Who we are
DEAR LUCY (“we,” “us,” “the agency”) is a companion meeting and booking service operating in Brussels, Belgium. This policy explains what personal data we collect through dearlucy.be, why we collect it, and how it is handled.
Data controller: DEAR LUCY. For any question about this policy or your data, contact bookings@dearlucy.be.
What we collect
Depending on which form you complete, we may collect:
- Enquiry form (clients): first and last name; email address; age; preferred date, time, duration, and location for the booking; a copy of your passport or identity card; and any additional information you choose to share in the “Questions” field.
- Application form (companions): first and last name; email address and telephone number; age and city; languages spoken and relevant experience; general availability; a recent photograph; and any additional information you choose to share about yourself.
Why we collect it, and our legal basis
| Data | Purpose | Legal basis |
|---|---|---|
| ID document | Verifying you are who you say you are, and that you meet our 21+ age requirement, before any meeting is arranged. | Consent (Art. 6(1)(a) GDPR) and our legitimate interest in preventing fraud and protecting companions. |
| Booking details | Arranging and confirming the meeting. | Consent / performance of a service you requested. |
| Application details and photo | Assessing applications and arranging an initial conversation. | Consent. |
You give this consent explicitly when you tick the checkbox on either form. You may withdraw consent at any time by contacting us — see Section 7.
Who sees your data
ID documents submitted through the enquiry form are reviewed by one designated member of our team for screening purposes only.
Your ID document is never shared with the companion, never attached to your booking record, and never passed to any third party.
Companion applications and photographs are reviewed only by our team and are never shared with clients or made public without your separate, explicit agreement.
We do not sell, rent, or trade personal data to third parties.
We may be required to disclose data to Belgian authorities if compelled by law (see Section 8).
How long we keep it
- ID documents: deleted once screening is complete, whether or not the enquiry results in a booking.
- Booking correspondence (name, email, booking details): retained only as long as necessary for the purpose it was collected, then deleted.
- Application materials (non-accepted applicants): deleted unless you ask us to keep them on file for future openings.
- Application materials (active companions): retained for the duration of the working relationship and deleted after it ends.
How we protect it
Data submitted through our forms is transmitted over an encrypted (HTTPS/TLS) connection.
ID documents and application photos are stored in an access-restricted system and are accessible only to authorised team members.
We limit access to personal data to the minimum number of people necessary to carry out screening and administration.
Your rights
Under the GDPR, you have the right to:
- Access the personal data we hold about you.
- Correct inaccurate data.
- Erase your data (“right to be forgotten”).
- Restrict or object to certain processing.
- Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
- Lodge a complaint with the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit), if you believe your data has been mishandled.
Legal disclosure
We may disclose personal data where required by Belgian or EU law, or in response to a valid request from a competent authority. Any such disclosure is limited to what is legally required.
Changes to this policy
We may update this policy from time to time. The “last updated” date at the top reflects the most recent revision. Material changes will be reflected on this page.
Contact
DEAR LUCY · bookings@dearlucy.be