How Men Can Remove Their Data from Luluvise

Lulu, formerly Luluvise, is a social-networking site and app for 'girls by girls'. The premise sounds fairly innocent enough, but when you realise that the founders seem to be living the often parodied lives of American high school girls from the Lindsay Lohan smash hit film "Mean Girls", things take a bit of a turn from the worse. Not content with undoing a hundred years or so of female equality in the fight against misogyny, Lulu centres around one thing, sex. Most importantly, Lulu revolves around talking about repeatedly shagging your "sexy CEO" male boss up against his desk and then rating him on his performance, looks and pong (yes, his scent) afterwards.

Lulu works by scraping the friend data of any budding Kardashian trainee who dares to sign up using Facebook Connect. You can only use the app if your Facebook profile says that you're female (sorry genderqueer folks) and men are prohibited from seeing the profiles created for them by the service and the harpies that control it.

This raises some very important questions about data protection and privacy, however. Concerns which aren't covered in Lulu's privacy policy or terms of service. Currently their site only displays policies covering the data of 'registered users' and not that of those who involuntarily have their data sucked up by a vacuum.

Over the weekend I reached out to Lulu and asked them to provide details of how men could request access to view and then either change or remove their personal data.

Although the company is registered in the US, it trades and operates out of the UK and so falls under jurisdiction of the Data Protection Act. The ICO (Information Commissioners Office) requires all companies who process personal data on computers to register as a "data controller". The Act allows individuals to perform subject access requests on any organisation processing their personal data and gives provisions for the stopping and removal.

Lulu's response to my request concerning their data protection policies is below:

Dear Mr Leydon,

We can provide the requested information contributed to the database by registered user(s) of the Lulu app to anyone personally affected by it if he sends us the following:

· Proof of identity (a screenshot of passport, bank statement or utility bill will suffice); and

· Facebook Username (look for what comes after when logged into one's Facebook account and see also attached for a visual explanation).

As soon as I have this information, we can send him the information regarding Lulu Reviews of him (if any) created by girls on Lulu.

Please also note that we have a progressive takedown policy and can permanently remove any man from Lulu (and/or LuluDude if he has registered for the complementary male product). This means that all reviews (if any) would be deleted and no one can review him going forward. For this, I also need his Facebook username.

Luluvise Limited is not the Data Controller of the information you contemplate below in your email. It is User Generated Content, which is controlled and owned by the user who put it on the app. Despite not being the Data Controller of this data, our terms of use with our members (who are the Data Controllers) allow us, where a person is both personally affected by and concerned with the nature of that information, to make it available to him for his review and removal option.

I hope this helps answer your questions. Please let me know if you need anything else.

Thank you.

Whilst Lulu will provide you with the personal information it holds about you and will also remove it, unfortunately it fails to understand its role as a Data Controller in the UK. Whilst the data held about its users is defined by Lulu as "User Generated Content" the storage and processing of the data is still done by Lulu, on their IT services and not by the user, making them Data Controllers.

Still, a round of applause must be given to Lulu, for providing a 'progressive takedown policy', although I do wonder if "permanent deletion" prevents their app from reimporting men's data when another female user signs up again.

There you have it, a nice guide on how to remove your data from Lulu.

Chris Leydon.