Privacy Notice — Sapphic Sphere

1. About this Notice

This Privacy Notice explains how The Big Small Talk LLC, trading as Sapphic Sphere (“Sapphic Sphere”, “we”, “us” or “our”), collects, uses, stores, shares and protects personal information relating to:

visitors to our website;
people who join a waitlist or mailing list;
people referred to Sapphic Sphere;
membership applicants;
unsuccessful applicants;
current and former members;
event attendees;
people who contact us;
people who make reports or complaints; and
other individuals whose personal information is lawfully processed through Sapphic Sphere.

Sapphic Sphere currently operates on a referral-only membership basis.

We do not currently use third-party identity verification, facial recognition, biometric verification or routine identity-document checks as part of the membership process.

If we introduce identity, age or biometric verification in future, we will update this Notice before that processing begins and provide applicants with the relevant information at the point of collection.

This Notice should be read alongside:

the Membership Eligibility and Admission Policy;
the Terms of Membership and Sale;
the Community Standards, Safety, Reporting and Appeals Policy; and
the Cookie Notice.

WHO IS RESPONSIBLE FOR YOUR INFORMATION?

2. Data controller

Unless stated otherwise, the organisation responsible for determining why and how Sapphic Sphere personal information is processed is:

The Big Small Talk LLC
trading as Sapphic Sphere

A United States limited liability company.

Business mailing address:
2333 Brickell Ave D1-92, Miami, Florida 33129, United States

Privacy email:
privacy@sapphicsphere.com

General support email:
support@sapphicsphere.com

Sapphic Sphere is operated from the United Kingdom and offers services only in territories currently approved for membership.

Where another service provider acts as an independent controller for its own purposes, that provider is separately responsible for the processing it controls and will provide its own privacy information.

OUR PRIVACY PRINCIPLES

3. How we approach privacy

Sapphic Sphere is intended to be a privacy-conscious membership community.

We aim to:

collect only information that is genuinely necessary;
explain why information is required before collecting it;
treat membership and eligibility information as sensitive;
keep private eligibility information separate from ordinary member profiles where practicable;
restrict access to sensitive information;
avoid collecting identity documents unless genuinely necessary;
never require intrusive evidence of sexual behaviour;
avoid using sensitive eligibility information for advertising;
give members appropriate access, correction and deletion rights;
use proportionate security measures;
review higher-risk processing before introducing it; and
comply with applicable privacy laws in the territories where Sapphic Sphere operates.

No online service can guarantee absolute security, but we aim to minimise unnecessary collection and exposure of sensitive information.

REFERRAL-ONLY MEMBERSHIP

4. How referrals work

Sapphic Sphere currently accepts membership applications through referral.

Where possible, the referring member should provide the prospective applicant with a referral link, invitation code or other invitation mechanism so that the prospective applicant provides her own information directly to Sapphic Sphere.

We ask members not to provide unnecessary personal or sensitive information about another person when making a referral.

A referral does not guarantee admission.

The referred person must still satisfy the Membership Eligibility and Admission Policy and complete her own application.

We may record:

the fact that a referral was made;
the identity or member reference of the referring member;
the date of the referral;
the referral code or invitation reference;
the outcome of the referral; and
limited information necessary to prevent referral abuse or duplicate applications.

We will not ask a referring member to provide details of another person’s sexual history, medical history or other unnecessary sensitive information.

INFORMATION WE COLLECT

5. Account and contact information

We may collect:

name;
email address;
username;
password or authentication credentials;
country and region of residence;
account creation date;
membership status;
communication preferences;
referral information; and
account-security information.

Where possible, passwords are handled through secure authentication systems and are not visible to Sapphic Sphere administrators.

6. Application and eligibility information

Because Sapphic Sphere is a selective membership community, we collect information needed to determine whether an applicant meets the published eligibility criteria.

This may include:

confirmation that you are aged 18 or over;
ordinary country, territory or US state of residence;
your declaration concerning female sex;
confirmation that you identify and live as a woman;
your declaration that your sexual orientation is lesbian or bisexual;
your acceptance of the membership purpose;
application answers;
referral details;
eligibility-review notes;
admission, waitlist or rejection status;
appeal information; and
records showing which version of the Membership Eligibility and Admission Policy you accepted.

We do not currently require routine government-issued identity documents as part of the normal referral-only admission process.

We do not ordinarily require:

evidence of sexual activity;
details of previous sexual partners;
intimate photographs;
genetic testing;
physical examination;
unnecessary medical records; or
disclosure of a Gender Recognition Certificate or equivalent document.

Sexual orientation is assessed through the applicant’s own good-faith declaration, not through evidence concerning intimate behaviour.

SEXUAL-ORIENTATION INFORMATION

7. Special-category information

Information concerning sexual orientation receives enhanced legal protection in many jurisdictions.

For UK applicants and members, sexual-orientation information is special-category personal data under UK data-protection law.

Sapphic Sphere processes this information because lesbian or bisexual sexual orientation is an essential membership criterion.

Where UK law applies, we will identify:

an ordinary lawful basis for processing under Article 6 of the UK GDPR; and
a separate Article 9 condition permitting the processing of special-category information.

For the principal sexual-orientation eligibility declaration, Sapphic Sphere intends to rely on explicit consent where appropriate.

The application process will therefore contain a separate affirmative consent relating specifically to sexual-orientation information.

That consent will not be bundled with:

acceptance of the Terms of Membership;
subscription payment;
marketing consent; or
cookie consent.

You may withdraw consent where consent is the basis or condition relied upon.

However, where information about sexual orientation is objectively necessary to assess or administer eligibility for Sapphic Sphere, withdrawal may mean that we cannot complete an application or continue membership.

Withdrawal does not make earlier lawful processing unlawful.

We may retain a minimum record where necessary to comply with law or establish, exercise or defend legal claims.

8. Membership itself may reveal sensitive information

Even if sexual orientation is not displayed publicly on a profile, membership of a community specifically for lesbian and bisexual women may reveal or strongly imply information about a person’s sexual orientation.

We therefore treat the following with particular care:

applicant lists;
member lists;
referral records;
membership directories;
event attendance associated with Sapphic Sphere;
eligibility records; and
certain membership communications.

Members must also respect one another’s privacy under the Terms of Membership and Community Standards.

AGE AND IDENTITY

9. Current age approach

Sapphic Sphere is for adults aged 18 or over.

Applicants must confirm that they meet the minimum age requirement.

Because membership is currently referral-only, Sapphic Sphere does not currently operate routine third-party age or identity verification.

Where there is a genuine and proportionate reason to question whether an applicant meets the minimum age requirement or whether an account is authentic, Sapphic Sphere may request additional clarification.

Any such request will be limited to what is reasonably necessary.

We will not collect identity documents merely because they might be useful.

10. Future verification services

Sapphic Sphere may introduce identity or age verification in future if it becomes necessary for:

community safety;
fraud prevention;
territorial compliance;
payment-provider requirements;
legal obligations; or
expansion beyond the referral-only model.

If this happens, we will update this Privacy Notice before implementation.

Before any applicant is asked to use a verification provider, we will explain:

the identity of the provider;
what information will be collected;
why verification is required;
whether photographs or biometric processing are involved;
the provider’s role;
relevant retention periods;
international transfers;
any consent required; and
any alternative verification process available where required.

Sapphic Sphere will not introduce biometric verification without an appropriate legal and privacy assessment.

PROFILE AND COMMUNITY INFORMATION

11. Member profile information

Members may choose or be required to provide information such as:

profile photograph;
display name or nickname;
biography;
interests;
approximate location;
relationship status where voluntarily provided;
hobbies;
profession or industry;
groups joined;
events attended;
networking preferences; and
other profile information.

Your profile privacy settings determine which information is visible to other members where the platform provides those controls.

Do not include information in your profile that you do not want visible to the audience shown by the relevant privacy setting.

Sapphic Sphere does not use profile information to provide romantic compatibility matching or matchmaking services.

12. Posts, messages and community activity

When you use Sapphic Sphere, we may process:

posts;
comments;
reactions;
uploaded photographs;
video or audio;
group activity;
event activity;
connection requests;
messages;
reports;
moderation history; and
other member-generated content.

Private messages are not treated as public content merely because they are hosted through the platform.

However, messages may be processed or reviewed where:

a participant reports them;
security systems detect suspected abuse or malicious activity;
access is necessary to investigate a serious safety issue;
disclosure is required by law; or
limited technical processing is required to provide the messaging service.

We will not describe messaging as end-to-end encrypted unless that is technically true.

PAYMENTS

13. Subscription and transaction information

When you purchase membership or another paid Sapphic Sphere service, we may process:

name;
billing address;
email address;
membership plan;
amount;
currency;
transaction date;
payment status;
refund information;
tax information;
partial payment-card identifiers;
payment-provider customer or transaction reference; and
chargeback information.

Complete payment-card details are ordinarily processed by the payment provider rather than stored by Sapphic Sphere.

Payment provider: Stripe or another provider identified at checkout.

The payment provider’s own privacy notice applies to processing for which it acts as an independent controller.

EVENTS

14. Event information

Where you register for or attend an event, we may process:

name;
member account;
contact details;
ticket information;
attendance;
accessibility requests;
emergency contact details where genuinely necessary;
dietary information where necessary;
event communications;
photographs or recordings where a suitable lawful basis exists; and
incident information.

Some event information may reveal health, religion or other sensitive characteristics.

We will collect only information reasonably necessary for the relevant event.

SAFETY, MODERATION AND COMPLAINTS

15. Safety and moderation information

We may process information concerning:

reports;
complaints;
alleged rule breaches;
moderation decisions;
appeals;
warnings;
account restrictions;
harassment or stalking reports;
fraud;
safety concerns;
evidence submitted by members;
alleged unlawful conduct; and
communications with regulators, police or legal advisers.

Reports can contain personal or sensitive information concerning several individuals.

Members should provide only information reasonably relevant to the issue being reported.

Access to moderation information is limited to people who require it for legitimate safety, legal or administrative purposes.

TECHNICAL INFORMATION

16. Device, log and security information

When you access Sapphic Sphere, we or our providers may automatically process:

IP address;
browser type;
operating system;
device type;
login times;
account activity;
session information;
security events;
approximate geographic information derived from IP address;
cookie identifiers;
referral information;
error information; and
technical diagnostic information.

This information may be used for:

authentication;
security;
fraud prevention;
territorial controls;
troubleshooting;
performance;
analytics where permitted; and
protecting the service.

COOKIES

17. Cookies and similar technologies

Sapphic Sphere may use:

Strictly necessary technologies

For purposes including:

login;
authentication;
security;
session management;
subscription administration; and
remembering essential settings.

Optional technologies

These may include:

analytics;
performance measurement;
embedded media; and
marketing technologies.

Where applicable law requires consent, optional cookies will not be activated before the user has made the relevant choice.

Further information will be contained in the Cookie Notice.

MARKETING

18. Marketing communications

If you subscribe to newsletters, launch alerts or promotional communications, we may collect:

name;
email address;
preferences;
consent records;
subscription date;
engagement information where legally permitted; and
unsubscribe status.

Marketing consent is separate from membership eligibility.

You may unsubscribe from optional marketing without cancelling membership.

Sapphic Sphere does not intend to use private eligibility information to target behavioural advertising.

WHY WE USE PERSONAL INFORMATION

19. Purposes and expected UK lawful bases

Where UK data-protection law applies, the principal purposes and expected lawful bases include:

Referral administration

Purpose: Administer invitations and prevent referral abuse.

Article 6 basis: Legitimate interests in operating a controlled referral-based membership community.

Membership application

Purpose: Receive and administer an application and take steps requested before entering a membership contract.

Article 6 basis: Steps necessary before entering into a contract and, where relevant, legitimate interests.

Membership eligibility

Purpose: Assess whether an applicant meets the published criteria.

Article 6 basis: Steps before entering a contract and legitimate interests.

Special-category condition for sexual orientation: Explicit consent where appropriate.

Providing membership

Purpose: Operate accounts, groups, messaging, events and membership services.

Article 6 basis: Performance of the membership contract.

Payments

Purpose: Collect subscriptions, administer refunds and maintain accounting records.

Article 6 basis: Contract and legal obligations.

Community safety and moderation

Purpose: Investigate reports, enforce rules, prevent abuse and protect members.

Article 6 basis: Legitimate interests and, where applicable, legal obligations.

Security and fraud prevention

Purpose: Secure accounts, identify suspicious activity and prevent misuse.

Article 6 basis: Legitimate interests and legal obligations where applicable.

Legal and regulatory compliance

Purpose: Respond to lawful requests and exercise legal rights.

Article 6 basis: Legal obligation and/or legitimate interests.

Accessibility

Purpose: Provide reasonable adjustments and accessible services.

Article 6 basis: Legal obligations and legitimate interests.

Where health information is processed, an additional special-category condition will be identified.

Optional marketing

Purpose: Send promotional communications.

Article 6 basis: Consent or another lawful basis permitted by applicable direct-marketing law.

Optional analytics

Purpose: Understand and improve use of the service.

Article 6 basis: Consent where required for the technology used, or legitimate interests where lawful.

LEGITIMATE INTERESTS

20. Our legitimate interests

Where we rely on legitimate interests, these may include:

operating a genuine referral-only membership model;
maintaining a selective community;
preventing misuse of referral links;
preventing fraud;
protecting members;
enforcing community rules;
securing accounts;
maintaining reliable records;
defending legal claims; and
improving service reliability.

We consider whether our interests are overridden by the rights and interests of the people concerned.

Legitimate interests are not treated as a blanket justification for intrusive sensitive-data processing.

AUTOMATION

21. Automated processing

Some providers may use automated systems for:

spam detection;
fraud indicators;
account security;
payment fraud;
moderation triage; or
technical threat detection.

Sapphic Sphere does not intend to determine final membership eligibility by making automated inferences concerning sexual orientation or sex.

Where an automated result has a significant effect on a member or applicant, human review will be available where required by law or reasonably appropriate.

WHO RECEIVES INFORMATION?

22. Service providers

We may provide necessary information to providers supporting:

community hosting;
payment processing;
website hosting;
email delivery;
customer support;
security;
analytics;
events;
video or audio services;
legal compliance; and
professional advice.

Current launch providers should be listed here once confirmed:

Community platform: Mighty Networks
Payment processing: Stripe
Business email: [insert provider]
Marketing email: [insert provider]
Website/hosting: [insert provider]
Analytics: [insert if used]

There is currently no third-party identity-verification provider.

Providers should receive only the information reasonably required for their function.

23. Other members

Information you choose to include in your profile or post within the community may be visible to other members according to the relevant privacy settings.

Sapphic Sphere does not make private application declarations or internal eligibility-review notes visible to ordinary members.

24. Legal disclosures

We may disclose personal information where reasonably necessary:

to comply with law;
in response to a valid court order;
to respond to an authorised regulator;
to report or investigate suspected crime;
to protect vital interests;
to establish, exercise or defend legal rights;
to prevent serious harm; or
as part of a legitimate business sale or restructuring subject to appropriate safeguards.

Sensitive member information will not be disclosed merely because somebody asks for it.

WE DO NOT SELL ELIGIBILITY INFORMATION

25. Sensitive data and advertising

Sapphic Sphere does not sell or rent:

sexual-orientation declarations;
sex-eligibility information;
application information;
referral records identifying sensitive eligibility characteristics; or
private membership-review information.

We do not use private eligibility information for unrelated behavioural advertising.

If a future practice would constitute regulated sale or sharing under an applicable law, we will update this Notice and provide any legally required choice before introducing it.

INTERNATIONAL DATA TRANSFERS

26. Where information may be processed

The Big Small Talk LLC is based in the United States, and some service providers may process information in the United States or other countries.

Personal information may therefore be processed outside the country where you live.

Where international-transfer law applies, Sapphic Sphere will use an appropriate lawful transfer mechanism.

For UK personal information, mechanisms may include:

UK adequacy regulations;
the UK Extension to the EU-US Data Privacy Framework where applicable;
the UK International Data Transfer Agreement;
the UK Addendum to approved contractual clauses; or
another lawful mechanism.

Where a transfer requires an assessment of risks or safeguards, that assessment will be completed.

Additional care will be taken with sensitive membership information.

RETENTION

27. How long we retain information

We keep information only for as long as reasonably necessary for:

the purpose for which it was collected;
membership administration;
referral administration;
fraud prevention;
safety;
accounting and tax;
legal obligations; and
establishing, exercising or defending legal claims.

Retention periods are reviewed periodically.

Information may be anonymised where appropriate.

28. Indicative retention periods

Waitlist information

Until you unsubscribe or for up to 24 months after your last meaningful interaction, whichever occurs first.

A minimal suppression record may be retained to ensure that marketing preferences are respected.

Referral information

Routine referral records may normally be retained for up to 12 months after the application process concludes.

A minimal referral-history record may be retained longer where reasonably necessary to prevent abuse or repeated circumvention.

Unsuccessful applications

Ordinary application information will normally be retained for up to 12 months after the final decision or appeal.

Longer retention may occur where necessary for a live complaint, fraud investigation or legal claim.

Eligibility declarations

For accepted members: during active membership and for a reasonable period afterwards.

A minimum audit record may be retained where necessary to demonstrate that admission rules were applied consistently or to defend legal rights.

Member account and profile

For the duration of membership.

Following account deletion, ordinary active-account information will normally be removed or deactivated within 30 days, subject to information that must legitimately be retained.

Technical backups may persist for up to 90 days before being overwritten.

Payment and accounting records

Normally up to six years, or longer if required by applicable accounting, tax or legal rules.

Moderation and safety information

Routine cases: normally up to three years after closure.

Serious safety, fraud or legal matters may be retained longer where necessary and proportionate.

Support and complaint records

Normally up to three years after closure, unless longer retention is reasonably necessary.

Technical security logs

Normally up to 12 months, unless a particular security incident requires longer retention.

Event records

Ordinary attendance information: normally up to two years.

Financial event records may be retained for the applicable accounting period.

SECURITY

29. How we protect information

Safeguards may include:

encrypted transmission;
encryption at rest where supported;
multi-factor authentication;
role-based administrator access;
least-privilege permissions;
secure password handling;
access logging;
vendor review;
contractual confidentiality;
data minimisation;
separation of eligibility information from ordinary profile information;
incident-response procedures; and
backup and recovery controls.

Access to sexual-orientation and eligibility information will be restricted to authorised people who genuinely require it.

Ordinary moderators should not automatically have access to sensitive application information.

DATA BREACHES

30. Security incidents

If we become aware of a personal-data breach, we will:

investigate;
contain the incident where possible;
assess the risk to affected people;
document the incident;
notify relevant service providers where necessary;
notify regulators where legally required; and
notify affected individuals where legally required.

Because membership of Sapphic Sphere may reveal sensitive information concerning sexual orientation, we will take that into account when assessing the seriousness of any breach.

YOUR RIGHTS

31. UK data-protection rights

Where UK GDPR applies, you may have rights including:

access;
rectification;
erasure;
restriction;
objection;
data portability;
withdrawal of consent; and
rights relating to certain automated decision-making.

These rights are not absolute in every circumstance.

We may retain limited information where lawfully required or reasonably necessary to establish, exercise or defend legal claims.

32. US privacy rights

Privacy rights vary between US states.

Where a state privacy law applies to Sapphic Sphere, you may have rights including:

access;
correction;
deletion;
portability;
restrictions concerning sale or sharing;
restrictions concerning targeted advertising;
rights relating to sensitive information; or
appeal rights.

State-specific notices will be introduced where required before Sapphic Sphere opens membership in the relevant state.

The company’s place of organisation does not remove mandatory privacy rights applicable in another approved state.

33. Other approved territories

Members in other approved territories may have different or additional privacy rights.

Mandatory local rights prevail where applicable.

EXERCISING YOUR RIGHTS

34. Privacy requests

To exercise a privacy right, contact:

privacy@sapphicsphere.com

Please describe the request you wish to make.

We may need to verify your identity before fulfilling some requests, but verification will be proportionate.

We will respond within the time required by applicable law.

35. Sexual-orientation information

Where we rely on explicit consent to process sexual-orientation information, you may withdraw that consent by contacting:

privacy@sapphicsphere.com

Withdrawal does not affect processing that was lawful before withdrawal.

Because sexual orientation is part of the membership eligibility criteria, we may be unable to complete an application or continue providing membership where we can no longer lawfully process the minimum eligibility information required.

Before taking such action, we will consider whether another lawful basis or condition legitimately applies.

CHILDREN

36. Adults only

Sapphic Sphere membership is for people aged 18 or over.

We do not knowingly offer member accounts to children.

Because the current model is referral-only, we rely initially on:

referral controls;
applicant age declaration;
account monitoring; and
proportionate follow-up where genuine concerns arise.

If we reasonably believe an applicant or member may be under 18, we may restrict access while the matter is reviewed.

We may introduce stronger age-verification controls in future if required.

CHANGES TO THIS NOTICE

37. Updates

We may amend this Notice because of:

changes in law;
regulatory guidance;
new features;
new providers;
expansion into new territories;
changes to referral processes;
future introduction of identity verification;
security improvements; or
changes in processing practices.

The current version and effective date will be displayed at the top.

Where a material change affects existing sensitive information, additional notice or new consent will be obtained where required.

Sapphic Sphere will not introduce biometric identity verification merely by silently changing this Notice. Applicants will receive specific information before any such processing begins.

COMPLAINTS

38. Contacting Sapphic Sphere

Questions or complaints about privacy should be sent to:

Sapphic Sphere Privacy
The Big Small Talk LLC
2333 Brickell Ave D1-92, Miami, Florida 33129, United States

Email:
privacy@sapphicsphere.com

39. UK regulator

Where UK data-protection law applies, you may also complain to the:

Information Commissioner’s Office (ICO)

You do not have to complain to Sapphic Sphere before approaching the ICO.

40. Other regulators

Members in other approved territories may have the right to complain to a relevant privacy regulator, attorney general or data-protection authority.

Where required, territory-specific notices will identify the appropriate authority.

APPENDIX 1 APPLICATION PRIVACY NOTICE — SHORT FORM

How we use your application information

The Big Small Talk LLC, trading as Sapphic Sphere, uses the information you provide to:

administer your referral and application;
assess membership eligibility;
prevent misuse and fraud;
contact you about your application; and
administer membership if you are accepted.

Your application includes information about your sexual orientation. This is sensitive information and, where UK data-protection law applies, is special-category personal data.

Sapphic Sphere does not currently use third-party identity or biometric verification as part of the standard referral-only application process.

Please read the full Privacy Notice before continuing.

Private eligibility information is not sold or used for unrelated behavioural advertising.

APPENDIX 2

Where explicit consent is the applicable Article 9 condition, present this as a separate unticked choice:

☐ I explicitly consent to The Big Small Talk LLC, trading as Sapphic Sphere, processing information about my sexual orientation for the purpose of assessing and administering my application and membership as described in the Privacy Notice. I understand that I may withdraw my consent, but Sapphic Sphere may be unable to assess or continue my membership where this information is necessary to administer the membership eligibility criteria.

Record:

date and time;
applicant identifier;
exact consent wording;
Privacy Notice version;
Membership Eligibility and Admission Policy version; and
method by which consent was given.

APPENDIX 3 REFERRAL PRIVACY NOTICE — SHORT FORM

Display wherever an existing member sends or generates a referral:

Referring someone to Sapphic Sphere

Please refer only someone you genuinely believe may be interested in Sapphic Sphere.

Do not provide us with unnecessary information about the person you are referring.

In particular, do not submit:

details of her sex life;
medical information;
private correspondence;
identity documents; or
other sensitive information.

Where possible, send the person your referral link so that she can decide whether to apply and provide her own information directly to Sapphic Sphere.

A referral does not guarantee membership.

APPENDIX 4 MEMBER PRIVACY REMINDER

Protecting one another’s privacy

Membership of Sapphic Sphere may itself reveal sensitive information about a person.

Do not publish or share another member’s:

membership status;
private profile;
messages;
photographs;
identity;
contact information; or
screenshots from private spaces

outside Sapphic Sphere without appropriate permission.

Exceptions may apply where information must lawfully be reported to police, regulators, safeguarding bodies or professional advisers.

See the Terms of Membership and Community Standards for the full rules.