Information under Articles 13 and 14 GDPR
Privacy policy
Last updated: 19 October 2026
This is a courtesy translation. In case of any discrepancy, the Italian version prevails.
Secret Sedux organises private nights for adults only. Taking part in events of this kind is sensitive information: that is why we collect only the data we need, show it only to those who need to see it and delete it when it is no longer needed. Here you will find, in plain words, what we process, why, for how long and how you can exercise your rights.
1Who processes your data
The data controller is:
[Full name or business name of the controller][Full address]
[Italian tax code or VAT number]
Email for privacy matters: [email address]
For any question about this policy, or to exercise your rights, write to the address above.
2What data we process
If you sign up (Sign up page)
- Profile data: first name and surname, email, phone number (optional), password (stored only in encrypted form, which no one can read), your declaration that you are 18 or over and the date of your consent.
- Questionnaire answers: who you are (man, woman, couple), age, country and province, how you heard about us, why you want to take part, experience of similar events and of the lifestyle, the swinger sites or apps you are on with your profile name (optional), orientation, what you expect, what you would like to see or try and the other answers you choose to give, optional contact details (Telegram) and an emergency contact.
- Photos (optional): up to 3 on your profile. Your browser resizes and re-encodes them before uploading, so data hidden in the file, such as GPS location, never reaches us.
- Membership application for the association, if you fill it in: full name, place and date of birth, tax code, address, email, phone, your signature (drawn in the box) and the date you signed. The association needs them to register you as a member; only the organisers can see them.
- Sign-in with Face ID, fingerprint or another passkey, if you turn it on: we receive only a public key and the name of the device. Your face and fingerprint stay on your phone and never reach us.
- Your profile status (under review, approved, not eligible) and the date of the review.
- The language in which you use your page (Italian or English: the one chosen with the IT/EN switch or, failing that, your phone’s language), so that emails and notifications reach you in the same language.
- The number of nights you have attended, not which ones: it lets the organisers see, as a statistic, how many guests come back. It is deleted with your profile.
- If the organisers or staff suspend your profile (blacklist): since when, who decided it, the reason they note for the organisers and any requests for reinstatement you make, with the message you write.
If you request to attend a night or receive an invitation
- Your request: the night, the option chosen (dinner and party, or party only), any note and any photos requested for that night.
- For guests on the list: name or nickname, phone number (optional), type (single man, single woman, couple), option, contribution, payment method and date, organisers’ notes.
- Your invitation: your personal code and QR, whether and when the invitation was sent and opened, and the times of entry, exit and any re-entry recorded at the door. Once the night has been anonymised, these remain only as numbers, without names, for statistics.
- Your rating of the night, if you choose to give one: the stars and comments on the venue, service, atmosphere, food, entertainment and games, parking and accessibility, and what you would improve.
No payments are made on the site: you pay outside the site, as the organisers tell you in the payment instructions. On the site we record only the amount, method and date of payment and any discount code (if you chose how to pay when the site allowed it, also that choice; for payments made with PayPal from the site when this was possible, also the transaction number); never card or bank account details.
If you design your night
The ideas for a night that you write on your page (Design your night): the name of the night, the theme, the venue, when, dinner and drinks, the dress code, the music, the shows, the guests, the contribution you have in mind and the story behind it, with the dates on which they were saved and sent. The organisers can mark an idea as read or as a source of inspiration (you will see this on your page) and add internal notes.
If you propose a collaboration (Collabora con noi page)
Name, city or province, the type of proposal and your answers to the form (for example availability, type of space, discipline, indicative fee), a link of your choice, optional email, phone number and Telegram, your declaration that you are 18 or over and the date of your consent. The organisers can add internal notes.
If you are on the staff
Name, username, role (and, for organisers, whether they handle the cash desk), encrypted password, any passkeys, sign-in sessions, which payments you have recorded, which nights you work at and, if you provide it, your availability for upcoming nights (with an optional note).
Technical data
- Session cookies that keep you signed in, and the data linking them to your account: they are described on the Cookies and preferences page.
- Your IP address, used only to limit sign-in attempts and repeated form submissions.
- If you turn on notifications on a device: the delivery address your browser gives us, the keys used to encrypt messages, the type of device (e.g. “iPhone · Safari”) and when the last notification arrived. The message travels encrypted through your browser’s notification service (Apple, Google, Microsoft or Mozilla), which cannot read it. Notifications to members are discreet: no names of nights on the lock screen.
- The data our hosting provider processes to run and protect the site (for example IP address and browser type in security logs).
We do not use analytics, advertising or profiling tools and we do not load third-party resources: fonts, images and code are hosted on our own site.
3Data concerning your sex life
Some answers to the questionnaire (for example your orientation or what you expect from a night) and, more generally, the very fact of signing up or taking part reveal information about your sex life. Under the GDPR these are special categories of personal data (Art. 9): we process them only with your explicit consent, which you give by ticking the relevant box and which we record together with the date. You can withdraw it at any time by deleting your profile or writing to us; withdrawal does not affect the lawfulness of the processing carried out before it.
4Why we process it and on what legal basis
| Purpose | Legal basis |
|---|---|
| Managing your profile and assessing whether you can take part in the nights | Explicit consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR) and steps taken at your request before participation (Art. 6(1)(b)) |
| Managing requests, the guest list, contributions, invitations and entry at the door | Performance of the participation agreement (Art. 6(1)(b)) and explicit consent for data concerning your sex life (Art. 9(2)(a)) |
| Sending you service emails: profile confirmation, payment instructions and deadline reminders, invitation, reminders of the night (the day before and on the day), a request to rate the night the day after, reminders to sign the membership application, password recovery | Performance of the agreement (Art. 6(1)(b)) |
| Registering you as a member of the association and keeping the signed membership application | Performance of the membership relationship you request (Art. 6(1)(b)) and the association’s legal obligations (Art. 6(1)(c)) |
| Collecting your ideas for nights (Design your night) as a source of inspiration | Consent (Art. 6(1)(a)): proposing an idea is optional |
| Collecting your ratings of the nights in order to improve the next ones | Consent (Art. 6(1)(a)): rating is optional |
| Assessing a collaboration proposal and getting back to you | Consent (Art. 6(1)(a)) and steps taken at your request (Art. 6(1)(b)) |
| Contacting the person you named in case of an emergency during a night | Vital interests of you or of other people (Art. 6(1)(d) and Art. 9(2)(c)) |
| Suspending a profile (blacklist) and alerting the organisers when someone signs up again with the email of a suspended profile | Legitimate interest in the safety and smooth running of the nights (Art. 6(1)(f)) |
| Protecting the site and accounts: sessions, limits on attempts, abuse prevention | Legitimate interest in security (Art. 6(1)(f)) |
| Complying with legal obligations and defending our rights | Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f) and Art. 9(2)(f)) |
Decisions on participation are taken by the organisers, who are people: there is no automated decision-making and no profiling.
5Mandatory and optional data
The required fields in the forms are needed to sign up, assess your participation and let you in: without them, we cannot proceed. You may choose not to give your phone number, Telegram, photos and the answers marked as optional.
6Who sees your data
- The organisers see profiles, answers, photos, requests, ratings and ideas for nights, collaboration proposals and the guest list. The emergency contact stays hidden until it is really needed.
- Door staff see only the guests who have paid for the nights they work at, with name, type, option, code and any notes for entry: no phone numbers, amounts, questionnaires or photos.
- Staff see what door staff see and, in addition, who has entered the night and, so that they can suspend a profile (blacklist), members’ names and type and whether they are already suspended: no emails, answers, photos or reasons for suspension.
- Other participants never see your data. The venue of the night appears only on paid invitations.
We do not sell or pass on your data to anyone. We may disclose it to the authorities only where the law requires it.
7Providers and transfers outside the EU
To run the site we rely on providers that process data on our behalf, as processors (Art. 28 GDPR), and only for the service they provide to us:
- Cloudflare, Inc. (United States): site hosting, database, photo storage and protection against attacks;
- the email delivery service: [Resend, Inc. (United States) or Sendinblue SAS – Brevo (France): state the one in use].
Where a provider processes data outside the European Economic Area, the transfer takes place with the safeguards provided for by the GDPR: an adequacy decision (EU-US Data Privacy Framework) or standard contractual clauses approved by the European Commission.
8How long we keep it
| Data | How long we keep it |
|---|---|
| Profile, questionnaire and profile photos | Until you delete your profile (you can do so at any time from your page) or the organisers delete it; at the latest [24 months] after your last sign-in or your last night. After deletion it remains only in the backup copies already made, for at most 12 weeks (see below). |
| Requests to attend and attached photos | Until the request is withdrawn, you leave the guest list or the night is anonymised. |
| Guest list (names, phone numbers, notes) and invitations | Until the night is anonymised, which happens automatically 30 days after the night. After that, only numbers and total takings remain, without names. From the second day after the night, the invitation no longer shows either the venue or the QR. |
| Ideas for nights (Design your night) | Until you delete them (you can do so at any time from your page) or the organisers delete them. If you delete your profile, drafts are deleted and ideas already sent remain without your name. |
| Ratings of the nights | With your name until the night is anonymised, together with the guest list; after that, the stars and comments remain without a name, for the record. They are deleted if you leave the guest list for that night. |
| Collaboration proposals | For as long as needed to assess them and get back to you, at the latest [12 months]; you can ask for them to be deleted sooner. |
| Suspended (blacklisted) profile that is then deleted | Only a hash of the email (SHA-256) remains, with the date of the suspension: it does not contain the address, but recognises it if someone signs up again with the same email. In that case the new profile stays under review like any other, and only the organisers see that the email had been suspended. The hash is deleted when the new sign-up is made and in any case 24 months after the deletion. |
| Staff accounts | For as long as the person is part of the staff. |
| Backup copies of the database | One copy a week, in a private storage space at our provider (Cloudflare R2); the last 12 are kept, about 3 months. They are used only to restore data in case of failure. A deleted profile or other deleted data remain in the copies already made until these are replaced, for at most 12 weeks. [The copies are encrypted: the key to open them is not kept on the site. Remove this sentence if backups are not encrypted] |
| Activity log of the restricted area (which staff member did what, with the name of the guest or member concerned) | 12 months. When the night is anonymised, the names of guests and members are replaced with “Anonimo” (“Anonymous”); when a profile is deleted, the member’s name is not kept. |
| Notifications on a device | Until you turn them off or sign out of your account on that device (or delete your profile); if the device no longer accepts them, they are deleted at the first failed delivery. |
| The night’s list on the door staff’s phone (to work without a connection: names, type, option, code, notes, whether the member is blacklisted, entries and exits with who recorded them, and the hash of the QR; no phone numbers, amounts or venue) | Until signing out of the account or the end of the session on that phone, at most a day and a half after the last update. |
| Staff availability for the nights | Until the night or the staff member’s access is deleted. |
| Sign-in sessions | 7 days for staff, 30 days for members, or until you sign out. |
| Password recovery codes | 20 minutes, and they can be used only once. |
| IP addresses for the limits on attempts | For the duration of the monitoring window (15 to 60 minutes), after which they are overwritten or deleted. |
If the law requires us to keep something for longer, we keep it only to comply with that obligation.
9How we protect it
- an always encrypted connection (HTTPS); only the public pages appear in search engines: the restricted area, invitations and personal data stay out of them;
- passwords stored only in encrypted form (PBKDF2), limits on sign-in attempts and sign-in with passkeys;
- session cookies that cannot be read by the page’s scripts and are sent only to our site;
- photos in private storage, with no public links, visible only to you and the organisers;
- link previews (WhatsApp, Telegram, iMessage…) with no name or venue;
- emails with a neutral subject line and text, which do not reveal what they are about.
10Other people’s data
If you sign up as a couple, the person filling in the profile declares that the other person is also 18 or over, has read this policy and consents to the processing of their data. If you give an emergency contact, let that person know that you have given us their name and number: we will use them only in an emergency during a night.
11Your rights
At any time you can ask us to:
- access your data and receive a copy of it (Art. 15);
- rectify it (Art. 16): you can change much of it yourself from your page;
- erase it (Art. 17): you can delete your profile yourself, with one tap;
- restrict its processing (Art. 18) or object to processing based on legitimate interest (Art. 21);
- receive it in a machine-readable format (portability, Art. 20);
- withdraw your consent, without affecting what was done before.
Write to [email address]: we will reply within one month. If you believe that the processing infringes the GDPR, you can lodge a complaint with the Garante per la protezione dei dati personali, the Italian data protection authority (garanteprivacy.it).
12Minors
The site and the nights are for adults only. We do not knowingly collect data from minors: if we find out that a profile belongs to a minor, we delete it.
13Changes
If we change the way we process data, we update this page and the date at the top; if the change is significant, we let members know.