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OVERVIEW

Luxemo Limited, company incorporated in Cyprys with registration number HE425497 and registered office at Loutrakiou, 5 CHARA VENEZIA, 1st floor, Flat/Office 101, Strovolos 2027, Nicosia, Cyprus ("FriendsOnly", "we", "us", "our") respects your privacy and is committed to protecting the personal data we hold about you.

FriendsOnly Privacy Policy helps you to understand our practices regarding to personal data which is collected by FriendsOnly. Information specified herein includes every kind of information which is located on our website www.FriendsOnly.me, some services which could be offered by Us to You via FriendsOnly.me, or otherwise through your connections with us (social media pages, FriendsOnly website (or related services), collectively the “Services”). FriendsOnly is responsable for your personal data processing. FriendsOnly shall be considered as the only personal data collected controller (in the context of use of website Services).

FriendsOnly Privacy Policy provides you a right to contact us (as defined in the bottom herein) and find out information about us required by the appropriate legislative acts .

PERSONAL DATA WE COLLECT

2.1. We will process Your personal data based on other legal bases such as:

2.1.1. Our legal obligations;

2.1.2. The performance of Our contract with You (i.e. the provision of Our Services to you);

2.1.3. Our legitimate business interests (i.e. for fraud prevention, maintaining the security of Our network and services, seeking to improve the Services that We provide and Your interaction with us). Whenever We rely upon on this lawful basis We assess Our business interests to make sure that they do not override Your rights. Furthermore, in some cases You have the right to object to this processing;

2.1.4. With Your consent for direct marketing purposes so that We may keep You fully up to date with other products and services that We supply and think may be of interest to you. Where We rely upon consent, We will need Your explicit consent, which may be removed at any time.

Please be informed that when you use FriendsOnly we collect some types of information which can be related to you, and this information can be identifiable and not identifiable. All the types of personal data We collect specified in this Privacy Policy.

2.2. Categories of Personal Data We Collect

2.2.1. Login/telephone number, password We collect;

2.2.2. Information about the permitted age;

2.2.3. Email;

2.2.4. The data you enter in the feedback form;

2.2.5. Unique identifiers, browser type and settings, device type and settings, operating system, mobile network information. We also collect information about the interaction of Your browsers and devices with Our Services, including OS, IP address, URL of Your request; and

2.2.6. Your video within complaints procedure.

2.3. When We Collect Your Personal Data

2.3.1. Within your registration procedure;

2.3.2. Within providing by you the respective payment information; and

2.3.3. When you contact to us via measures specified herein; and

2.3.4. When You sent complaints to FriendsOnly.

2.4. How We Use Your Personal Data

2.4.1. We strive to ensure that the content can be enjoyed by everyone, and to keep the content appropriate, tasteful and lawful. To do that, we collect and process your personal data for the following business and commercial purposes:

2.4.1.1. Communicating with you by email and text about the Services, verifying your identity, responding to support inquiries or, sharing information about the Services;

2.4.1.2. Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law;

2.4.1.3. As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties;

2.4.1.4. Providing, improving, operating, developing, predicting, or performing, including maintaining or servicing accounts, enhancing the Services and your experience;

2.4.1.5. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

2.4.1.6. Debugging to identify and repair errors that impair existing intended functionality;

2.4.1.7. Undertaking internal research for technological development and demonstration;and

2.4.1.8. Undertaking activities to verify or maintain the quality or safety of the Services owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Services owned, manufactured, manufactured for, or controlled by us.

2.5. How We Obtain Your Personal Data

2.5.1. We collect your personal data from the following categories of sources:

2.5.1.1. Directly from you. When you provide it to us directly to open an account and use the Services, or when you update the information in your account;

2.5.1.2. Automatically or indirectly from you. For example, through and as a result of your use of and access to the Services;

2.5.1.3. We also collect IP addresses and browser types from the devices you use; and

2.5.1.4. From our service providers.

Please be advised that if we intend to collect additional categories of personal data, we will provide you with a new notice at or before the time of collection.

2.6. Why We Obtain Your Personal Data

2.6.1. For Our legitimate interests;

2.6.2. For the performance of a contract with You;

2.6.3. To comply with a legal obligation; and

2.6.4. To make sure that Your use of Our Services is legal.

2.7. Who We Share Your Personal Data With

2.7.1. We share personal data with the following categories of third parties:

2.7.1.1. Government bodies/agencies or regulators when it is required to do so by law of appropriate jurisdiction;

2.7.1.2. Our service providers; and

2.7.1.3. Our affiliated entities.

2.8. Legal Bases for Processing

2.8.1. We process personal data for, or based on, one or more of the following legal bases:

2.8.1.1. Performance of a Contract. By using the Services, you have contracted with us through the Terms of Service, and we will process certain personal data to perform under that contract.

2.8.1.2. Legitimate Interests. We may process personal data for our legitimate interests, including complying with any applicable law, rule or regulation, investigation or remedy; enforcing our Terms of Service; protecting our, our users' or others' rights, property and safety; and detecting and resolving any fraud or security concerns.

2.8.1.3. Compliance with Legal Obligations and Protection of Individuals. We may process personal data to comply with our legal obligations, including as required by valid legal process, governmental request, and to protect those individuals who use our Services and others.

2.9. Personal Data We Share

2.9.1. We share with the following categories of third parties the following categories of personal data for a business purpose:

2.9.1.1. Identifiers (e.g. name, address, email address, government ID, IP address): Service providers.

2.9.1.2. Identifiers (e.g. account name): Other Subscribers and guests.

2.9.1.3. Audio, electronic, visual, thermal, olfactory, or similar information (e.g. content you create): Service providers.

2.10. Personal Data We collect about You

2.10.1. A summary of the Personal Data that We process, when We collect it, how We use it and why We use it (i.e. the legal basis for processing) is listed below:-

Personal Data When We collect How We use Why We use

login/telephone number,

password In registration procedure We use Your personal and contact information to register You as a User and identify You in Our Services. You can use it to log in Necessary for the performance of a contract with you

information about the permitted age In registration procedure We need to make sure that Your use of Our services is legal Necessary to comply with a legal obligation

email In feedback form We use it to communicate with you Necessary for the performance of a contract with you

the data you enter in the feedback form, your request and the history of correspondence with you When You communicate with support We use it to communicate with you Necessary for the performance of a contract with you

unique identifiers, browser type and settings, device type and settings, operating system, mobile network information. We also collect information about the interaction of Your browsers and devices with Our services, including OS, IP address, URL of Your request When You use Our services We use it to optimise Our service and to improve Our app, Website, services, direct marketing, User relationships, behaviour profiling and experiences Necessary for Our legitimate interests

all data, including videos and posts, that the Creators publish When You as a Creator are publishing content We use it to show Creator’s profile all Users Necessary for the performance of a contract with you

All content sent in chat When You chatting with Creator We use this to prevent the publication of prohibited content Necessary to comply with a legal obligation

YOUR RIGHTS REGARDING PERSONAL DATA

3.1. You have certain rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Policy, or by following instructions provided in this Privacy Policy or in communications sent to you.

3.2. Your rights vary depending on the laws that apply to you, but may include:

3.2.1. The right to be informed about Our collection and processing of Your personal data including without limitation the legal basis for the collection and processing, the categories of data, the methods of data use, the envisaged period for which the personal data will be retained. This Privacy Policy should tell You everything You need to know, but You can always contact Us to find out more or to ask any questions.

3.2.2. The right to access Your personal data We collect about you, commonly referred to as “Subject Access Requests”, which provides you, as the data subject, the right to obtain a copy of Your personal data that We are processing for You

In accordance with the EU regulations (GDPR requirements) We are required to respond without undue delay to all Subject Access Requests in practice this means We have to respond within one (1) month of receipt of the Subject Access Request.

3.2.3. The right to have Your personal data rectified if any of Your personal data that We collect and process is in any way inaccurate or incomplete.

3.2.4. The right of erasure (otherwise known as “the right to be forgotten”), i.e. the right to ask Us to delete or otherwise dispose of any of Your personal data that We process. Please note that this is not an absolute right and We may not be able to comply with Your request as We may be legally obliged to continue to retain Your personal data for a specific period

3.2.5. The right to restrict (i.e. prevent) the processing of Your personal data by us.

3.2.6. The right to object to Us processing Your personal data for a particular purpose or purposes. Please note that the right to object only applies in certain circumstances and will depend on the purposes or legal basis for the processing.

3.2.7. The right to data portability. This only applies where You have provided personal data to Us directly, the legal basis for Us processing Your personal data is i) consent or ii) for the performance of a contract and We are processing Your data using automated means. In such instances You have the right to receive Your personal data (or request that We transfer it to another Controller) in a structured, commonly used and machine readable format.

3.3. Accessing, Modifying, Rectifying, and Correcting Collected Personal Data

3.3.1. We must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us. Any updates or corrections to your information may be made through your account settings.

3.3.2. Depending on the laws that apply to you, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, please contact us at the information provided at the end of this Privacy Policy. We reserve the right to deny access as permitted or required by applicable law.

3.3.3. The verifiable consumer request must:

3.3.3.1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

3.3.3.2. We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

3.4. Consumer Request by an Authorized Agent

3.4.1. If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require an email be sent to [email protected], along with all of the below items:

3.4.1.1. Proof that you gave the authorized agent signed permission to submit the request.

3.4.1.2. Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.

3.4.1.3. To verify your identity, depending on the nature of the request, we may also require a valid Government Issued ID, email address, and the last 4 digits of the social security number.

3.4.2. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

3.4.3. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require to create an account with us. However, if you do have an existing login, we will require you to log in to submit a request. We will only use personal data provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

3.5. Your European Union and UK Privacy Rights

3.5.1. In addition to the above-listed rights, European Union and UK privacy law provide individuals with enhanced rights in respect of their personal data. These rights may include, depending on the circumstances surrounding the processing of personal data:

3.5.1.1. The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;

3.5.1.2. The right to request the restriction of processing of personal data or object to processing of personal data carried out pursuant to

i. a legitimate interest (including, but not limited to, processing for direct marketing purposes); or

ii. performance of a task in the public interest.

3.5.2. In certain circumstances, the right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and

3.5.3. In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.

Please consider that we are capable to require amended information from you to validate your request. To exercise any of the rights above, please visit https://friendsonly.me/faq or email us at [email protected]ly.me.

3.6. Your California Privacy Rights

3.6.1. Californian legislation (in particular, “Shine the Light” law) permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

3.6.2. There are following additional rights provided by the California Consumer Privacy Act (“CCPA”) for California residents:

3.6.2.1. Right to Know. You have the right to request that we disclose certain information to you about the personal data we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:

i. The categories of personal data collected about you;

ii. The categories of sources from which we collected your personal data;

iii. The categories of personal data that we have sold or disclosed about you for a business purpose;

iv. The categories of third parties to whom your personal data was sold or disclosed for a business purpose;

v. Our business or commercial purpose for collecting or selling your personal data; and

vi. The specific pieces of personal data we have collected about you.

3.6.2.2. Data Portability. You have the right to request a copy of personal data we have collected and maintained about you in the past 12 months.

3.6.2.3. Right to Deletion. You have the right to request that we delete the personal data we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your personal data, we may deny your request or may retain certain elements of your personal data if it is necessary for us or our service providers to:

3.6.2.3.1. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

3.6.2.3.2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

3.6.2.3.3. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;

3.6.2.3.4. Debug to identify and repair errors that impair existing intended functionality;

3.6.2.3.5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;

3.6.2.3.6. To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

3.6.2.3.7. Complete the transaction for which the personal data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you;

3.6.2.3.8. Comply with a legal obligation; and

3.6.2.3.9. Otherwise use the personal data, internally, in a lawful manner that is compatible with the context in which you provided the information.

3.6.2.4. Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:

3.6.2.4.1. Deny you goods or services.

3.6.2.4.2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

3.6.2.4.3. Provide you a different level or quality of goods or services.

3.6.2.4.4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

3.6.2.5. `Right to Opt-Out/In. You have the right to opt-out of the sale of your personal data. You also have the right to opt-in to the sale of personal data. However, we do not sell your personal data.

3.6.3. If You want to exercise your California privacy rights described above, please submit a verifiable request to us by:

visiting

help
; or emailing us at [email protected].

3.6.4. If you have an account with us, you can exercise any of the above rights from your profile. If you don’t have a profile or if you are unable to access, control, or delete your information from within your profile, you can contact us through any of the above methods.

3.6.5. Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal data.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

3.7. Consumer Request by an Authorized Agent

3.7.1. If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require an email be sent to [email protected], along with all of the below items:

Proof that you gave the authorized agent signed permission to submit the request.

Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.

3.7.2. To verify your identity, depending on the nature of the request, we may also require a valid Government Issued ID (not expired), email address, and the last 4 digits of the social security number.

3.7.3. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require to create an account with us. However, if you do have an existing login, we will require you to log in to submit a request. We will only use personal data provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

3.7.4. We will acknowledge receipt of the request within seven (7) business days of its receipt. We will respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to forty-five (45) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

3.7.5. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

YOUR CHOICES

4.1. You are capable to choise and change settings regarding infromation we collect about you via your web browser settings or our help on the following issues:

4.1.1 Communications Opt-Out. You are capable to opt out of receiving email communications from FriendsOnly. You can do it at any time when you follow the opt-out link provided by any email message you received from FriendsOnly. You can also change your nonifications settings or contact us via FriendsOnly contacts specified it this Privacy Polycy.

4.1.2. Cookie. You are capable to change any your cookies settings. Please find out more invormation about cookies we use in this Privacy Policy and Cookies Policy on FriendsOnly legal information.

4.1.3. Location Information. You are capable both prevent, or limit us in our ability to receive your location information. Please contuct us via email if you have an issues concerning incapability to change your location settings.

PROTECTING PERSONAL DATA

5.1. When You provide Your personal data through Our Website, Our applications, this information is transmitted across the internet securely using industry standard encryption. Your personal data will be held encrypted on secure servers.

5.2. Please pay attention to the fact that there no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES.

6.1. Collection of Personal Data from Children. Our Services are not intended for anyone under 18. Anyone under 18 years of age is not permitted to use the Services, and we do not knowingly collect information from children under the age of 18. By using the Services, you represent that you are 18 years of age or older.

6.2. Identity Verification. We require checks for Subscribers to ensure that we do not knowingly offer our Services to or collect personal data from anyone under 18 or anyone using a false identity. These checks involve providing certain information to one or more of our service providers.

6.3. Payment Information. Payments made by users to access content are processed by our third-party payment providers. For example, when you make a payment that is processed by a payment provider, you will provide that third-party with your credit card number, credit card expiration date, and security code, which they process and store subject to their privacy policy and terms of service.

6.4. Third-Party Websites and Services. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. As a convenience, we may reference or provide links to third- party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business (including, but not limited to, our service providers). You access these third-party services at your own risk. This Privacy Policy does not apply to any third-party services; please refer to the Privacy Policy or policies for such third-party services for information about how they collect, use, and process personal data.

6.5. Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third-party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third- party acquirers and may be among those assets transferred.

6.6. International Use. Your personal data will be stored and/or processed in Cyprus and other countries. By your use of the Services, you acknowledge that we will transfer your data to, and store your personal data in, the above countries, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the above countries, including to law enforcement and/or national security authorities in those countries. For transfers of data into and out of the European Economic Area, pursuant to Article 46 of the General Data Protection Regulation, we use data transfer agreements subject to EU-approved standard contractual clauses.

6.7. Do Not Track. We currently do not use any cross-site tracking technologies and do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms. Note, however, that you may find information about how to block or reject certain tracking technologies in our Cookie Policy.

Public personal data

7.1. All data, including videos and posts, that the Creators publish on their profile is public.

CHANGES TO THIS Privacy Policy

8.1. Any changes that We make to Our Privacy Policy in the future will be posted on Our app and Website.

8.2. Where appropriate, We will notify You of the changes when You next visit Our Website. This Privacy Policy was last updated on [-] 2021.

ADDITIONAL INFORMATION AND ASSISTANCE

9.1. We would appreciate for your suggestions, requests or comments concerning this Privacy Policy.

Please do not hesitate to contact Us via [email protected].