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Privacy

PRIVACY POLICY

Last updated: November 16, 2023

As the operator of OnlyBabes, Movo Media, LLC (which will be referred to throughout this Privacy Policy as "OnlyBabes", "we", “our” or "us") respects your privacy. We are committed to protecting the personal data that we process about you. The OnlyBabes service enables: (i) "Creators" to share and monetize their own content (as well as subscribe to, and view, the content of other Creators); and (ii) "Fans" to subscribe to, and view, the content of Creators.

1. Privacy Policy

This Privacy Policy ("Policy") sets out our company's practices with respect to the personal data we process about our Creators and Fans. Some parts of the Policy are specifically directed at Creators, and some parts are specifically aimed at Fans. This Policy also applies to how we process the personal data of individuals that feature in content uploaded by a Creator ("Content Collaborators"), and where we process personal data about you in the context of our business relationships.

We process your personal data when you use any of our online applications and website locations for OnlyBabes or its related brands (all collectively referred to hereafter as the “Site”) and for the provision of the various services that we offer from time to time via the Site. We also process your personal data when you interact with us through our social media pages on third-party websites (e.g. Twitter and Instagram), or otherwise. We refer to these activities collectively as the "Services" in this Policy.

We are a "data controller" of the personal data that we process in connection with these Services. This means that we decide the reasons why we process personal data about you and how we do so.

Please review this Policy to understand how OnlyBabes processes your personal data in connection with the Services. By your using our Services, you acknowledge that you have read and understand the information in this Policy.

If you have any questions about this Policy or our processing of your personal data, please review Section 17 (assistance and contact information) for information about how to contact us.

2. Personal Data

"Personal data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.

In addition, we may collect data that is not capable of identifying you or is otherwise not associated or linked with you, such as deidentified, aggregated or anonymised information. This type of data is not personal data and our use of such data is not subject to this Policy.

3. Keep us updated on changes to your personal data

It is very important that the personal data we hold about you is accurate and current. Keep us informed if your personal data changes at any point during your relationship with us. Updates or corrections can be made through your account settings on our Site.

4. Strict Age Requirements

This Policy is in addition to, but does not form part of, our Terms of Service (which also includes our Acceptable Use Policy) that govern your use of the Site and the Services.

The Services are strictly intended for individuals 18 years of age or older. No one under the age of 18 years of age is ever permitted to access or use the Services. By using the Services, you represent and warrant that you are 18 years of age or older.

5. Third-Party Links

The Site and the Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you.

OnlyBabes is not responsible for, and this Policy does not apply to, the content, security or privacy practices of those other websites, plug-ins or applications. We encourage you to view the privacy and cookie policies and other notices of those third parties to find out how your personal data may be used.

6. If you do not wish to provide personal data, we cannot provide you access to Services

OnlyBabes needs to collect personal data from you in order to provide you with access to the Services and some of the features and functions of the Services. This is done in accordance with our contract with you (i.e., our Terms of Service). OnlyBabes is also required to process certain personal data in accordance with the applicable laws we are subject to. If you do not wish to provide personal data when requested, OnlyBabes may not be able to provide you with access to the Services or specific features and functions of the Services.

7. Updates

OnlyBabes may update this Policy from time to time. Any updates will be effective upon the posting of the revised Policy on our Site. We use reasonable efforts to notify you in the event material updates are made to this Policy.

8. Categories of personal data

OnlyBabes either processes itself, or uses third-party providers processors to process on our behalf, the different kinds of personal data about Creators and Fans. The categories of personal data are grouped together as follows:

USER DATA

Creators and Content Collaborators

-Full name

-Alias, as applicable

-Residence

-Country of residence

-Email address

-Telephone number

-Copy of government ID provided to OnlyBabes

-Self photograph of party holding government ID

-Third-party social media handle/personal website address

-Signature on release forms

Fans

-Email address

-Telephone number

THIRD-PARTY ONBOARDING DATA

Creators

-Copy of government ID provided to OnlyBabes third-party providers

-Short .gif, taken from selfie provided to third-party providers

-Results of third-party age and identity verification process (pass/reason for fail)

-Metadata associated with third-party age and identity verification process

Fans

-For locations where third-party age and identification is conducted for Fans, a copy of government ID that you provide to third-party provider

-For locations where third-party age estimation, or third-party age and identity verification of Fans is conducted, a short .gif taken from selfie provided to third-party providers

-The results of third-party age estimation process or third-party age and identity verification process (pass/reason for fail)

-Metadata associated with third-party age and identity verification process

ACCOUNT DATA

Creators

-Profile name

-Password

-Avatars and headers of your Creator account

-Your subscriptions, subscribers and referrals

-Posts you have made to your Creator account

-Comments on posts made from your Creator account

-Chat messages between you and other users

-Customer support questions/comments you submit to OnlyBabes

Fans

-Profile name

-Password

-Avatars and headers of your Fan account

-Your subscriptions

-Comments on posts made from your Fan account

-Chat messages between you and other users

-Customer support questions/comments you submit to OnlyBabes

FINANCIAL DATA

Creators

-Payment card information

-Billing address

-Funds added to your wallet

-Bank account information

-Payout country

-Corporate or business entity if registered for tax or VAT purposes

-Social security number (US Creators only) or other tax ID information

-W-9 form (US Creators only)

-1099-MISC form (US Creators only)

-1099-NEC form (US Creators only)

Fans

-Payment card information

-Billing address

-Funds added to your wallet

TRANSACTION DATA

Creators

-Earnings

-Payout requests

-Payments made to your Creator account

-Payments made from your Creator account to other Creators

-Any failed payments

Fans

-Payments made from your Fan account to Creators

-Any failed payments

TECHNICAL DATA

Creators and Fans

Internet and other electronic network activity information, including:

-Internet protocol (IP) address and associated location data

-Internet Service Provider (ISP)

-Device and type

-Name and version of browser

USAGE DATA

Creators and Fans

Cookies are used when necessary to allow you to browse the Services and access certain pages of the Site. With your consent, we will use cookies:

-For performance on the Site to analyze how users interact in order to improve the Services.

-When you are a Creator, we can recognize that you have referred another Creator through your designated referral code

-For Site functionality such as saving your logged-in status

Please refer to OnlyBabes’ Cookies Policy for more information, including how to delete or block cookies. Data collected from cookies may be in a aggregated or anonymized format.

OnlyBabes does not use any cross-site tracking technologies and it does not sell personal data collected about you. OnlyBabes does not share personal data collected about you for cross-context behavioral advertising.

FACE RECOGNITION DATA

Creators and Fans in certain locations

-As is more fully explained in Section 9 below, during onboarding, OnlyBabes’ third-party providers may use face recognition technology so that you can be digitally verified.

-Face Recognition Data remains with the third-party provider. OnlyBabes does not ever collect, receive, possess, or have access to such Face Recognition Data

9. The OnlyBabes’ onboarding processes

CREATORS

OnlyBabes has processes intended to ensure that all Creators on the Site: (i) are at least 18 years of age; and (ii) verify their identity. Before an individual can start a Creator account, OnlyBabes will:

-Request you to provide Creator User Data, as this is set out in Section 8 above (see categories of personal data)

-Check your country of residence. This process is intended to ensure lawful access to the Site and the Services.

-Request you to provide Financial Data, as this is set out in Section 8 above (see categories of personal data). This is required so payments can be made to Creators for content, and so Creators can access their earnings via the Site. Financial Data is collected as a verification and anti-fraud measure.

-Request you to go through a third-party age and identity verification process:

-This process involves the third-party provider collecting a short .gif, taken from a "selfie" and photo from a government identity document (provided to the third-party provider). The third-party provider then uses Face Recognition Data to match the two images so they can digitally verify your age and identity.

-As described at Section 8 above (categories of personal data), OnlyBabes does not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.

-Where permitted by applicable law, OnlyBabes receives from the third-party providers Third-Party Onboarding Data, and certain Technical Data, as set out above in Section 8 (categories of personal data), to maintain a record of the age and identity verification process.

Check that you have not previously been banned from using the Website and our Services (e.g. as a result of violating the OnlyBabes’ Terms of Service).

FANS

OnlyBabes has processes intended to ensure that: (i) all Fans on the Site are at least 18 years of age; and (ii) Fans in certain locations verify their identity. Before you can start a Fan account, we will:

-Request you to provide Fan User Data, as this is set out above in Section 8 (categories of personal data).

-Check your country of residence. This is intended to ensure lawful access to the Site and the Services.

-Request you to provide Financial Data, as set out at Section 8 (categories of personal data). This is necessary so that Fans can make payments to Creators. Financial Data is also collected as a verification and anti-fraud measure.

-Request you to go through a third-party process to gain assurances of your age. The specific process will depend upon your location and the third-party provider. This may include:

Third-party age and identity verification:

-For certain locations, we are required to verify the age and identity of our Fans, so we need to take additional steps. This process involves our third-party provider collecting a short .gif, taken from a selfie and photo from a government identity document (in both cases, that you provide to the third-party provider). The third-party provider then uses Face Recognition Data to match the two images so they can digitally verify your age and identity.

-As set out at Section 8 (categories of personal data), we do not ourselves collect, receive, possess, or have access to this data.

-Where permitted by applicable law, we may receive from our third-party providers Third-Party Onboarding Data, and certain Technical Data, as set out at Section 8 (categories of personal data), to maintain a record of the age and identity verification process.

Third-party age estimation

-For certain locations, we use third-party providers to conduct age estimation. This process involves our third-party provider collecting a short .gif "selfie" (that you provide to the third-party provider) and using digital technology to estimate your age, which may involve the use of Face Recognition Data.

-If you go through the third-party age estimation process, we will only receive the results of the process (pass / fail and reason for failing), to maintain a record of the age estimation process.

-If you fail the third-party age estimation process (e.g. if you are over 18 years of age, but their technology has predicted that you look under 18 years of age), you may have the option to go through the third-party age and identity verification process set out above.

MORE INFORMATION ON OUR ONBOARDING PROCESSES

Why does OnlyBabes use third-party face recognition technology?

The use of face recognition technology by our third-party providers is an important technological measure used in our wider onboarding processes for Creators and Fans. It is intended to ensure safety on the Website and our compliance with applicable laws.

We use third-party service providers to carry out age and identity verification, who carry out these services on our behalf, as data processors.

How does Face Recognition Data help to prevent fraud?

Face recognition technology reduces the possibility of fraudulent face image spoofing and the uploading of fraudulent government identity documents when individuals go through the onboarding process.

Where our third-party providers have identified possible fraud attempts (such as the use of fake or otherwise manipulated documents) our third-party providers may maintain a record of such attempts, including Face Recognition Data, for the purposes of detecting unlawful activity and preventing access to the Website.

Periodic authentication of your identity

During the time that you hold an account with us, we may require you to periodically authenticate your identity. If you have gone through the third-party age identity verification process, where permitted by applicable law our third-party providers may retain Face Recognition Data to enable you to authenticate your identity. Where this is retained, you do not need to provide the third-party provider with your government identity document again when authenticating your identity.

Withdrawing your consent: You may withdraw your consent to the retention of your Face Recognition Data for the purposes of subsequent authentication (and delete this) by contacting [email protected]. While withdrawing your consent to the retention of your Face Recognition Data will not affect your ability to complete a subsequent authentication process, it may require you to provide the third-party provider with your government identity document again during the authentication process.

10. Why your personal data is used and the lawful reasons for processing

OnlyBabes will process personal data either for, or based on, one or more of the following legal reasons:

Consent: Your consent is requested only in specific circumstances which includes, for example, the processing of: (i) Face Recognition Data by our third-party providers as part of the age and identity verification process for all Creators (and for Fans in certain locations); and (ii) age estimation captures (which may involve the use of Face Recognition Data) by our third-party providers for Fans in certain locations. Please see Section 9 (the onboarding processes), above, for further information.

Performance of a contract: By using the Services, you have contracted with us through our Terms of Service, and we will process personal data to perform that contract (e.g. to fulfil transactions between Fans and Creators and/or process Creator earnings) and to enforce the terms of that contract.

Legitimate interests: We may process personal data if it is in our, or a third-party's, legitimate interests (as detailed in the table below). This includes, for example, investigating and responding to a report made through our DMCA takedown procedure to protect a Creator's intellectual property rights.

Compliance with legal obligations: As a global business, we may process personal data to comply with applicable law, rules and regulations in the locations where we operate.

Task carried out in the public interest: We may process personal data as necessary for a task carried out in the public interest. This may include, for example, reporting illegal activity to relevant law enforcement authorities, other governmental agencies and non- governmental organizations.

OnlyBabes will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

The information set out below indicates the purposes for which your personal data is processed and the legal justification (i.e., basis) for the processing. Some of the above grounds for processing may overlap and there could be several grounds which justify the basis for processing:

ACTIVITY

Account creation (both Creators and Fans)

Basis: Performance of a contract

Creator age and identity verification and where applicable, subsequent authentication (including Face Recognition Data)

Basis: Consent

Fan age and identity verification and where applicable, subsequent authentication (including Face Recognition Data)

Basis: Consent

Fan age estimation, which may involve the use of Face Recognition Data

Basis: Consent

Fan age verification

Basis: Performance of a contract

Government identity document validity check, and maintaining a record of the age and identity verification process (for Creators, and Fans in certain locations)

Basis: Performance of a contract

Maintaining a record of the age estimation process (for Fans in certain locations)

Basis: Performance of a contract

Providing the Services, including the hosting of Creator Content, the fulfillment of transactions between Fans and Creators and processing Creator earnings

Basis: Performance of a contract

Providing technical support to Fans and Creators

Basis: Performance of a contract

Communicating with you about the Services, responding to support requests, sharing information about the Services, or updating Terms of Service

Basis: Performance of a contract

Ensuring compliance with, and/or enforcing the OnlyBabes’ Terms of Service and other OnlyBabes’ policies

Basis: Performance of a contract

Moderation and filtration:

Text and content uploaded to the Site

Livestreaming on the Site

Content sent in chat messages on the Site

To monitor and investigate alleged violations of OnlyBabes’ Terms of Service

Basis: Performance of a contract

Filtration of text sent in direct messages on Site to investigate alleged violations of OnlyBabes’ Terms of Service

Basis: Performance of a contract

Removal from the Services of text and content uploaded by Users that is identified as illegal, and suspending or deactivating those User accounts

Basis: Compliance with legal obligations; Performance of a contract

Removal from the Services of text and content uploaded by Users that is identified as violating OnlyBabes’ Terms of Service, and when appropriate, suspending or deactivating those User accounts

Basis: Performance of a contract

Maintaining a record of banned Users, to prevent further access to the Site

Basis: Legitimate interests

Reporting illegal activity to relevant law enforcement authorities, other governmental agencies and non-governmental organizations

Basis: Legitimate interests, Public Interest

Preservation and sharing of personal data in the context of legal proceedings

Basis: Legitimate interests

Complying with applicable laws, rules and regulations

Basis: Legitimate interests, compliance with legal obligations

Monitoring transactions and business network, systems, applications, and data, to: (1) detect malicious, deceptive, fraudulent, or illegal activity in order to protect information security and integrity, and User safety; and (2) respond to or investigate incidents where appropriate

Basis: Legitimate interests, Public Interest

To protect the rights and property of OnlyBabes’ Users, the company and other third parties, as necessary and appropriate

Basis: Legitimate interests

Data analysis and testing, system maintenance, reporting and hosting of data, to maintain develop and/or improve the Services

Basis: Legitimate interests, Consent

In the context of a possible sale, merger, acquisition, business reorganization or group structuring

Basis: Legitimate interests

Processing of personal data in connection with sponsorships, and with service providers, professional advisors and other third parties for business purposes

Basis: Legitimate interests, Performance of a contract

11. Obtaining your personal data

OnlyBabes’ collects your personal data from the following categories of sources:

Directly from you: When you provide it to OnlyBabes directly to open an account and use the Services, when you update your personal data in your account, or by corresponding with OnlyBabes.

Automatically or indirectly from you: As a result of your use of the Services.

From OnlyBabes’ service providers: Where this is permitted by applicable law, OnlyBabes will receive third-party onboarding data and technical data from third-party age and identity verification providers.

12. Sharing your personal data

OnlyBabes may share personal data with the following categories of third parties:

Third-party service providers: Payment processing, customer support, IT support, content and text moderation matters, and age and identity verification or age estimation service providers. The lawful basis for sharing personal data with these recipients is that it is necessary for our legitimate interests (i.e., services to support business functionality).

Professional advisers: Legal advisors, bankers, auditors, accountants, consultants, and insurers. Professional advisors will process personal data as necessary to provide their services. The lawful basis for sharing personal data with these recipients is that it is necessary for our legitimate interests (i.e., professional services).

Corporate: Third parties involved in the event of a possible sale, merger, acquisition, business reorganization or group restructuring exercise. The lawful basis for sharing personal data with these recipients is that it is necessary for assessing and putting into effect potential transactions).

Affiliates: For coordination and management of OnlyBabes and its related businesses, in accordance with the purposes set out at Section 8 above (categories of personal data). The lawful basis for sharing personal data with these recipients is that it is necessary for our legitimate interests (i.e., coordinating the operations of our business).

Authorities, regulators and organizations: In response to requests from appropriate authorities (including law enforcement and tax authorities, regulators, and non-governmental organizations). The recipients may use personal data in the performance of their regulatory, law enforcement or otherwise appropriate role. The lawful basis for sharing personal data with these recipients is the compliance necessary related to a legal obligation for which OnlyBabes is subject to, or necessary for, a legitimate interest, or where it is in the interests of the wider public to do so.

13. Your rights regarding personal data

You have certain rights regarding the collection and processing of personal data. You may exercise these rights by contacting us using the contact details set out in Section 17 below.

There are certain circumstances, subject to certain exemptions, that you will have the right to:

Withdraw your consent to the processing of your personal data: Please note that withdrawing your consent will not affect the lawfulness of any processing carried out before you have withdrawn your consent.

Request to know or access to your personal data: You may request to receive a copy of the personal data we hold about you and to check that OnlyBabes is lawfully processing it.

Request correction of the personal data that OnlyBabes holds about you: You may correct any incomplete or inaccurate personal data about you.

Request the deletion or erasure of your personal data: You may request OnlyBabes to delete or remove personal data where there is no legitimate reason for OnlyBabes continuing to process it. You also may request OnlyBabes to delete or remove your personal data where you have exercised your right to object to processing (see below). Please note that OnlyBabes may not always be able to comply with your request of the deletion or erasure of your personal data for specific legal reasons.

Request the restriction of processing of your personal data: You may request OnlyBabes to suspend the processing of personal data about you if you want to establish its accuracy, or the reason for processing it.

Request the transfer of some sections of your personal data to another party.

You have the right to object to processing of your personal data where OnlyBabes is relying on a legitimate interest for the processing and there is something about your personal situation which makes you want to object to processing on this ground.

OnlyBabes does not process personal data that is subject to solely automated decision-making, where that decision-making is likely to have a legal or similarly significant effect on you.

You also have the right:

To lodge a complaint with a data protection regulator.

Depending on your location, to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights, or appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by contacting us using the contact details set out in Section 17 below.

14. Exercising your rights

If you would like to exercise your rights that are set out in Section 13, you may do so by contacting OnlyBabes using the contact details set out in Section 17 below.

If you submit the request yourself, please make sure your request contains sufficient information to allow us to confirm your identity and properly understand, evaluate, and respond to your request.

In order to verify your identity, OnlyBabes may need to request additional personal data from you, taking into consideration our relationship with you and the sensitivity of your request. In certain circumstances, OnlyBabes may decline a privacy rights request, particularly where we are unable to verify your identity.

If your request is made through a third-party authorized by you, OnlyBabes will also require proof that the third-party has permission to submit such a request on your behalf (e.g., a signed document evidencing the third-party has authority to make the request on your behalf).

15. Control over your personal data

Modifying and deleting your personal data: If you have an account with OnlyBabes, you may update your account settings on our Site. Please note that changes to your settings may require a reasonable amount of time to take effect.

Access to device information: You may control the Services' access to your Technical Data through your "Settings" app on your device. As an example, you can withdraw permission for the Services to access your network devices and geolocation.

Email notification opt-out: OnlyBabes does not currently send emails to you for direct marketing purposes. However, we may send email notifications which are related to your account (e.g. for Creators, when you have a new subscriber, or when you received a new tip, or when somebody renewed their subscription with you). You may opt-out of receiving certain types of email communications from OnlyBabes by changing your notification preferences on the Site. You may also email us using the contact details set out in Section 17 below. Please include "Email notification opt-out" in the email's subject line and include your name and your account email address in the body of your email.

You cannot opt-out of certain automated email notifications that are necessary to provide the Services or are otherwise required in accordance with applicable law (e.g. account verification, transactional communications, changes or updates to features of the Services, technical and security notices).

16. Retention of your personal data

OnlyBabes will retain your personal data for as long as it is reasonably necessary to fulfil the purposes for which it was collected, and as set out in this Privacy Policy. OnlyBabes will typically retain personal data for a period of 6 months after the deletion or deactivation of an account on the Site.

Please note that:

OnlyBabes will delete your personal data sooner where a shorter retention period is required by applicable law.

OnlyBabes will retain your personal data for a longer period when we deem it necessary to carry out the processing activities that are set out in this Privacy Policy; as an example:

-where it is necessary to comply with laws and regulatory obligations that are applicable to OnlyBabes (e.g. adhering to record keeping, maintenance requirements and financial or tax reporting requirements, which in some cases is up to 7 years; also if OnlyBabes receives a valid legal request, such as a preservation order or search warrant, related to an account);

-for purposes of identifying and reporting illegal activity, protecting the safety of OnlyBabes’ Users and third parties, or otherwise protecting the rights and property of our users, us, and other third parties;

-for purposes of legal proceedings; and

-for the purposes of responding to requests from third parties in relation to your account, such as requests received from, or investigations by, law enforcement authorities, or relevant governmental authorities and applicable non-governmental organizations.

The personal data that we retain and the length of time for which it is retained will be determined on a case-by-case basis, depending on the particular circumstances.

17. Assistance and contact information

If you have questions about this Privacy Policy, or how we process your personal data, please submit a ticket through your account or email us at [email protected].

18. United States privacy disclosures

Residents of the states of California, Colorado, Connecticut, Nevada, Utah, and Virginia: These U.S. State Privacy Disclosures ("U.S. Disclosures") supplement the information contained in the Privacy Policy by providing additional information about our personal data processing practices relating to individual residents of these states. Unless otherwise expressly stated, all terms defined in this Policy retain the same meaning in these U.S. Disclosures.

For the purposes of these U.S. Disclosures, personal data does not include publicly available information or de-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

No sales for targeted advertising

OnlyBabes does not sell or share personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual's activities across businesses or distinctly-branded websites, applications, or other services ("targeted advertising").

Sensitive information

Although sensitive information may be disclosed for a business purpose as described below, OnlyBabes does not sell or share sensitive information for the purpose of targeted advertising.

The following personal data elements we, or our service providers, collect may be classified as "sensitive" under certain privacy laws ("sensitive information") including:

-username and password;

-social security number, driver's license number, and passport number;

-government identifiers (such as driver's license numbers);

-partial payment card number and the name registered with your payment card; and

-Face Recognition Data (biometric information which is collected and processed by our third-party providers).

We use this sensitive information for the purposes set out in Section 10, to the extent necessary for the operation of our Services, or to enter into and perform a contract with you, or to comply with legal and regulatory requirements, or to protect the safety of our Users and third parties, or as otherwise permissible for our own internal purposes consistent with all applicable laws.

De-identified information

OnlyBabes may at times receive, or process personal data, to create de-identified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual. When OnlyBabes maintains de-identified information, we will maintain and use the information in a de-identified form and we will not attempt to re-identify the information except as required or permitted by applicable law.

Minors

The Services are strictly intended for individuals 18 years of age or older. Anyone under 18 years of age is not permitted to use the Services. By using the Services, you represent that you are 18 years of age or older.

CALIFORNIA SPECIFIC DISCLOSURES

The following disclosures apply to residents of the State of California:

Personal data collection

California law requires that OnlyBabes provide disclosures about what personal data we collect by reference to the categories of personal data set forth within California law. To address this obligation, we have identified the relevant California personal data category for the personal data set out in more detail at Section 8 above:

Identifiers: Your name, address, phone number, email address, passport or other government identity information including driver's license information, account information, or other similar identifiers.

Customer Records: Your driver's license number, passport number, partial debit card information, partial credit card information, bank account information or other payment or financial information.

Protected Classification Characteristics: Your age, date of birth, and gender.

Commercial Information: Information about products or services purchased and your use of the Services.

Biometric Information: Which is limited to Face Recognition Data, used by our third-party providers for age and identity verification purposes. Face Recognition Data remains with our third-party providers and OnlyBabes does not collect, receive, possess, or have access to this data.

Internet and Network Information: This category includes device information, log-in information, and analytics data.

Sensory Information: Pictures, videos and the other content you upload to the Site.

Professional and/or employment Information: Examples would be the business or organization you are employed or associated with and, if applicable, your title with that business or organization and information relating to your role with the business or organization.

Other Personal Data: This category includes communication preferences, customer service and communication history, personal data an individual permits us to see when interacting with us through social media, personal data an individual provides us in relation to a question or request, and messages you send us through the Services or make available to us on social media.

Inferences: Information generated from your use of the Services.

We may disclose all of these categories of personal data for a business purpose to service providers or other third parties, as outlined in this Policy.

Disclosure of personal data

As set out in Section 12 above, we may disclose the categories of personal data identified above to the following categories of third parties for various business purposes: our group and affiliated companies, service providers, our professional advisers, business partners, other businesses as needed to provide our Services, and certain third parties where you have provided consent, where it is in connection with a corporate transaction, or where we are required by law or in connection with other legal process.

Sources of personal data

OnlyBabes collects personal data directly from you, from your browser or device when you interact with our Services, and from our business partners and affiliates, third parties you direct to share information with us, and other third-party providers. For more information, please see Section 11 above.

Purpose for collection

OnlyBabes collects personal data about you for the purposes set out above in Section 10.

Notice of financial incentives

As discussed above, OnlyBabes does not currently use any cross-site tracking technologies and we do not sell personal data collected about you, or share personal data collected about you for cross-context behavioral advertising. We do not currently send emails for direct marketing purposes.

We do currently offer a referral program, whereby existing Creators on the Site can use their unique referral code to introduce people who are interested in becoming Creators on the Site, and the referring Creator will receive referral payments, based on the referred Creator's earnings. The referral program is subject to our Terms of Service and any such referral payments are calculated, and limited, as described in the Referral Program Terms in our Terms of Service.

Any personal data associated with the referring Creator, or the referred Creator, is processed in accordance with this Privacy Policy.

OnlyBabes has determined that the value of the referral program is reasonably related to the value of the personal data we process in connection with the referral program (based on our reasonable but our sole determination). We estimate the value of the personal data we receive and otherwise process in connection with the referral program by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the referral program.

You may exercise your rights in relation to your personal data as outlined in this Policy, and as applicable, by submitting a ticket through your account or by emailing [email protected].