July 9, 2017
Cumming Without Permission (CWP) is a website/blog with features similar to Facebook, but tailored specifically to the kinky community; particularly Domination and submission and Parent/little kinks. The kinky community is a mix of the most beautiful and diverse group of adults of every gender, orientation, race, religion, and age. The one thing that unites us all is the importance of consent to the health and well-being of the community.
About these Guidelines
Our members trust us with their most intimate and private data. Maintaining that trust is essential, which means keeping members’ data safe, secure, and private.
While the overwhelming majority of our members use CWP to connect with the community, explore their sexuality, and build long-lasting relationships, we recognize that with millions of members spread all over the world, there are bound to be a few bad apples in the barrel. In those cases, we want to help law enforcement in serving their legitimate interest of protecting our community and the general public.
By providing guidelines for law enforcement personnel, we hope to strike a balance between the often competing interests of member privacy and justice.
We hope these guidelines will help to set expectations on both sides, as well as to add transparency to our internal processes. Our members should know that we value their private information and that we do what we can to protect it. At a minimum, this means only releasing data to third-parties when the appropriate legal requirements have been satisfied.
By the same token, we also hope to educate law enforcement professionals about CWP so that they can more efficiently tailor their data requests and target just the information needed to conduct their investigation while respecting other members’ right to privacy.
Please note that this is a general guideline and that information available will vary from case to case. Some of the information is optional for members to provide. In other cases, we might not have collected or retained the information.
Here is a non-exhaustive list of the kind of data we maintain about a member and/or a member might decide to share with the community.
Public Member Data
- General Info: nickname, age, gender, orientation, role, location
- Relationships: relationship status, relationships in, and what they are looking for
- About me and list of websites
- Latest Public Activity
- List of friends, followers, and members following
- Upcoming Events Organizing or RSVPed to
- Groups member is a leader or member of
- Content Shared Publicly – status updates, writings, pictures, videos
- Fetishes into, curious about, soft limits, and hard limits
- Wall Posts
Private Member Data
- Friends Only Content – Writings, Pictures, Videos
- Private Conversations
- Email Address
- Mobile Number
- Date Signed Up On
- Date of Birth (self-reported)
- List of member blocks and group bans
- Support History
- Browser and IP Address History
- Server logs that are subject to our data retention policy.
- Backups that are subject to our data retention policy.
- Event analytics data that we use for statistical purposes.
Data Retention Policy
Emergency Requests and Exigent Circumstances
We evaluate emergency disclosure requests on a case-by-case basis. If we receive information that gives us a good faith belief that there is an emergency involving the danger of death or serious physical injury to a person, we may provide information necessary to prevent that harm, if we have it.
Disclosure of Non-Public Information
It is our policy to disclose non-public member information in connection with a criminal or civil investigation only with a member’s consent or upon receipt of a valid subpoena, civil investigative demand, court order, search warrant, or other similar valid legal process.
CWP reserves the right to object to any requests for non-public information. Where CWP agrees to produce non-public information in response to a lawful request, we will conduct a reasonable search for the requested information.
Here are the kinds of information we will agree to produce, depending on the kind of legal process we are served with:
With member consent: We will provide private account information if requested, directly to the member, or to a designated third party with the member’s written consent once we are satisfied that the member has verified his or her identity.
With a subpoena: If served with a valid subpoena, civil investigative demand, or similar legal process issued in connection with an official criminal or civil investigation, we can provide certain non-public account information, which may include:
- Signup date
- Friends only content
- Email address associated with the account
- Mobile number associated with the account
- IP address(es) used to access the account at a specified time or event relevant to the investigation
With a court order or a search warrant: We will not disclose account access logs unless compelled to do so by either (i) a court order issued upon a showing of specific and articulable facts showing that there are reasonable grounds to believe that the information sought is relevant and material to an ongoing criminal investigation; or (ii) a search warrant issued upon a showing of probable cause. This may include:
- Any logs which would reveal a user’s movements over a period
- Member or IP-specific analytic data such as browsing history
- Security access logs other than account creation or for a specific time and date
Only with a search warrant: We will not disclose the private content of any member account unless compelled to do so under a search warrant issued upon a showing of probable cause. Private account content may include:
- Contents of a private conversation with a specific member(s) during a specific timeframe
We will take steps to preserve account records for up to 90 days upon formal request from law enforcement in connection with official criminal investigations, and pending the issuance of a court order or other process.
It is our policy to notify members about any pending requests regarding their accounts, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
Before disclosing member information, we will make a reasonable effort to notify any affected member(s) by sending a message to their verified email address providing them with a copy of the subpoena, court order or warrant so that they can have an opportunity to challenge the legal process if they wish.
CWP does not provide expert testimony support. Also, CWP records are self-authenticating and should not require the testimony of a records custodian. If a particular form of certification is required, please attach it to your records request.
We reserve the right to seek reimbursement for administrative costs associated with responding to requests for information, as allowed by law.
Please serve requests via email to email@example.com.
Please make your requests as specific and narrow as possible, including the following information:
- Full information about authority issuing the request for information;
- Name and badge/ID of the responsible agent;
- A valid official return email address;
- Nickname and URL of the member of interest’s profile – If you’re unable to locate the nickname (including the URL to the member’s profile), we can try to find the member’s account with a phone number or email address;
- URLs of any specific pages of interest; and
- Description of the types of records you need.
Please allow at least two weeks for us to be able to look into your request.
Important Note: Any request in a civil matter has to go through the superior court of Clarke County in Washington state (United States of America).
If you have any questions, comments, or suggestions, don’t hesitate to email us at firstname.lastname@example.org.