POLICIES & TERMS

How We Use Your Data

Last updated: June 2026

1. Who We Are

is the data controller for the personal data described in this policy. We are incorporated in England and Wales. Our registered address and contact details are available at our helpdesk. If you have any questions about how we handle your data, please contact us before raising a complaint.

We are registered with the Information Commissioner's Office (ICO); our registration number is . You can verify our registration at ico.org.uk.

2. Personal Data We Collect

Depending on how you use our website, we may collect:

• Account data — email address, username, and account preferences when you register.
• Transaction data — order details, subscription tier, payment references, and correspondence related to purchases. We do not store full payment card details; card processing is handled by our payment processor.
• Usage data — pages visited, features used, device type, browser, IP address, and referring URLs, collected automatically via cookies and server logs.
• Communications — messages you send us via email or support channels.
• Content preferences — your membership tier and access history, which may indicate preferences for adult content. This is special category data under UK GDPR Article 9 — see Section 5 below.

We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently done so, please contact us immediately.

3. How We Use Your Data and Our Lawful Basis

We process your personal data only where we have a lawful basis to do so under UK GDPR Article 6:

• Performance of a contract (Art. 6(1)(b)) — to create and manage your account, process payments, fulfil orders, and deliver digital content you have purchased.
• Legitimate interests (Art. 6(1)(f)) — to maintain security, prevent fraud, improve our service, and comply with our legal obligations, where these interests are not overridden by your rights.
• Legal obligation (Art. 6(1)(c)) — to retain financial records as required by HMRC and respond to lawful requests from regulatory authorities.
• Consent (Art. 6(1)(a)) — for non-essential cookies and analytics (see Cookie Policy). You may withdraw consent at any time.

4. Special Category Data

Membership and access history on this platform may constitute data concerning a person's sex life, which is special category data under UK GDPR Article 9. We process this data only on the basis of your explicit consent (Art. 9(2)(a)), given when you create an account and accept these terms. You may withdraw this consent at any time by deleting your account, but note that withdrawal does not affect the lawfulness of processing before withdrawal.

5. Third Parties We Share Data With

We share your data only where necessary:

• Google LLC (Firebase) — our hosting, authentication, and database infrastructure provider. Operates as a data processor under a Data Processing Agreement. Firebase is certified under the UK–US Data Bridge and complies with the UK International Data Transfer Agreement (IDTA).
• CCBill LLC — our payment processing provider. CCBill processes payment data as an independent data controller under their own privacy policy. We receive only transaction references and status updates, not full card details.
• Google LLC (Google Analytics) — website analytics, subject to your cookie consent. See Cookie Policy.
• Legal authorities — where required by law, court order, or to protect the rights and safety of others.

We do not sell your personal data to any third party.

6. International Transfers

Our infrastructure providers (Firebase, Google Analytics) transfer data to the United States. We ensure these transfers are lawful by relying on the UK–US Data Bridge where applicable, and the International Data Transfer Agreement (IDTA) approved by the UK Secretary of State, supplemented where required by a transfer risk assessment. Google LLC participates in the UK–US Data Bridge and has published IDTA-compliant data processing terms.

7. How Long We Keep Your Data

• Account and subscription data — retained while your account is active, and for up to 12 months after closure to allow for disputes or reactivation.
• Financial and transaction records — retained for 6 years from the end of the relevant accounting period, as required by HMRC for VAT and corporation tax records.
• Dispute and complaint records — retained for 6 years from resolution, in line with the Limitation Act 1980.
• Consent records — retained for 3 years from the date consent was given or withdrawn.
• Analytics data — retained in accordance with Google Analytics default retention settings (up to 14 months for user-level data), subject to your cookie consent.

8. Your Rights

Under UK GDPR you have the following rights. You can exercise them by contacting us at . We will respond within one calendar month.

• Right of access — to obtain a copy of the personal data we hold about you.
• Right to rectification — to have inaccurate data corrected.
• Right to erasure — to have your data deleted where we no longer have a lawful basis to hold it (subject to legal retention obligations).
• Right to restrict processing — to ask us to pause processing while accuracy or lawfulness is in dispute.
• Right to data portability — to receive your data in a structured, machine-readable format where processing is based on consent or contract.
• Right to object — to processing based on legitimate interests, including profiling. We must stop unless we can demonstrate compelling legitimate grounds.
• Right to withdraw consent — where processing is based on consent, you may withdraw at any time without affecting prior processing.
• Rights related to automated decision-making — we do not make automated decisions with legal or significant effects about you.

9. Complaints

If you are unhappy with how we have handled your data, please contact us first. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at any time:

• Website: ico.org.uk/make-a-complaint
• Phone: 0303 123 1113

10. Changes to This Policy

We may update this policy periodically. Material changes will be notified by email or a prominent notice on the website. The "Last updated" date at the top of this page indicates when the policy was last revised. Continued use of the service after changes constitutes acceptance of the revised policy.

Terms of Use

Last updated: June 2026

1. Age Requirement

This website contains sexually explicit material. You must be 18 years of age or older to access any part of this service. By creating an account or accessing content you confirm that you are at least 18 and that it is legal to view adult content in your jurisdiction. We comply with the age assurance requirements of the Online Safety Act 2023 and reserve the right to request verification of age at any time.

If we reasonably suspect that a user is under 18, we will immediately suspend their access and delete their account without refund.

2. Your Account

You are responsible for keeping your login credentials confidential and for all activity that occurs under your account. You must notify us immediately at if you suspect unauthorised access. We may suspend or terminate accounts that breach these terms.

You may only create one account per person. Creating multiple accounts to circumvent a suspension or to abuse any free tier is a breach of these terms.

3. Membership and Digital Content

We offer a free Follower tier and a paid Subscriber tier. Paid subscriptions grant access to premium content and downloads as described on the pricing page at the time of purchase. We reserve the right to modify the content available under each tier with reasonable notice.

Digital content is delivered over the internet. You acknowledge that delivery speed and quality may be affected by factors outside our control, including your internet connection. We do not guarantee uninterrupted availability but will endeavour to maintain reasonable uptime.

4. Payments

All prices are displayed in the currency shown at checkout and are inclusive of VAT where applicable. Payment is processed by CCBill LLC, a third-party payment processor. By making a purchase you agree to CCBill's terms of service in addition to these terms.

We currently operate a manual payment confirmation process. Your order will be fulfilled upon confirmation of payment receipt. You will receive email confirmation of each successful payment.

5. Dispatch & Delivery of Physical Merchandise

All physical merchandise orders are dispatched within 3 business days of payment confirmation, in line with credit card association requirements. The 3-business-day period begins from the point at which we confirm receipt of payment — not from the time the order is placed. You will receive a dispatch notification by email once your order has shipped. Delivery timeframes vary by destination and carrier and are not guaranteed.

If your order has not been dispatched within this timeframe, please contact us at and we will investigate promptly.

6. Your Cancellation Rights (Consumer Contracts Regulations 2013)

If you are a consumer in the United Kingdom, you ordinarily have a 14-day right to cancel any contract entered into at a distance without giving a reason. However, under Regulation 37 of the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, the right to cancel does not apply to digital content that has been downloaded or where access has begun, provided you have given explicit prior consent to the supply beginning before the cancellation period expires and acknowledged that you lose your right to cancel as a result.

By ticking the acknowledgement at checkout, you consent to immediate access to digital content and acknowledge that you waive your 14-day cancellation right once that content has been accessed or delivered. If you have not accessed the content, your 14-day cancellation right remains in full. To cancel an unaccessed order, contact us at .

For physical merchandise, the standard 14-day cancellation right applies. Returned items must be in their original condition. Refunds will be issued within 14 days of receiving the returned item.

7. Digital Content Quality (Consumer Rights Act 2015)

Under the Consumer Rights Act 2015, digital content must be of satisfactory quality, fit for purpose, and as described. If digital content you have purchased does not meet these standards, you are entitled to a repair, replacement, or where these are not possible, a price reduction. Please contact us within 30 days of purchase to report a quality issue.

Our liability for faulty digital content is limited to the price paid. We are not liable for any indirect, consequential, or special losses arising from use of the content. Nothing in these terms affects your statutory rights under the Consumer Rights Act 2015.

8. Intellectual Property

All content on this website — including photographs, videos, graphics, text, and the Scarlett St. Claire brand — is owned by or licensed to and protected by copyright and other intellectual property laws.

Purchasing a subscription or downloading content grants you a personal, non-exclusive, non-transferable licence to access and view that content for your own private use only. You may not reproduce, redistribute, share, resell, or publish any content from this service, whether in full or in part, without our prior written consent. Breach of this clause may result in immediate account termination and legal action.

9. Acceptable Use

You must not use this service to:

• Share, redistribute, or commercially exploit any content without authorisation;
• Use automated tools, bots, or scripts to scrape, download, or access content;
• Attempt to circumvent any access controls, age verification, or security measures;
• Harass, impersonate, or harm any person;
• Transmit malicious code or interfere with the operation of the service;
• Engage in any activity that is unlawful under the laws of England and Wales.

10. Our Liability

We are not liable for any indirect, incidental, or consequential losses arising from your use of this service, including loss of data, loss of profits, or service interruptions, except where such liability cannot be excluded by law. Our total liability to you for any claim arising from your use of the service is limited to the amount you paid to us in the 12 months preceding the claim.

Nothing in these terms limits our liability for death or personal injury caused by our negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be limited by law.

11. Termination

We reserve the right to suspend or terminate your account at any time if you breach these terms. You may delete your account at any time. On termination, your right to access any content ceases immediately. We are not obliged to refund subscription fees for the remaining period unless the termination was caused by our material breach.

12. Changes to These Terms

We may update these terms from time to time. We will notify you of material changes by email or a notice on the website. Continued use of the service after the effective date of any changes constitutes your acceptance of the new terms. If you do not accept the revised terms, you should close your account.

13. Governing Law and Jurisdiction

These terms are governed by the law of England and Wales. Any dispute arising from or in connection with these terms shall be subject to the exclusive jurisdiction of the courts of England and Wales, without prejudice to any mandatory consumer protection rights you may have under the law of your country of residence.

If you are a consumer, you may also refer disputes to the Online Dispute Resolution (ODR) platform operated by the European Commission at ec.europa.eu/odr, though for UK residents the primary recourse is the courts of England and Wales or an approved ADR scheme.

Cookies & Tracking

Last updated: June 2026

1. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device, remember your preferences, and gather usage information. Similar technologies include local storage, session storage, and tracking pixels — this policy covers all such technologies.

2. Cookies We Use

We use two categories of cookies: those that are strictly necessary for the website to function, which do not require your consent; and those used for analytics, which we set only with your explicit consent.

3. Your Rights and Consent

Under PECR, we are required to obtain your prior, freely given, specific, informed, and unambiguous consent before placing any cookies that are not strictly necessary. The "Accept All" and "Reject All" options in our cookie banner are presented with equal prominence. Refusing non-essential cookies will not prevent you from using the core features of this website.

You may change your cookie preferences at any time by clicking "Cookie Settings" in the website footer or by using your browser's cookie controls. Please be aware that clearing cookies will also remove the record of your consent, and you will be asked again on your next visit.

4. Third-Party Cookies and Analytics

Google Analytics is operated by Google LLC, a US-based company. When you consent to analytics cookies, data about your visit (including a pseudonymous identifier derived from your IP address) is transferred to Google's servers in the United States. This transfer is covered by the UK–US Data Bridge and Google's IDTA-compliant data processing terms. Google does not use analytics data collected on our behalf to serve you advertisements. For more information, see Google's Privacy Policy.

5. Managing Cookies in Your Browser

You can also control cookies at the browser level. Below are links to guidance for common browsers:

• Google Chrome
• Mozilla Firefox
• Apple Safari
• Microsoft Edge

Note that disabling all cookies may prevent some features of this website from working correctly.

6. Changes to This Policy

We may update this Cookie Policy when we introduce new cookies or technologies, or when the regulatory guidance we follow changes. The "Last updated" date at the top of this section will reflect any revisions. We will seek fresh consent if we introduce new categories of non-essential cookies.

7. Contact Us

If you have any questions about our use of cookies, please contact us at .