Privacy Policy for Geisha Noir, Ltd

Effective Date: October 24, 2025
Last Updated: October 24, 2025

1. Introduction and Scope

This Privacy Policy explains how Geisha Noir, LLC (“we,” “our,” or “us”) collects, uses, safeguards, transfers, and discloses personal information belonging to VIP clients, authorized Guests, contracted performers (“Geisha Girls”), security and logistics personnel, and other parties who interact with Geisha Noir in connection with high-end private Engagements, VIP companionship programs, multi-day travel assignments, and jurisdiction-approved intimacy services.

This Privacy Policy applies to all Personal Data collected or processed by Geisha Noir, LLC in connection with:

VIP vetting and onboarding,
Booking and execution of multi-day Engagements,
Travel and itinerary coordination,
Security and safety protocol enforcement,
Legal and jurisdictional compliance,
Post-engagement dispute resolution and recordkeeping.

This Policy applies to both:

Personal Data you provide directly, and
Personal Data collected or verified through confidential security screening, lawful due diligence, or compliance procedures.

Geisha Noir complies with applicable data protection and privacy regulations, including but not limited to:

The EU General Data Protection Regulation (EU GDPR),
The UK GDPR,
The California Consumer Privacy Act (CCPA) and its amendments,
The Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada,
Applicable national privacy, identity verification, and record-keeping laws in jurisdictions where the Engagement is performed.

By entering into or requesting an Engagement with Geisha Noir, LLC, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.

This Policy is distinct from and separate from the privacy policy governing Geisha Noir, LLC (the public-facing entertainment, events, and performance company). This Policy governs private, confidential, invitation-only services and VIP companionship itineraries.

2. Definitions

For the purposes of this Privacy Policy:

“Personal Data” means any information relating to an identified or identifiable natural person. This includes names, contact information, identification documents, travel itineraries, and any other data that can be linked to a person.
“Sensitive or Special Category Data” means Personal Data that reveals or relates to intimate preferences, health or wellness considerations relevant to safety during the Engagement, or other information that would reasonably be treated as confidential under EU GDPR Articles 6 and 9 or equivalent laws. This includes certain preference information disclosed by a VIP or performer for compatibility, safety planning, or boundary-setting.
“Processing” means any operation performed on Personal Data, whether automated or not, such as collection, recording, structuring, storage, consultation, transmission, restriction, deletion, or destruction.
“Controller” means Geisha Noir, LLC, which determines the purposes and means of processing your Personal Data within its escort and private-companionship business unit.
“Processor” means any vetted third-party service provider that processes Personal Data on behalf of Geisha Noir under strict contractual, confidentiality, and security requirements (for example: secure travel coordinators, payment processors, dedicated security vendors).
“VIP” means the principal contracting client who books an Engagement.
“Guest(s)” means any individual authorized in writing by the VIP to participate in, attend, or benefit from the Engagement and who has been approved by Geisha Noir.
“Engagement” means the contracted period of companionship, appearance, travel attendance, or related services provided to a VIP and approved Guests by Geisha Noir.
“Jurisdiction” means the city, region, state, province, or country in which an Engagement lawfully begins and whose laws govern the Engagement.
“Consent” means a freely given, specific, informed, and unambiguous indication of an individual’s agreement to the Processing of Personal Data, including Sensitive or Special Category Data, where required.

3. Information We Collect

Geisha Noir collects Personal Data and, in limited cases, Sensitive Personal Data. We collect only what is reasonably required to conduct lawful, safe, private, consent-based Engagements.

3.1 Personal Data (VIPs, Guests, and Performers)

We may collect the following categories of Personal Data:

Identity and Verification Data:
Full legal name, alias or preferred name, date of birth, government-issued identification (passport, driver’s license, national ID), citizenship or residency status, and—where necessary—visa or entry eligibility.
Contact Information:
Email address, mobile number, encrypted messaging handle, and emergency contact information.
Booking and Engagement Records:
Requested Engagement tier (e.g., 24-hour, 72-hour, 7-day), participating cities and destinations, requested appearance schedule, requested number of performers, security notes, and itinerary milestones.
Travel and Logistics Information:
Flight details, hotel reservations, chauffeur or ground transport assignments, venue and dining locations, time-stamped itinerary, and coordination details for movement between jurisdictions.
Financial and Transaction Data:
Billing address, method of payment, payment confirmations, retainers, invoices, reconciliation records, and any dispute-related adjustments.
Note: Credit card and bank data are processed through compliant, secure processors and are not retained in raw form beyond what is legally required for accounting and fraud prevention.
Guest List and Attendee Verification Data:
Identification copies or confirmations for Guests authorized by the VIP to attend a private Engagement. We require this for security, safety, and compliance screening.
Security and Conduct Records:
Incident reports (if any), behavioral flags (for example, prior breach of code of conduct), safety alerts, and enforcement notes relevant to the protection of performers and staff.

3.2 Sensitive or Special Category Data

Because Engagements may involve close physical proximity and require explicit comfort protocols and boundaries, we may collect limited Sensitive or Special Category Data, which may include:

Personal preference information is voluntarily disclosed to establish compatibility, comfort, and boundaries for all parties.
Confidential health/safety disclosures where necessary to ensure physical safety (for example, allergies, mobility limitations, or known triggers/stressors relevant to on-site wellbeing).
Security-related restrictions (for example, “this Guest must not be left unsupervised with any performer,” or “this VIP has requested privacy accommodations in hotel access”).

This category of data is collected only:

With explicit written or digital consent;
For the purpose of planning and safely executing a specific Engagement.
On a need-to-know basis internally; and
Under heightened confidentiality and access controls.

We do not collect Sensitive Data for marketing or general profiling.

3.3 Automatically Collected Technical Data

When you interact with our secure client portal or communications systems, we may also collect:

IP address, browser type, device type, and operating system.
Session metadata, access timestamps, login activity, and device fingerprinting (for fraud control and account security).
Audit logs documenting who accessed which portion of an itinerary or file.

This technical data supports fraud prevention, identity verification, and secure operation of our VIP portal and internal scheduling systems.

4. How We Collect Information

We collect Personal Data and Sensitive Data:

Directly from you (VIP intake forms, pre-engagement questionnaires, ID verification submissions, travel preference surveys, Guest approval lists).
From Guests authorized by the VIP, for their own verification.
From performers and security personnel in the course of pre-engagement coordination.
From internal operations (for example, incident logs or compliance audits).
From secure third-party providers (e.g., identity-check services, payment processors, or licensed security firms), where legally permissible.

We do not purchase Personal Data from data brokers. We do not scrape social media.

5. Legal Basis for Processing

Geisha Noir processes Personal Data and, where applicable, Sensitive Personal Data under the following lawful bases:

Contractual Necessity:
To evaluate, confirm, and deliver the Engagement you have requested; to schedule personnel; to coordinate travel, security, and accommodations; to manage billing and retainers.
Legitimate Interests:
To protect the safety and well-being of performers, staff, VIPs, and Guests; to prevent fraud; to vet identities; to resolve disputes; to maintain accurate internal records of conduct and compliance.
Legal Obligation:
To comply with record-keeping, tax, accounting, customs, immigration, work authorization, and jurisdiction-specific regulatory requirements, including those tied to adult-services licensing in certain regions.
Consent:
For the collection and Processing of Sensitive or Special Category Data (for example, highly personal preference information or certain safety-related disclosures), and for any optional marketing communications or post-engagement outreach.

Where our Processing relies on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of Processing prior to withdrawal, but it may limit our ability to provide or continue an Engagement.

6. How We Use Your Information

We use Personal Data and, where provided, Sensitive Personal Data for the following purposes:

Engagement Planning and Fulfillment
- Verifying the eligibility and identity of VIPs and Guests;
- Assigning approved performers and security personnel;
- Creating hour-by-hour itineraries that comply with jurisdictional requirements;
- Booking travel, accommodations, chauffeured transport, and venue access.
Safety and Security
- Enforce identity pre-screening for all Guests.
- Maintaining safety protocols, safe-word/comfort systems, and escalation procedures;
- Documenting incidents, boundary violations, or rule breaches to protect all parties.
Regulatory and Jurisdictional Compliance
- Ensuring Engagements occur only in regions where Geisha Noir is licensed/authorized;
- Demonstrating compliance (if lawfully compelled) to regulators or law enforcement;
- Confirming lawful immigration/work status for performers and staff.
Financial Administration
- Processing retainers, invoices, adjustments, credits, and reconciliation after an Engagement;
- Generating accounting records required by law (tax, audit, or customs declarations).
Confidential Communications
- Sending itinerary confirmations, updates, or change notices;
- Alerting you to material compliance requirements;
- Issuing formal notices regarding schedule changes or the substitution of personnel.
Dispute Management
- Maintaining evidentiary records in the event of a billing dispute, safety complaint, or post-engagement arbitration;
- Enforcing our Terms of Service, including termination-of-service provisions.

We do not use Sensitive Personal Data for generalized marketing. We do not train AI models or analytics models on Sensitive Personal Data.

7. Cookies, Session Logs, and Secure Portals

For VIPs who access Geisha Noir's private scheduling or coordination portals, we may use cookies, encrypted tokens, and session logging to:

Authenticate user identity;
Prevent unauthorized account access;
Track changes to itineraries and Guest lists for compliance.
Maintain time-stamped evidence of consent to terms and conditions.

For EU/UK users, cookie usage and tracking technologies comply with the ePrivacy Directive and local consent rules. You may decline non-essential cookies; however, secure portal features may not function without session tokens.

8. Data Sharing and Disclosure

Geisha Noir does not sell Personal Data. We disclose Personal Data only under the following controlled circumstances:

8.1 Service Providers and Operational Partners

We may share limited Personal Data with carefully vetted processors who assist in delivering the Engagement, including:

Chauffeur / executive transport providers,
Luxury hotel or accommodation partners,
Licensed security personnel assigned to the Engagement,
Travel logistics coordinators,
IT and secure communications providers,
Payment processors and financial institutions.

Such partners receive only the minimum information needed to perform their function and are bound by confidentiality and data protection agreements.

8.2 Legal, Regulatory, and Safety Obligations

We may disclose information:

When required by law, subpoena, court order, arbitration order, or other lawful process;
To comply with licensing, zoning, work authorization, or border-control inspections in a given Jurisdiction;
To protect the safety of performers, staff, VIPs, or Guests where there is a credible and immediate risk.

When we are legally permitted to do so, we will attempt to notify the affected VIP or performer before disclosure.

8.3 Internal Compliance and Enforcement

We may internally circulate conduct-related reports concerning an Engagement (for example, breach of consent protocol, unsafe behavior, attempted photography in violation of Terms). This is done to protect personnel and inform future acceptance or denial of booking requests.

8.4 Corporate Events

In the event of corporate restructuring, merger, asset transfer, or sale of Geisha Noir, LLC, Personal Data may be transferred to a successor entity under equivalent or stronger confidentiality and privacy obligations.

9. Cross-Border Transfers

Because Geisha operates in multiple jurisdictions, Engagement data (including identity verification data, itinerary details, and security assignments) may be transferred across borders, including between the EU/EEA, the United Kingdom, the United States, and other regions in which licensed activity may occur.

When transferring Personal Data internationally, Geisha Noir uses recognizes safeguards such as:

Standard Contractual Clauses (SCCs) approved by the European Commission;
UK International Data Transfer Addenda;
Adequacy decisions were applicable.
Contractual obligations requiring equivalent protections for Personal Data.

We take steps to ensure that cross-border transfers do not reduce the level of protection afforded to your Personal Data.

10. Data Security

Geisha Noir uses layered technical, administrative, and physical safeguards to protect Personal Data and Sensitive Personal Data against unauthorized access, alteration, disclosure, or destruction. These safeguards include:

Encryption of data in transit and at rest;
Compartmentalized storage of Sensitive Personal Data with need-to-know access only;
Multi-factor authentication for staff access.
Strict device control for on-site security personnel;
Audit trails and tamper-resistant incident logs;
Regular vulnerability assessments of secure systems.

In the unlikely event of a data breach affecting your Personal Data, Geisha Noir will notify you and, where applicable, notify data protection authorities within the timelines required by law.

11. Data Retention

We retain information only as long as necessary to fulfill the purposes described in this Policy or to comply with legal, contractual, or regulatory requirements.

Examples:

Engagement records and billing data: Retained for up to seven (7) years for tax, accounting, audit, and dispute resolution.
Identity documentation and Guest verification data: Retained for up to ninety (90) days after the conclusion of the Engagement, unless ongoing legal, compliance, or dispute obligations require longer retention.
Security and conduct incident reports: Retained as long as reasonably necessary to protect staff and performers, enforce Terms of Service, and defend against legal claims.
Travel itineraries and logistics manifests: Retained for operational audit and compliance purposes, generally not exceeding two (2) years unless required longer by law.
Marketing contact data (where applicable): Retained until consent is withdrawn.

After the applicable retention period expires, Geisha Noir securely deletes, anonymizes, or irreversibly de-identifies the data.

12. Your Rights and Choices

Depending on your jurisdiction (for example, the EU/EEA, UK, certain U.S. states, or Canada), you may have some or all of the following rights with respect to your Personal Data:

Right of Access – You may request confirmation of whether we process your Personal Data and obtain a copy.
Right to Rectification – You may request correction of inaccurate or incomplete information.
Right to Erasure (“Right to be Forgotten”) – You may request deletion of your Personal Data, subject to legal retention obligations.
Right to Restrict Processing – You may request temporary suspension of Processing under certain conditions.
Right to Object – You may object to certain Processing, including Processing based on legitimate interests or direct marketing.
Right to Data Portability – Where applicable, you may request a structured, commonly used, machine-readable copy of certain Personal Data.
Right to Withdraw Consent – If Processing is based on consent, you may withdraw that consent at any time.

To exercise your rights, contact us at privacy@sakurageishagroup.com (or the dedicated address provided in your Engagement Agreement).
We may require identity verification to protect confidentiality.
We will respond within the timelines required by applicable law.

Please note: Certain information (for example, security incident logs, billing records, and compliance documents) may not be immediately deletable if we are legally required to maintain it or if it is relevant to an active dispute.

13. Children’s Privacy

Geisha Noir's services are intended exclusively for adults 21 years of age or older.
We do not knowingly collect Personal Data from minors, nor do we permit minors to participate in any Engagement.
If you believe a minor’s information has been provided to us, notify us immediately, and we will delete it.

14. Confidentiality, Non-Disclosure, and Non-Recording Obligations

In addition to privacy rights, all VIPs, Guests, and associated service personnel are bound by strict confidentiality and non-disclosure requirements. These obligations include:

No unauthorized recording (audio, photo, or video) of performers, staff, itineraries, or in-room activity.
No distribution, posting, streaming, or publication of Engagement details in real time.
No public disclosure of the identity, likeness, or personal details of any Geisha Girl, security professional, or Guest without explicit written consent.

Any attempt to violate these confidentiality obligations may result in immediate termination of the Engagement, forfeiture of fees, denial of future service, and pursuit of legal or injunctive relief. These confidentiality obligations exist in parallel with this Privacy Policy and survive the end of the Engagement.

15. Changes to This Privacy Policy

Geisha Noir may update this Privacy Policy to reflect changes in law, operational practices, data security standards, or jurisdictional licensing obligations.

When we make material changes, we will:

Update the “Effective Date” at the top of this Policy; and
Where legally required, notify active VIPs or registered contacts via secure communication.

Your continued participation in or request for services after such changes constitutes acceptance of the revised Policy.

16. Contact, Data Protection Officer, and Supervisory Authorities

For questions, concerns, or to exercise your privacy rights, you may contact:

Geisha Noir, LLC

Attn: Data Protection Officer

Email: privacy@geishanoir.com

For residents of the European Union, you may also contact your national Data Protection Authority (DPA), coordinated under the European

Data Protection Board (EDPB).

For residents of the United Kingdom, you may contact the Information Commissioner’s Office (ICO).

For residents of Canada, you may contact the Office of the Privacy Commissioner of Canada.

For residents of the United States, you may contact the Federal Trade Commission (FTC) for privacy-related complaints.

You also have the right to lodge a complaint with your local supervisory authority if you believe that Geisha Noir is is not processing your Personal Data in compliance with applicable law.

Appendix A — Key Terms Summary

Personal Data:
Any information relating to an identified or identifiable person (e.g., name, ID copy, itinerary).

Sensitive or Special Category Data:
Highly confidential Personal Data, such as preference disclosures or certain safety/compatibility details, is collected only with explicit consent and held under heightened access control.

Controller:
Geisha Noir, LLC, which determines the purposes and means of Processing Personal Data for private Engagement services.

Processor:
A third party under contract with Geisha Noir that processes Personal Data solely to support an Engagement (for example, secure transport coordinators or payment processors).

Engagement:
A contracted companionship and travel-attendance service, including multi-day itineraries, governed by jurisdictional licensing and safety protocols.

VIP / Guest:
The primary contracting client (VIP) and any pre-approved Guest authorized to participate in an Engagement.

Consent:
Freely given, informed, specific permission for certain Processing activities, especially Sensitive or Special Category Data.