Privacy Policy

Silk Lounge ("we", "us", or "our") respects your privacy. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information when you use our website, directory, messaging tools, and related services (the "Platform").

We comply with the New Zealand Privacy Act 2020 and its Information Privacy Principles (IPPs). By using the Platform, you acknowledge this Policy and our Terms & Conditions.

The data controller for personal information processed through the Platform is Silk Lounge, operating in New Zealand. Privacy enquiries, access requests, and corrections may be sent to compliance@silklounge.co.nz.

Depending on how you use the Platform, we may collect:

• Account identifiers: internal user ID, role (client, provider, or admin), and account status.
• Authentication data: passkey/WebAuthn credentials, device-linked login metadata, and session tokens.
• Contact details: email addresses and phone numbers used for verification, alerts, or account recovery.
• Profile and listing data: display name, alias, photos, service descriptions, preferences, availability, and location region.
• Verification data: Account Master Photo (held securely for fraud prevention); temporary ID document images processed in memory and not stored after verification.
• Messaging data: chat content, connection requests, booking confirmations, and related metadata.
• Transaction data: Silk Token purchases, balances, and billing records.
• Safety data: emergency contacts, check-in settings, safety reports, and emergency alarm events.
• Technical data: IP address, browser/device type, app logs, and usage analytics necessary to operate and secure the Platform.
• Location data: region or market hub selection for directory discovery (precise GPS is used only with your consent where enabled).

• Directly from you when you register, create a listing, purchase tokens, send messages, or contact support.
• Automatically through cookies, session storage, and server logs when you browse or use the Platform.
• From identity verification flows you initiate during onboarding or security checks.
• From safety features you configure, such as Silk Shield emergency contacts.

We use personal information to:

• Provide, maintain, and improve the Platform and its features.
• Verify age, identity, and eligibility to use adult-oriented services.
• Facilitate connections and secure messaging between clients and providers.
• Process Silk Token purchases and maintain wallet balances.
• Enforce our Terms, Safety Terms, and content standards.
• Investigate fraud, abuse, and safety incidents.
• Send service notifications (e.g. connection alerts) where enabled.
• Comply with legal obligations and respond to lawful requests.
• Protect the rights, property, and safety of users and the public.

Temporary ID scans: When you submit a New Zealand driver's licence or passport for age verification, the image is processed in memory using automated checks and is permanently deleted immediately after processing. It is not stored on our servers.

Account Master Photo: Your verification selfie is stored securely and is never displayed to other users, search engines, or the public. It is used solely for internal governance, fraud prevention, and account integrity.

Under the Privacy Act 2020, we process personal information where necessary to provide the Platform, with your consent (e.g. verification submissions, optional location), to comply with law, or where we have a legitimate interest that is not overridden by your privacy rights — such as preventing fraud and maintaining platform safety.

We may disclose personal information:

• To other users as part of normal Platform function (e.g. public listing details, messaging between connected parties).
• To infrastructure and service providers who assist us under confidentiality obligations (hosting, payment processing, SMS dispatch where enabled).
• To law enforcement, regulators, or courts when required by law or to protect safety.
• Within the Silk Lounge network to enforce safety policies against serious misconduct, as disclosed in our Terms.
• In connection with a merger, acquisition, or asset sale, subject to continued protection of your information.

We do not sell your personal information.

Our primary operations and data storage are oriented toward New Zealand. If we use overseas service providers, we take reasonable steps to ensure comparable privacy safeguards, consistent with IPP 12 of the Privacy Act 2020.

We retain personal information only as long as necessary for the purposes described in this Policy, unless a longer period is required by law.

• Active account data is retained while your account remains open.
• Messaging and connection records may be retained for safety, dispute resolution, and legal compliance.
• When you delete your account, public profile data is removed promptly. A 14-day cooling-off period applies before permanent purge of remaining records, consistent with IPP 11 and platform safety governance.
• Anonymised or aggregated data that cannot identify you may be retained indefinitely.

We implement technical and organisational measures appropriate to the sensitivity of the data we hold, including encryption in transit, access controls, passkey-based authentication, and restricted internal access to verification imagery. No system is completely secure; please protect your devices and report suspected breaches to compliance@silklounge.co.nz.

Under the Privacy Act 2020, you have the right to request access to and correction of personal information we hold about you. You may also:

• Withdraw consent where processing is consent-based (this may limit Platform features).
• Delete your account through in-app settings or by contacting us.
• Complain to the Office of the Privacy Commissioner if you believe we have breached the Privacy Act.

Submit requests to compliance@silklounge.co.nz with enough detail for us to verify your identity. We will respond within a reasonable timeframe.

We use session storage, local storage, and essential cookies to maintain login state, entry preferences, chat state, and theme settings. These are necessary for core Platform functionality. We do not use third-party advertising cookies on authenticated experiences.

The Platform is strictly for adults aged 18 and over. We do not knowingly collect personal information from minors. If you believe a minor has provided information to us, contact compliance@silklounge.co.nz immediately.

To report unlawful content or submit a copyright / takedown notice, email compliance@silklounge.co.nz with sufficient detail to identify the content and your claim. See our Contact page for more channels.

We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent revision. Material changes will be posted on this page. Continued use of the Platform after changes take effect constitutes acceptance of the updated Policy.

Privacy Officer / Compliance: compliance@silklounge.co.nz
General enquiries: admin@silklounge.co.nz
Billing: billing@silklounge.co.nz