Privacy Policy

Privacy Policy

Last updated: 30 September 2026

Top Companions takes privacy and discretion seriously.

This Privacy Policy explains how we collect, use, store and protect personal information when you visit our website, contact us, create an account, become a member, submit an application or arrange a booking through Top Companions.

It also explains your rights under the General Data Protection Regulation (“GDPR”) and applicable Belgian data-protection law.

1. Who is responsible for your data?

Top Companions is responsible for the processing of personal information described in this Privacy Policy.

For privacy enquiries, requests concerning your personal data or the exercise of your GDPR rights, please contact:

Top Companions

Email: [email protected]

Further identifying information concerning the data controller may be provided where required by law or upon a valid request.

2. Adults only

Top Companions is an adults-only service.

Our website, companion profiles, membership areas and booking services are intended exclusively for persons aged 18 or over.

We do not knowingly collect information from minors for the purpose of providing our services.

If we become aware that information relating to a minor has been submitted to us improperly, we will take appropriate steps in accordance with applicable law.

3. Information we may collect

The information we collect depends on how you interact with Top Companions.

Information provided by clients and website users

This may include:

• name;
• email address;
• telephone number;
• age or date of birth;
• country of residence;
• preferred language;
• booking dates and locations;
• hotel or meeting information;
• travel arrangements;
• booking preferences;
• correspondence with us;
• membership information;
• payment and transaction information;
• identification information where verification is required;
• information supplied in connection with a complaint, safety concern or dispute.

We ask clients to provide only information that is reasonably relevant to their enquiry or booking.

Information relating to companions and applicants

This may include:

• name and contact information;
• identity and age-verification information;
• photographs and videos;
• profile information;
• languages;
• availability;
• travel information;
• booking history;
• payment information;
• professional correspondence;
• safety reports;
• information required for legal or regulatory compliance.

Additional information may be collected during an application or screening process where appropriate.

Information collected automatically

When you visit our website, certain technical information may be collected automatically, including:

• IP address;
• browser and device information;
• operating system;
• approximate country or region;
• referring page;
• pages visited;
• date and time of access;
• security and diagnostic information.

Cookies and similar technologies are addressed separately below and in our Cookie Policy.

4. Sensitive information

Because of the nature of our services, certain information communicated to Top Companions could reveal or allow conclusions to be drawn about highly private aspects of a person’s life.

Under the GDPR, information concerning a person’s sex life or sexual orientation is subject to enhanced legal protection.

Top Companions therefore applies particular care to such information.

We aim to:

• collect only information genuinely necessary for a legitimate purpose;
• limit internal access to people who need the information;
• avoid using sensitive booking information for unrelated purposes;
• avoid using such information for advertising profiles;
• protect such information through appropriate technical and organisational measures;
• delete or anonymise it when there is no longer a lawful reason to retain it.

Where the GDPR requires an additional legal condition for processing special-category data, we will process such information only where an appropriate condition under applicable law exists.

5. Why we use personal information

We may process personal information for the following purposes.

Enquiries and bookings

To:

• respond to enquiries;
• determine availability;
• coordinate introductions;
• arrange appointments;
• communicate booking information;
• coordinate travel and logistics;
• manage changes and cancellations.

Contract administration

To enter into and perform agreements with clients, members, companions and other persons with whom we have a contractual relationship.

Payments and accounting

To:

• process payments;
• issue payment requests;
• keep transaction records;
• meet accounting and tax obligations;
• investigate payment disputes or suspected fraud.

Payment-card information may be handled directly by our payment providers rather than stored by Top Companions.

Safety and security

To:

• verify identities where appropriate;
• assess safety concerns;
• maintain appropriate booking records;
• communicate during appointments where necessary;
• investigate serious incidents;
• prevent fraud, abuse and misconduct;
• protect clients, companions, staff and other persons.

Legal and regulatory compliance

To comply with obligations arising under Belgian and European law, including obligations concerning:

• identity and adulthood verification;
• advertising;
• prevention of exploitation and human trafficking;
• cooperation with competent authorities;
• accounting and taxation;
• data protection;
• fraud prevention.

Membership services

To create and administer membership or restricted-access accounts and provide access to member or VIP content.

Communications and marketing

Where permitted by law, we may use contact information to communicate relevant news or information about Top Companions.

Where consent is required, marketing communications will be sent only with the appropriate consent.

You may unsubscribe from marketing communications at any time.

Unsubscribing from marketing does not prevent us from sending communications necessary for an existing booking, account, transaction or legal obligation.

Website operation and security

To operate, maintain, secure and improve our website and identify technical problems, misuse or security threats.

6. Legal grounds for processing

Depending on the circumstances, we process personal information on one or more of the following grounds:

Performance of a contract

Where processing is necessary to arrange or perform a booking, membership or another agreement with you.

Steps taken at your request before entering into a contract

For example, when you contact us asking about availability or a potential booking.

Legitimate interests

Where processing is reasonably necessary for legitimate business purposes, such as:

• operating and protecting our business;
• preventing fraud;
• maintaining appropriate records;
• responding to enquiries;
• protecting the safety of clients and companions;
• establishing or defending legal claims.

We consider the impact on the individuals concerned before relying on legitimate interests.

Legal obligations

Where processing is necessary to comply with Belgian, European or other applicable legal requirements.

Consent

Where consent is the appropriate legal basis, including certain marketing activities, cookies or the processing of particular information where required by law.

Consent may be withdrawn at any time, without affecting processing that lawfully took place before withdrawal.

Other grounds permitted by law

In exceptional circumstances, another basis recognised under the GDPR may apply, for example where processing is necessary to protect someone’s vital interests or for the establishment, exercise or defence of legal claims.

7. Identity and age verification

Top Companions may verify the identity and adulthood of persons using or appearing through our services where this is necessary for safety, fraud prevention or legal compliance.

Belgian legislation concerning specialised advertising platforms may require the verification and retention of specified information relating to advertisers and persons whose profiles or advertisements appear on such platforms.

Where these obligations apply, Top Companions will collect and retain the information required by law and will not use it for unrelated purposes.

Certain verification information may be subject to specific deletion or retention requirements imposed by law.

8. Who receives personal information?

Top Companions does not sell personal data.

Information may be disclosed only where reasonably necessary to parties such as:

• the companion involved in a proposed or confirmed booking;
• payment processors and banks;
• accountants and professional advisers;
• website hosting and IT-security providers;
• email and communications providers;
• travel providers where we are arranging travel;
• hotels or accommodation providers where necessary;
• professional service providers acting on our behalf;
• insurers;
• competent judicial, police, regulatory or governmental authorities where legally required.

We aim to disclose only the information reasonably necessary for the relevant purpose.

A companion does not automatically receive all information held about a client, and a client does not receive private information held about a companion.

9. Safety and legally required disclosures

Discretion does not prevent Top Companions from acting where there is a serious safety or legal concern.

Information may be disclosed where reasonably necessary or legally required to:

• protect someone’s physical safety;
• investigate suspected fraud;
• respond to a serious incident;
• prevent or report suspected exploitation or human trafficking;
• comply with a lawful request from competent authorities;
• establish, exercise or defend legal rights.

Where Belgian law requires information to be supplied to police, judicial or other competent authorities, we will comply with those obligations.

10. How long do we retain information?

We do not apply one retention period to every category of information.

Information is retained only for as long as reasonably necessary for the purpose for which it was collected, taking account of legal, accounting, contractual, safety and regulatory requirements.

Different information may therefore have different retention periods.

Booking and correspondence records

Booking and related communications may be retained for a reasonable period where necessary for:

• administration;
• safety;
• complaints;
• payment disputes;
• fraud prevention;
• establishing or defending legal claims.

Information that is no longer required will be deleted or anonymised where reasonably possible.

Accounting and transaction records

Invoices, transaction records and other accounting information are retained for the period required under applicable tax and accounting law.

Legally required platform records

Where the Belgian rules applicable to specialised advertising platforms require particular identification, account, advertisement, payment or modification records to be retained, those records may be kept for the statutory period.

Under the applicable Belgian framework, certain records may have to be retained for three years after the end of the relationship with the relevant advertiser, exclusively for legally prescribed purposes.

Identification material

Identification documents and verification material will not be retained for longer than permitted or required by law.

Where legislation requires particular verification material to be deleted following verification, Top Companions will follow that requirement.

Marketing information

Marketing contact details may be retained until consent is withdrawn or the individual opts out, subject to retaining minimal suppression information where necessary to ensure that an opt-out is respected.

Technical information

Website and security logs are retained only for an appropriate period having regard to website security, fraud prevention and technical requirements.

11. Security

Top Companions uses appropriate technical and organisational measures designed to protect personal information against:

• unauthorised access;
• disclosure;
• alteration;
• loss;
• misuse;
• destruction.

Access to private information is limited according to operational need.

Because no method of electronic transmission or storage can be guaranteed completely secure, absolute security cannot be promised.

We nevertheless treat discretion and information security as an important part of our operations.

12. Cookies and similar technologies

Our website may use cookies and similar technologies.

Cookies that are strictly necessary for the operation or security of the website may be used without consent where permitted by law.

Analytics, advertising, social-media or other non-essential cookies will be activated only where the legally required consent has been obtained.

You may withdraw or adjust your cookie preferences at any time through the cookie-preference settings made available on the website.

Further details, including the categories and duration of cookies used on the website, are provided in our Cookie Policy.

13. International transfers

Some service providers used by Top Companions may process information outside Belgium or the European Economic Area.

Where personal information is transferred internationally, we will use an appropriate transfer mechanism where required under the GDPR, such as:

• an adequacy decision;
• European Commission Standard Contractual Clauses;
• another legally recognised safeguard.

Additional protections may be used where appropriate.

14. Your GDPR rights

Subject to the conditions and limitations provided by law, you may have the right to:

• request confirmation that we process your information;
• obtain access to your personal information;
• request correction of inaccurate information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing relies on consent;
• object to direct marketing;
• lodge a complaint with a supervisory authority.

These rights are not absolute.

For example, we may be required to retain particular information because of legal, accounting, safety, regulatory or evidentiary obligations even after a deletion request.

We may ask for reasonable information to verify your identity before responding to a privacy request.

15. Right to deletion

You may ask us to delete personal information concerning you where the conditions of the GDPR are met.

Deletion may not be possible immediately where information must continue to be processed or retained because of:

• a legal obligation;
• accounting or tax requirements;
• statutory data-retention requirements;
• an ongoing dispute;
• the establishment, exercise or defence of legal claims;
• another lawful exception recognised under the GDPR.

Where information cannot yet be deleted, its use may be restricted where appropriate.

16. Marketing choices

You may unsubscribe from marketing emails at any time using the unsubscribe mechanism provided in the communication or by contacting us.

We will then stop using your information for that marketing purpose.

We may retain minimal information necessary to record that you have opted out so that your preference continues to be respected.

17. Automated decision-making

Top Companions does not ordinarily make decisions producing legal or similarly significant effects solely by automated means.

If this changes, we will provide the information required by the GDPR.

18. Data breaches

Top Companions maintains procedures for responding to personal-data breaches.

Where a breach is likely to result in a risk to people’s rights and freedoms, we will notify the competent supervisory authority as required by the GDPR.

Where a breach is likely to result in a high risk to an affected individual, we will also inform that individual where required by law.

19. Links and third-party websites

Our website may contain links to websites or services operated by third parties.

Top Companions is not responsible for the privacy practices of independent third parties.

We recommend reviewing their privacy information before providing personal data to them.

20. Changes to this Privacy Policy

We may update this Privacy Policy to reflect:

• changes in our services;
• changes in technology;
• changes in our processing activities;
• changes in applicable law or regulatory guidance.

The latest revision date will appear at the top of this page.

Material changes may also be communicated through the website or another appropriate method.

21. Contacting us about privacy

Questions, requests or concerns concerning personal information can be directed to:

Top Companions

Email: [email protected]

Please do not include unnecessary sensitive information in an initial privacy request.

We may request additional information where reasonably necessary to verify your identity.

22. Complaints

If you believe your personal information has been processed unlawfully, you may contact us so that we can investigate the matter.

You also have the right to lodge a complaint with the competent data-protection supervisory authority.

For Top Companions in Belgium, the supervisory authority is:

Belgian Data Protection Authority

Autorité de protection des données / Gegevensbeschermingsautoriteit

You may also have the right to contact the supervisory authority in the EU country where you habitually live or work.

Nothing in this Privacy Policy limits any rights available to you under applicable data-protection law.