Privacy & Data
Discretion is the principal asset of the Agency. We process personal data in line with the UK GDPR and the Data Protection Act 2018, and retain only what is required.
Data controller
The data controller is BENEROUITH & CO MEDIA LTD, a company registered in England & Wales under company number 17212781, with registered office at 16 Pentland Close, London, England, N9 0XN. Contact the controller at benerouithcoltd@gmail.com.
What we collect
- From clients: a name and contact, the details necessary to confirm a booking, and any reference provided during screening.
- From companions: identity verification, right-to-work documentation, contact details, professional photography, and bank details for fee remittance.
- From this website: nothing automated. We do not use Google Analytics, Meta Pixel, advertising trackers or behavioural cookies.
Lawful basis (UK GDPR Art. 6)
- Booking enquiries — performance of a contract you have requested with us, and our legitimate interest in operating the Agency.
- Companion verification — legal obligation (Modern Slavery Act 2015, immigration and employment law) and our legitimate interest in safeguarding.
- Marketing imagery and biographies — explicit written consent from the companion concerned, withdrawable at any time.
How we store it
All personal records are stored on encrypted, UK/EU-hosted infrastructure. Access is limited to the Agency principals. Records are not sold or shared with third parties beyond what is strictly necessary (for example payment processors and the Agency's solicitors).
Retention
Client correspondence is retained for 12 months from last contact, then deleted. Verification documents are retained for as long as the companion is represented, and for 24 months after representation ends.
Your rights
Under UK GDPR you have the right to (i) request a copy of your personal data, (ii) correct inaccuracies, (iii) request erasure, (iv) restrict processing, (v) data portability, and (vi) object to processing. We respond within one calendar month.
If you are not satisfied with our response, you may complain to the Information Commissioner's Office (ico.org.uk · 0303 123 1113).
Cookies
We do not use analytics, advertising or third-party tracking cookies. No cookie consent banner is required because no non-essential cookies are set.