the register, and for six years afterwards where required for legal record-keeping.

• Ask for a copy of what we hold about you.
• Ask us to correct anything inaccurate.
• Ask us to delete your record. We do this within thirty days, apart from anything we are legally required to keep, and you do not have to give a reason.
• Ask us to restrict how we use it, or object to our use of it where we rely on legitimate interests.
• Ask for your data in a portable format.
• Withdraw consent for the journal at any time.

Write to hello@naughtyescort.com to exercise any of these. We reply within thirty days and we do not charge for it. If you are unhappy with how we handled a request, you can complain to the Information Commissioner's Office in the UK, or to the supervisory authority where you live.

Your name and photographs are published only with your written consent. You can withdraw that consent at any time by writing to us, and the profile comes down. Withdrawal does not affect bookings already accepted.

Clients are never given your contact details, your address, or your legal name where it differs from your working name. You are not told which other companions a client has booked, and clients are not told which other clients you have accepted.

Identity documents are checked in person and the record we keep of that check is the minimum needed to show it happened.

This website is served over HTTPS with a strict content security policy. Administrative access requires a password stored as a hash and is limited to named accounts with defined roles. Public forms are rate limited and validated on the server.

No system is perfect. If we ever suffer a breach that is likely to affect your rights, we will tell you and the relevant supervisory authority within the time the law allows, and we will tell you what we know rather than waiting until we know everything.

When we change this policy we update the review date at the top. If a change materially affects how we use data we already hold, we will tell affected clients and subscribers directly rather than relying on this page.