Privacy Notice

Last updated: 13 April 2026

Introduction

This Privacy Notice (“Notice”) explains how Trusted Media Limited (trading as “adultway”, and referred to throughout as “we”, “us” or “our”) handles personal data when you interact with our platform, applications, and related services (collectively, the “Platform”).

adultway is an AI-powered chat platform. Users communicate with AI-generated personalities via our website, WhatsApp integration, voice channels, and email. Interactions may include text messages, images, video content and other media.

We are committed to safeguarding your personal data. All information processed by adultway is encrypted at rest and in transit using AES-256 encryption and TLS 1.3. Our infrastructure is hosted on a platform that holds SOC 1 Type 2 and SOC 2 Type 2 certifications and complies with PCI DSS 4.0 under a shared responsibility model.

By accessing or using the Platform you acknowledge that you have read and understood this Notice. If you do not agree with any aspect of it, you should stop using the Platform immediately. Capitalised terms not defined here carry the meaning given in our Terms of Service.

Who We Are

For the purposes of applicable data protection legislation (including the UK General Data Protection Regulation and the Data Protection Act 2018), the data controller is:

Trusted Media Limited
27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
Company number: 08153782
ICO registration: ZC006299
Contact: hello@adultway.com

What Data We Gather

Data you supply to us

When you register, subscribe, make a purchase or otherwise engage with the Platform, you may provide us with:

• Your email address and chosen username;
• Billing and payment details (processed through our third-party payment providers);
• Content you create or share on the Platform, including chat messages, images, videos and other media (“User Content” as defined in the Terms of Service);
• Any correspondence you send to us, including support queries and feedback.

You are under no obligation to supply this data; however, certain features of the Platform may be unavailable without it.

Data gathered automatically

When you use the Platform, we (and our third-party service providers) may automatically record:

• Device and browser information (type, operating system, screen resolution);
• IP address and approximate geographic location derived from it;
• Unique device identifiers;
• Pages visited, features used, time spent and navigation paths;
• Referring and exit URLs;
• The version of the Platform you are using.

We use cookies and similar tracking technologies to collect some of this data. Full details are set out in our Cookies Notice.

Data from external sources

We may receive data about you from other sources, for example:

• Referrals from existing users;
• Social media platforms (such as when you interact with our profiles or log in via a third-party account);
• Third-party authentication providers (e.g. Google or Apple sign-in), where you choose to connect your account.

Linking a third-party account is entirely optional. You grant permission at the point of connection and may revoke it at any time through that third party’s settings. We may retain data previously collected even after you revoke access.

Legal Grounds for Processing

We rely on the following lawful bases under the UK GDPR when processing your personal data:

• Performance of a contract – processing that is necessary to fulfil our contractual obligations to you, including providing and administering the Platform.
• Consent – where we have obtained your explicit consent, for example for certain marketing communications or optional data sharing.
• Legitimate interests – processing that supports our legitimate business interests (such as improving the Platform, ensuring security, preventing fraud, and conducting analytics) provided those interests are not overridden by your rights and freedoms.
• Legal obligation – processing required to comply with applicable laws and regulations.

How We Use Your Data

We process personal data for the following purposes:

• Operating, maintaining and delivering the Platform and its features;
• Personalising your experience, including tailoring AI interactions;
• Training and improving our artificial intelligence and machine learning models;
• Communicating with you about your account, service updates, policy changes and features we think may interest you;
• Responding to your enquiries, feedback or support requests;
• Analysing usage trends to develop new products and improve existing ones;
• Detecting, investigating and preventing fraud, unlawful activity and misuse of the Platform;
• Ensuring the security and integrity of our systems and infrastructure;
• Complying with legal and regulatory obligations, enforcing our Terms of Service and protecting our rights or those of third parties.

We may combine data collected through the Platform with data obtained from other sources. We may also create aggregated or de-identified datasets derived from your data. Once data has been fully anonymised so that it can no longer identify you, it falls outside the scope of data protection law and we may use it for any lawful purpose, including research and marketing.

Who We Share Data With

We may disclose your personal data in the following circumstances:

• Group companies – entities that control, are controlled by, or are under common control with Trusted Media Limited, who will handle data consistently with this Notice.
• Service providers – trusted third parties who perform services on our behalf, including hosting, payment processing, analytics, fraud prevention, customer support, and marketing. These providers are contractually bound to process data only for specified purposes and in accordance with our instructions.
• Legal and regulatory authorities – where we are required to do so by law, regulation, court order, or governmental request.
• Protection and enforcement – where disclosure is reasonably necessary to protect the rights, property or safety of adultway, our users, or the public, or to enforce our Terms of Service and other agreements.
• Business restructuring – in connection with a merger, acquisition, sale of assets, reorganisation, or insolvency proceeding, where your data may be transferred as part of the transaction.
• User Content visibility – certain content or actions on the Platform may be visible to other users by design (for example, shared AI personalities or public profile information).
• With your direction or consent – we may share data with additional third parties where you have given consent or specifically instructed us to do so.

Analytics and Advertising

We use third-party analytics tools (such as Google Analytics) to understand how users interact with the Platform. These tools may collect data including the website you arrived from, pages viewed, time on site, and your IP address. The information is used solely for statistical analysis and to improve the Platform. You may opt out of Google Analytics by installing the Google Analytics Opt-Out Browser Add-on.

At the date of this Notice we do not serve third-party advertising on the Platform. Should this change in the future, we will update this Notice and provide details of how you can manage your advertising preferences. For further detail on how we use cookies and similar technologies, please refer to our Cookies Notice.

International Transfers

The Platform operates globally and your data may be transferred to, stored in, and processed in countries outside the United Kingdom. These countries may have data protection regimes that differ from UK law, and data may in certain circumstances be accessible to law enforcement and national security authorities.

Where we transfer personal data outside the UK or the European Economic Area to a country that has not been deemed to offer an adequate level of protection, we implement appropriate safeguards to protect your data, including:

• The UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (SCCs) approved by the European Commission, as applicable, which contractually oblige recipients to protect data to the standard required under UK and EU law;
• Technical and organisational measures including encryption, access controls, and regular security assessments;
• Where applicable, transfers to recipients in jurisdictions recognised as providing adequate data protection by the UK Secretary of State or the European Commission.

You may request a copy of the safeguards we rely on for international data transfers by contacting us at hello@adultway.com.

Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. The retention period for any given category of data depends on the nature of the data, why we hold it, and any applicable legal or regulatory requirements.

Once the applicable retention period expires, we will securely delete or anonymise your data. Anonymised data may be retained indefinitely for research and analytical purposes.

If an AI personality you have created and made publicly available achieves significant user engagement, we reserve the right to preserve that personality’s configuration and keep it active on the Platform even after you delete your account. This is to avoid disruption for the many users who may be actively interacting with it. If you intend to create public AI personalities, please avoid embedding identifiable personal information in their configuration.

Your Rights

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

• Access – you may request confirmation of whether we process your personal data and, if so, a copy of that data.
• Rectification – you may ask us to correct inaccurate or incomplete data.
• Erasure – you may ask us to delete your personal data where there is no compelling reason for its continued processing. Please note that we may be unable to comply in full where retention is required by law or for the establishment, exercise or defence of legal claims.
• Restriction – you may ask us to restrict the processing of your data in certain circumstances, for example while we verify its accuracy.
• Portability – where processing is based on consent or a contract and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format and have it transmitted to another controller.
• Objection – you may object to processing based on legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests. You may object to direct marketing at any time.
• Withdrawal of consent – where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Automated decision-making – you have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects, unless permitted by law.

You may exercise any of these rights by contacting us at hello@adultway.com. We will verify your identity before processing any request and will respond within one month. If your request is particularly complex or you have made multiple requests, we may extend this period by up to two further months, in which case we will inform you of the delay and the reasons for it.

You may also appoint an authorised agent to submit requests on your behalf. We will require written authorisation (or a power of attorney) from you before acting on any such request.

You will not be treated less favourably for exercising any of these rights.

Account Management

You may update, correct or delete your account information at any time through your profile settings. You may also deactivate your account from the same page.

If you unsubscribe from promotional emails (using the link provided in each email), we may still send you transactional or administrative messages relating to the Platform, such as notifications about changes to our policies.

Complaints and the Supervisory Authority

If you are unhappy with how we have handled your personal data, we encourage you to contact us first so we can try to resolve the matter. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) or, if you are located in the EEA, with your local data protection supervisory authority.

The ICO can be contacted at ico.org.uk or by telephone on 0303 123 1113.

Children and Young People

The Platform is not intended for anyone under the age of 18. Our Terms of Service expressly prohibit use by minors. If we become aware that we have collected personal data from an individual under 18, we will take prompt steps to close the relevant account and delete the data, except to the extent retention is required or permitted by law. For further information, please see our Underage Policy.

Security

We employ appropriate technical, organisational and administrative safeguards designed to protect your personal data against accidental loss, unauthorised access, disclosure, alteration or destruction. These measures include encryption, access controls, regular vulnerability assessments and staff training.

No method of electronic transmission or storage is entirely secure. Whilst we strive to protect your data, we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

External Links

The Platform may contain links to websites or services operated by third parties. We have no control over, and accept no responsibility for, the privacy practices or content of those third-party sites. We recommend that you review the privacy notice of any external site before providing personal data to it.

Regional and Supplementary Disclosures

United States – California

If you are a California resident, the California Consumer Privacy Act (“CCPA”) grants you additional rights. The categories of personal information we collect, the sources of that information, and how we disclose it are described in this Notice. In CCPA terms, the categories include: identifiers, financial information, commercial or transactional information, internet or electronic network activity information, general geolocation data, audio or visual information, other information you provide voluntarily through User Content, and inferences drawn from the above.

We may also collect “sensitive personal information” as defined by the CCPA, including account login credentials and any sensitive data you voluntarily include in User Content (for example, content revealing racial origin, religious beliefs, or sexual orientation). We do not use or disclose sensitive personal information beyond the purposes permitted by the CCPA.

We may use analytics services that result in the “sharing” (as defined by the CCPA) of online identifiers such as cookie data, IP addresses, and device identifiers with analytics partners. You may opt out of such sharing by adjusting your cookie preferences as described in our Cookies Notice. We do not knowingly “sell” or “share” the personal information of individuals under 16.

We do not respond to browser-level Do Not Track signals, as there is no universally accepted standard for how to interpret them.

United States – Nevada

Nevada residents may opt out of the sale of certain personal information to third parties. We do not currently sell personal information as defined by Nevada Revised Statutes Chapter 603A. If you wish to submit a do-not-sell request, please contact us at hello@adultway.com with the subject line “Nevada Do Not Sell Request”.

Changes to This Notice

We may revise this Notice from time to time to reflect changes in our practices, the Platform, or applicable law. The date at the top of this page indicates when the Notice was last updated. Where a change is material, we will provide you with reasonable notice (for example, by email or via a prominent notice on the Platform) before it takes effect. Your continued use of the Platform after any update constitutes your acceptance of the revised Notice.

Get in Touch

If you have any questions about this Notice, wish to exercise your rights, or have concerns about how we handle your data, please write to us at:

Trusted Media Limited
27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
Email: hello@adultway.com