PRIVACY POLICY

SugarBabyOnline, operated by [LEGAL ENTITY NAME], with its registered address at [LEGAL ADDRESS], RFC [RFC], hereinafter referred to as “SugarBabyOnline,” “SBO,” “we,” “us,” “our,” or the “Platform,” is responsible for the processing of personal data collected from users, visitors, creators, SugarBabies, SugarDaddies, subscribers, purchasers, and other individuals who interact with the Platform.

This Privacy Policy explains in greater detail how SugarBabyOnline collects, uses, stores, protects, transfers, and otherwise processes personal data.

Because SugarBabyOnline is an adult-oriented digital platform, certain users may voluntarily provide or the Platform may need to process information that is particularly private or sensitive in nature, including identity documents, age-verification information, selfies, facial or biometric verification information, financial and payout information, private communications, and intimate or sexually explicit content.

We recognize the importance of protecting this information and intend to apply additional safeguards appropriate to its nature.

This Privacy Policy should be read together with the SugarBabyOnline Terms and Conditions and any other applicable policies.

Where applicable law requires a specific form of consent, express consent, or separate notice, SugarBabyOnline will provide and obtain it through the appropriate mechanism.

1. IDENTITY AND INFORMATION OF THE DATA CONTROLLER

The entity responsible for the processing of personal data is:

Legal Name: [LEGAL ENTITY NAME]

RFC: [RFC]

Registered Address: [LEGAL ADDRESS]

Website: sugarbabyonline.com

General Contact: contact@sugarbabyonline.com

Privacy Contact: [PRIVACY EMAIL]

Legal Contact: [LEGAL EMAIL]

Telephone: [PHONE NUMBER]

SugarBabyOnline acts as the data controller, responsible entity, or equivalent entity to the extent applicable under the laws governing the relevant processing activity.

We determine the purposes and means of processing personal data described in this Privacy Policy, except where a third party independently determines its own processing purposes and means.

2. WHAT PERSONAL DATA WE COLLECT

Depending on how you interact with SugarBabyOnline, we may collect different categories of personal data.

We do not necessarily collect every category from every user.

A. Identification and age information

This may include:

• Full legal name
• Date of birth
• Age
• Nationality
• Government-issued identification
• Identification document number
• Identification document images
• Passport information
• INE or equivalent government-issued identification
• Profile photograph
• Selfie photographs
• Identity-verification results
• Age-verification results
• Verification status
• Electronic signature or acknowledgment
• Information necessary to establish that a person is 18 or older

B. Contact information

This may include:

• Email address
• Telephone number
• Username
• Account contact information
• Communication preferences

C. Account information

This may include:

• Username
• Password or authentication credentials
• Profile information
• Profile photograph
• Biography
• City or general location
• Account settings
• Followers and following
• Subscription status
• Creator status
• Verification status
• Referral information
• Account history

D. Technical and security information

This may include:

• IP address
• Browser type
• Operating system
• Device type
• Device identifiers
• Language
• Regional settings
• Login information
• Session information
• Date and time of access
• Security logs
• Authentication events
• Error logs
• Fraud-prevention signals
• Information concerning suspicious or unauthorized activity

E. Location information

Depending on the functionality used and applicable law, we may process:

• Country
• State or province
• City
• General or approximate location
• Location voluntarily provided by the user

We do not intend to require precise geolocation merely to browse the Platform unless that functionality is specifically disclosed and legally permitted.

3. PAYMENT, BILLING AND FINANCIAL INFORMATION

SugarBabyOnline may process information necessary to facilitate:

• Subscriptions
• Purchases
• Tips
• Paid posts
• Paid messages
• Other digital-content transactions
• Creator earnings
• Creator payouts
• Accounting
• Fraud prevention
• Chargeback management
• Tax and legal compliance

Depending on the transaction and payment method, this may include:

• Billing name
• Billing address
• Transaction amount
• Currency
• Transaction identifier
• Payment status
• Payment-provider information
• Payout information
• Bank account information
• CLABE or equivalent banking information
• Account-holder information
• Chargeback information
• Refund information
• Tax-related information where legally required

Creator payout information

Creators and SugarBabies who wish to receive earnings through the Platform may be required to provide banking or payout information.

This information may be necessary to:

1. Identify the recipient of the funds;
2. Process creator payouts;
3. Prevent fraud;
4. Comply with applicable financial, tax, accounting, or legal requirements; and
5. Resolve payment disputes or payment errors.

Banking and payout information is restricted information and is not intended to appear publicly on creator profiles.

Where a third-party payout provider is used, the information may be transmitted to that provider to process the requested payout.

4. PAYMENT-CARD INFORMATION

Payment-card transactions may be processed directly by third-party payment processors.

Depending on the payment method, SugarBabyOnline may receive only limited transaction information rather than the complete card number.

We do not intentionally request or retain payment-card security codes such as CVV after authorization.

Users should never post or send payment-card numbers, passwords, banking credentials, authentication codes, or other unnecessary financial credentials through public profiles, posts, comments, or messages.

Payment processors may independently process payment information under their own privacy policies and terms.

5. SENSITIVE AND HIGHLY PRIVATE PERSONAL DATA

Some information processed through SugarBabyOnline may constitute sensitive personal data under applicable law, while other information may be highly private or confidential even if a particular legal classification does not apply.

Depending on the circumstances, this may include:

• Biometric information
• Facial images used for identity verification
• Biometric identifiers or templates
• Liveness-verification information
• Information concerning sexual life or sexual preferences
• Intimate photographs or videos
• Private sexual or intimate communications
• Government identification documents
• Financial or banking information
• Other information classified as sensitive by applicable law

We will process information classified as sensitive personal data only when there is an applicable lawful basis and, where required, the corresponding express consent.

The voluntary upload of intimate content does not by itself authorize SugarBabyOnline to use that content for unrelated purposes.

6. IDENTITY AND AGE VERIFICATION

SugarBabyOnline is strictly an 18+ platform.

We may require identity and age verification before allowing certain users to access certain features, particularly creator monetization features.

Verification may include:

• Government-issued identification
• INE
• Passport
• Date of birth
• Selfie
• Liveness verification
• Facial comparison
• Biometric verification
• Electronic authentication
• Electronic signature
• Other verification methods

The purpose of verification may include:

• Confirming that a user is 18 or older;
• Confirming identity;
• Preventing impersonation;
• Preventing fraudulent accounts;
• Preventing minors from accessing prohibited services;
• Protecting users;
• Complying with applicable law;
• Meeting payment-provider requirements; and
• Protecting the security and integrity of the Platform.

Government identification documents are not intended to be publicly displayed on user profiles.

7. BIOMETRIC AND FACIAL VERIFICATION INFORMATION

Where identity-verification technology involves facial comparison, liveness detection, biometric identifiers, or similar technology, such information may be processed by SugarBabyOnline and/or a specialized verification provider.

Depending on the verification method, the provider may create or process biometric information or biometric templates.

Where technically and legally appropriate, SugarBabyOnline may receive only a verification result, such as:

“Verified” / “Not Verified”

rather than retaining the underlying biometric information.

Where biometric information is retained, we intend to retain it only for as long as reasonably necessary and legally permitted for the applicable verification, security, fraud-prevention, dispute-resolution, or legal purposes.

8. INFORMATION VOLUNTARILY PROVIDED BY USERS

You may voluntarily provide information when you:

• Create an account;
• Complete your profile;
• Become a SugarBaby;
• Become a SugarDaddy;
• Upload photographs;
• Upload videos;
• Publish posts;
• Send messages;
• Follow another user;
• Subscribe to a creator;
• Send a tip;
• Purchase paid content;
• Submit verification information;
• Contact customer support;
• Submit a complaint;
• Submit a safety report;
• Participate in referrals;
• Participate in promotions; or
• Otherwise communicate with SugarBabyOnline.

You are responsible for ensuring that information you voluntarily provide is accurate and that you have the legal right to provide it.

9. INFORMATION ABOUT OTHER PEOPLE

If you upload or provide information involving another person, you are responsible for ensuring that you have the necessary rights, permissions, authorizations, and consents.

This is particularly important when content includes:

• Another person’s face;
• Another person’s name;
• Private information;
• Photographs;
• Videos;
• Intimate material;
• Sexual content;
• Identification documents; or
• Other information capable of identifying that person.

Every person appearing in adult or sexually explicit content on SugarBabyOnline must be 18 years of age or older.

10. CREATOR AND SUGARBABY INFORMATION

Creators and SugarBabies may provide additional information necessary to operate their profiles and receive earnings.

This may include:

• Display name
• Profile photograph
• Biography
• Social-media links
• Subscription price
• Creator content
• Earnings information
• Payout information
• Banking information
• Tax-related information
• Verification information
• Referral information

Certain information is intentionally made available to other users through profile functionality.

However, restricted information such as government identification, banking information, verification records, and internal security information is not intended to be publicly displayed.

11. USER-GENERATED CONTENT

SugarBabyOnline may process:

• Photographs
• Videos
• Audio
• Text
• Posts
• Comments
• Paid posts
• Subscriber-only content
• Pay-per-view content
• Paid messages
• Profile information
• Messages
• Reports
• Support communications

User-generated content may contain personal data.

For example, a photograph or video may identify the person appearing in it.

The Platform processes such content to provide the services requested by users, including profile display, subscriptions, paid content, communication, moderation, security, and other Platform functionality.

12. ADULT AND INTIMATE CONTENT

SugarBabyOnline is an adult-oriented platform and may host lawful adult or sexually explicit content created and uploaded by eligible adults.

Such content may contain highly private personal information.

The processing of such content may be necessary to:

• Display creator profiles;
• Provide subscriptions;
• Provide paid posts;
• Provide pay-per-view content;
• Provide paid messages;
• Process purchases;
• Moderate content;
• Prevent abuse;
• Protect users;
• Investigate reports;
• Comply with applicable law; and
• Maintain Platform security.

SugarBabyOnline does not permit content involving minors.

No person under 18 may appear in, participate in, or be sexually depicted through Platform content.

Non-consensual intimate content, exploitation, trafficking, sexual abuse, or other prohibited content is not permitted.

13. PRIVATE MESSAGES

Messages sent through SugarBabyOnline are not intended to be publicly displayed.

However, users should understand that private communications are processed by the Platform’s technical systems.

Messages may be processed, accessed, reviewed, retained, or disclosed when reasonably necessary for:

• Delivery;
• Technical operation;
• Security;
• Fraud prevention;
• Abuse prevention;
• Investigation of reports;
• Moderation;
• Enforcement of Platform rules;
• Protection of users;
• Legal compliance; or
• Response to valid legal requests.

Access to private communications should be restricted to authorized personnel or systems with a legitimate operational, security, safety, or legal need.

SugarBabyOnline does not represent that private messages are protected by absolute or legally privileged confidentiality.

14. INFORMATION VISIBLE TO OTHER USERS

Depending on your account settings and Platform functionality, other users may see information such as:

• Username;
• Profile photograph;
• Biography;
• City or general location;
• Public posts;
• Public content;
• Followers;
• Following;
• Subscription-related information; and
• Other information intentionally published by you.

Users should assume that anything intentionally published publicly may be viewed, copied, captured, or redistributed by others.

SugarBabyOnline does not intend to make the following publicly accessible through ordinary profile functionality:

• Government identification;
• INE;
• Passport;
• Banking information;
• Payment credentials;
• Verification records;
• Biometric information;
• Private security information; or
• Internal moderation information.

15. PURPOSES OF PROCESSING

We may process personal data for the following purposes:

1. Creating and maintaining accounts;
2. Authenticating users;
3. Verifying age;
4. Verifying identity;
5. Operating the Platform;
6. Providing requested services;
7. Facilitating subscriptions;
8. Processing purchases;
9. Processing tips;
10. Processing paid content;
11. Processing creator payouts;
12. Providing customer support;
13. Preventing fraud;
14. Detecting prohibited activity;
15. Protecting account security;
16. Moderating content;
17. Investigating reports;
18. Preventing minors from accessing restricted services;
19. Enforcing our Terms and Conditions;
20. Maintaining accounting records;
21. Complying with tax obligations;
22. Complying with legal obligations;
23. Responding to lawful governmental requests;
24. Protecting users;
25. Protecting our rights and property;
26. Resolving disputes;
27. Preventing payment abuse and chargebacks;
28. Maintaining and improving the Platform; and
29. Performing other purposes described in this Privacy Policy.

16. SECONDARY PURPOSES

Where permitted by applicable law, certain personal data may also be processed for secondary purposes, including:

• Internal analytics;
• Service improvement;
• Product development;
• Platform optimization;
• User-experience analysis;
• Aggregated statistical analysis;
• Security analysis;
• Fraud analysis; and
• Promotional communications.

Where applicable law requires consent for a secondary purpose, we will request the applicable consent.

Users may withdraw consent for optional promotional communications without affecting necessary account, security, transactional, or legal communications.

17. COOKIES AND SIMILAR TECHNOLOGIES

SugarBabyOnline may use:

• Cookies;
• Pixels;
• Local storage;
• SDKs;
• Session technologies;
• Similar technologies.

These technologies may be used for:

• Authentication;
• Security;
• Session management;
• Preferences;
• Analytics;
• Performance;
• Fraud prevention;
• Platform functionality; and
• Marketing where legally permitted.

Where legally required, non-essential technologies will be subject to an appropriate consent mechanism.

A separate Cookie Policy may provide additional information.

18. FRAUD, SECURITY AND ABUSE PREVENTION

SugarBabyOnline may process account, technical, behavioral, transactional, and other information to detect and prevent:

• Fraud;
• Identity fraud;
• Fake accounts;
• Account takeover;
• Payment abuse;
• Chargebacks;
• Unauthorized access;
• Automated abuse;
• Platform manipulation;
• Scams;
• Impersonation;
• Prohibited activity.

Fraud-prevention systems may use automated tools and third-party services.

These processes may result in additional verification, restrictions, suspension, or manual review.

19. AUTOMATED PROCESSING AND MODERATION

SugarBabyOnline may use automated technologies and human review to assist with:

• Fraud detection;
• Security;
• Spam detection;
• Content moderation;
• Account protection;
• Recommendation systems;
• Platform analytics;
• Payment-risk assessment;
• Identity verification.

Automated systems may generate alerts or flags requiring human review.

Where applicable law provides specific rights concerning automated decision-making, users may exercise those rights through the applicable legal process.

20. CONTENT MODERATION

SugarBabyOnline may review content, accounts, messages, reports, or other information where reasonably necessary to:

• Detect illegal content;
• Detect prohibited content;
• Protect minors;
• Investigate non-consensual intimate content;
• Investigate fraud;
• Investigate harassment;
• Protect users;
• Enforce Platform rules;
• Protect Platform security; or
• Comply with law.

Moderation may involve automated systems, human reviewers, or both.

21. THIRD-PARTY SERVICE PROVIDERS

SugarBabyOnline may use third-party service providers, including:

• Hosting providers;
• Cloud providers;
• Identity-verification providers;
• Payment processors;
• Banking and payout providers;
• Email providers;
• Customer-support providers;
• Analytics providers;
• Security providers;
• Content-storage providers;
• Fraud-prevention providers;
• Communication providers; and
• Other technology providers.

These providers may process personal data necessary to provide their services.

Where applicable, contractual, technical, and organizational safeguards will be used to limit access and processing.

22. PAYMENT PROVIDERS AND VERIFICATION PROVIDERS

Third-party providers may independently process information under their own privacy policies.

For example, a payment provider may process payment-card information, while an identity-verification provider may process government identification, selfie, facial or liveness information.

Where a provider independently determines the purposes and means of its processing, that provider may act as an independent data controller or equivalent entity under applicable law.

Users should review the applicable provider’s privacy documentation when presented during the relevant process.

23. DATA TRANSFERS

Personal data may be processed or stored in jurisdictions other than the country where the user resides.

Depending on the providers used by SugarBabyOnline, infrastructure may be located in:

• Mexico;
• United States;
• Canada;
• European countries; or
• Other jurisdictions.

International transfers will be carried out subject to applicable legal requirements and appropriate safeguards where required.

24. DISCLOSURE OF PERSONAL DATA

SugarBabyOnline may disclose personal data when reasonably necessary for:

• Platform operation;
• Payment processing;
• Creator payouts;
• Identity verification;
• Fraud prevention;
• Security;
• Customer support;
• Accounting;
• Professional advisers;
• Corporate transactions;
• Legal compliance;
• Government authorities;
• Law enforcement where legally permitted or required; or
• Protection of rights and safety.

We do not sell government identification documents or verification information as a commercial product.

We do not disclose personal data to unrelated third parties merely because they request it.

25. GOVERNMENT AND LAW-ENFORCEMENT REQUESTS

SugarBabyOnline may disclose information to courts, government authorities, regulators, law-enforcement agencies, or other authorized entities when:

• Required by applicable law;
• Required by valid legal process;
• Required by a court order;
• Necessary to comply with a lawful governmental request;
• Necessary to investigate suspected unlawful activity where legally permitted; or
• Necessary to protect individuals or prevent serious harm where legally permitted.

Where legally permitted, we may evaluate the validity and scope of a request before responding.

26. CORPORATE TRANSACTIONS

If SugarBabyOnline is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar corporate transaction, personal data may be transferred as part of the relevant transaction.

Any such transfer will remain subject to applicable privacy and data-protection requirements.

27. INFORMATION SHARED BETWEEN USERS

SugarBabyOnline provides communication and social functionality through which users may voluntarily share personal information.

Once you voluntarily provide information to another user, SugarBabyOnline cannot guarantee what that recipient will subsequently do with it.

A recipient may potentially:

• Save it;
• Screenshot it;
• Photograph it;
• Record it;
• Copy it; or
• Share it elsewhere.

Users should carefully consider whether to share:

• Home addresses;
• Telephone numbers;
• Government identification;
• Banking information;
• Passwords;
• Precise location;
• Private photographs;
• Intimate information; or
• Information about third parties.

28. DATA SECURITY

SugarBabyOnline intends to maintain reasonable administrative, technical, and organizational safeguards appropriate to the nature of the personal data processed.

These measures may include:

• Role-based access;
• Authentication;
• Access controls;
• Encryption where appropriate;
• Secure transmission;
• Security logging;
• Monitoring;
• Backups;
• Security updates;
• Restricted administrative access;
• Vendor controls;
• Confidentiality obligations; and
• Incident-response procedures.

Restricted access

Access to highly sensitive information, including:

• Government identification;
• INE;
• Passport information;
• Verification information;
• Biometric information;
• Banking information; and
• Other restricted financial information

should be limited to authorized individuals who have a legitimate need to access such information.

Technical access to the Platform does not automatically authorize access to personal data.

Developers, programmers, contractors, technical personnel, administrators, and service providers should receive only the permissions necessary to perform their authorized functions.

29. SECURITY INCIDENTS

If SugarBabyOnline becomes aware of a security incident affecting personal data, we may:

• Investigate the incident;
• Contain the incident;
• Secure affected systems;
• Reset credentials;
• Restrict accounts;
• Preserve relevant evidence;
• Remediate vulnerabilities;
• Document the incident; and
• Notify individuals or authorities where required by applicable law.

Security incidents may include:

• Unauthorized access;
• Unauthorized disclosure;
• Loss;
• Theft;
• Destruction;
• Alteration;
• Credential compromise; or
• Unauthorized system access.

30. DATA RETENTION

SugarBabyOnline does not necessarily delete all information immediately when an account is closed.

Different categories of information may have different retention periods.

Information may be retained when reasonably necessary for:

• Legal compliance;
• Accounting;
• Tax obligations;
• Payment records;
• Chargeback management;
• Fraud prevention;
• Security;
• Dispute resolution;
• Investigations;
• Enforcement of agreements;
• Protection of legal rights; or
• Compliance with lawful requests.

Government identification and verification information should be retained only for the period reasonably necessary for the applicable verification, security, fraud-prevention, dispute-resolution, legal, or regulatory purpose.

Where personal data is no longer reasonably necessary, it may be deleted, anonymized, or securely disposed of, subject to applicable retention requirements.

31. ACCOUNT DELETION

Users may request deletion of their accounts through available Platform functionality or by contacting us.

Deletion of an account does not necessarily mean immediate deletion of every record associated with the account.

We may retain certain information where necessary or legally permitted for:

• Completed transactions;
• Accounting;
• Tax obligations;
• Fraud prevention;
• Security;
• Dispute resolution;
• Legal claims;
• Investigations;
• Legal obligations; or
• Protection of rights.

32. ARCO RIGHTS

Where Mexican law applies, individuals may exercise their applicable ARCO rights:

Access

Request information regarding personal data held and processed by us.

Rectification

Request correction of inaccurate or incomplete personal data.

Cancellation

Request deletion of personal data where legally appropriate.

Opposition

Object to certain processing activities where legally applicable.

Requests may be submitted to:

[PRIVACY EMAIL]

We will process requests in accordance with applicable legal requirements.

33. REQUIREMENTS FOR ARCO REQUESTS

To process an ARCO request, we may require information reasonably necessary to:

1. Identify the requester;
2. Verify identity or legal authority;
3. Identify the personal data involved;
4. Identify the right being exercised; and
5. Determine the appropriate response.

We may request additional information where reasonably necessary to prevent unauthorized disclosure.

34. WITHDRAWAL OF CONSENT

Where processing is based on consent, users may withdraw that consent subject to applicable legal limitations.

Withdrawal does not necessarily invalidate processing lawfully performed before withdrawal.

Processing may continue where another lawful basis exists, including:

• Legal obligations;
• Contract performance;
• Security;
• Fraud prevention;
• Payment processing;
• Legal claims;
• Defense of rights; or
• Other legally recognized grounds.

35. LIMITATION OF USE OR DISCLOSURE

Where applicable law provides such rights, users may request limitations on certain uses or disclosures of personal data.

Some processing cannot be disabled when necessary for:

• Account security;
• Fraud prevention;
• Payment processing;
• Legal compliance;
• Platform functionality;
• Enforcement of the Terms and Conditions; or
• Protection of users.

36. MINORS AND PERSONAL DATA

SugarBabyOnline is strictly intended for persons 18 years of age or older.

We do not knowingly permit persons under 18 to create or maintain accounts.

If we discover that a person under 18 has created an account or provided personal data, we may suspend or terminate the account and take appropriate measures regarding the information, subject to applicable law.

If you believe that a minor has created an account or appears in content, please contact:

[SAFETY EMAIL]

37. PROTECTION OF THIRD-PARTY PRIVACY

Users must not upload or distribute another person’s private information without appropriate authorization.

This includes:

• Government identification;
• Banking information;
• Private addresses;
• Private communications;
• Private photographs;
• Non-consensual intimate material;
• Personal contact information;
• Confidential documents; and
• Other sensitive personal information.

SugarBabyOnline may remove content or restrict an account when reasonably necessary to protect privacy or safety.

38. NON-CONSENSUAL INTIMATE CONTENT

SugarBabyOnline prohibits non-consensual intimate content.

This includes, among other things:

• Intimate images shared without authorization;
• Secretly recorded sexual content;
• Revenge pornography;
• Stolen private photographs;
• Unauthorized sexual recordings;
• Deepfakes or synthetic intimate content involving a person without appropriate authorization;
• Content intended to expose or humiliate a person; and
• Content sexualizing or involving minors.

Reports concerning such material may receive priority review.

Where legally appropriate, SugarBabyOnline may remove content, restrict accounts, preserve relevant information, and cooperate with competent authorities.

39. INTELLECTUAL PROPERTY AND PERSONAL DATA IN CONTENT

Users generally retain ownership of content they own, subject to the rights granted under the Terms and Conditions.

By uploading content, users authorize SugarBabyOnline to process that content as necessary to:

• Store it;
• Host it;
• Display it;
• Deliver it;
• Process payments;
• Provide subscriptions;
• Provide paid-content functionality;
• Moderate it;
• Secure it;
• Back it up; and
• Operate the Platform.

Personal data contained within that content remains subject to applicable privacy laws and this Privacy Policy.

40. INFORMATION RECEIVED FROM THIRD PARTIES

We may receive information from:

• Identity-verification providers;
• Payment providers;
• Payout providers;
• Fraud-prevention providers;
• Security providers;
• Social-login providers;
• Referral partners;
• Other users;
• Service providers; and
• Government or law-enforcement authorities where legally permitted or required.

We may combine third-party information with information collected directly from users where legally permitted and reasonably necessary.

41. ELECTRONIC RECORDS

SugarBabyOnline may maintain electronic records concerning:

• Account registration;
• Privacy-policy acceptance;
• Consent;
• Terms acceptance;
• Identity verification;
• Purchases;
• Subscriptions;
• Payments;
• Payouts;
• Reports;
• Communications;
• Security events; and
• Other relevant Platform activities.

These records may be retained for legal, contractual, security, accounting, fraud-prevention, and dispute-resolution purposes.

42. ELECTRONIC CONSENT

Where legally permitted, consent or acknowledgment may be provided electronically through:

• Checkboxes;
• Account registration;
• Electronic acceptance;
• Authentication;
• Electronic signatures;
• Verification flows; or
• Other legally appropriate mechanisms.

Where a specific type of consent requires a particular legal form, SugarBabyOnline will use a mechanism intended to satisfy the applicable requirement.

43. CONSENT FOR SENSITIVE PERSONAL DATA

Where applicable law requires express consent for the processing of sensitive personal data, SugarBabyOnline will obtain such consent through an appropriate mechanism.

Depending on the applicable requirement, this may include:

• An express checkbox;
• Electronic signature;
• Authentication;
• Verification flow; or
• Another legally valid mechanism.

Sensitive personal data will be processed only for identified and legitimate purposes and subject to appropriate safeguards.

44. DATA MINIMIZATION AND PRIVACY BY DESIGN

SugarBabyOnline intends to apply privacy-by-design and data-minimization principles.

Where reasonably feasible, this includes:

• Collecting information necessary for identified purposes;
• Restricting access to sensitive information;
• Separating public profile information from verification information;
• Using role-based permissions;
• Limiting administrative access;
• Avoiding unnecessary exposure of personal information;
• Limiting retention;
• Using specialized verification providers where appropriate; and
• Applying security measures appropriate to the nature of the information.

Technical personnel should not receive unrestricted access to personal information merely because they maintain or develop the Platform.

45. ADMINISTRATIVE AND TECHNICAL ACCESS

SugarBabyOnline may use developers, programmers, contractors, hosting providers, system administrators, and other technical personnel.

Technical personnel may require access to Platform infrastructure to perform their authorized duties.

However, technical access and personal-data access are separate concepts.

Where technically feasible, access to:

• Government IDs;
• INE;
• Passport documents;
• Bank information;
• Payout information;
• Verification records;
• Biometric information;
• Private communications; and
• Other highly sensitive information

should be restricted through role-based permissions and least-privilege controls.

No developer or contractor should automatically receive unrestricted access to sensitive user information merely because they work on the Platform.

46. ANONYMIZED AND AGGREGATED INFORMATION

SugarBabyOnline may create aggregated, statistical, or anonymized information that does not reasonably identify an individual.

Such information may be used for:

• Analytics;
• Business intelligence;
• Platform improvement;
• Security analysis;
• Performance measurement;
• Research; and
• Reporting.

Where information has been properly anonymized and can no longer reasonably identify an individual, it may be used in accordance with applicable law.

47. PROMOTIONAL COMMUNICATIONS

Users may receive promotional communications where legally permitted and, where required, after obtaining appropriate consent.

These may include:

• Platform announcements;
• Promotions;
• Product updates;
• Creator-related communications;
• Marketing messages.

Users may opt out of promotional communications through the applicable unsubscribe mechanism or account settings.

Transactional, security, legal, and account-related communications may continue where necessary.

48. PRIVACY REQUEST FEES

SugarBabyOnline will not charge a fee merely to exercise applicable privacy rights except where applicable law expressly permits such a charge.

Where legally permitted, reasonable costs may apply in circumstances expressly authorized by law.

49. AUTHENTICATION OF PRIVACY REQUESTS

To protect personal data against unauthorized disclosure, SugarBabyOnline may require reasonable identity verification before responding to a privacy request.

The verification information requested should be proportionate to the sensitivity of the request.

We may reject or delay a request where we reasonably cannot establish the identity or authority of the requester.

50. LEGAL AND REGULATORY COMPLIANCE

We may process and retain personal data when reasonably necessary to:

• Comply with applicable laws;
• Respond to legal proceedings;
• Respond to lawful governmental requests;
• Meet accounting or tax obligations;
• Prevent fraud;
• Investigate suspected unlawful conduct;
• Protect users;
• Protect SugarBabyOnline;
• Establish legal claims;
• Exercise legal rights; or
• Defend against legal claims.

Where disclosure is legally required, SugarBabyOnline may disclose information reasonably necessary to comply with the applicable requirement.

51. INTERNATIONAL USERS

SugarBabyOnline may be accessible internationally.

If you access the Platform from outside Mexico, your personal data may be transferred to, processed in, or stored in Mexico or other countries where SugarBabyOnline or its service providers operate.

Depending on your country of residence, additional privacy rights may apply.

Nothing in this Privacy Policy is intended to remove or limit mandatory rights that cannot legally be excluded.

52. THIRD-PARTY WEBSITES AND SERVICES

SugarBabyOnline may contain links to or integrations with third-party services.

Examples may include:

• Social-media platforms;
• Payment providers;
• Verification providers;
• External websites;
• Analytics providers;
• Communication services.

When you use a third-party service, that service may process your personal information under its own terms and privacy policy.

SugarBabyOnline does not control independent third-party privacy practices.

53. CHILD SAFETY AND AGE PROTECTION

Because SugarBabyOnline is an adult-oriented platform, age protection is a fundamental security requirement.

We may use:

• Age verification;
• Identity verification;
• Automated detection;
• Reports;
• Human review;
• Account restrictions; and
• Other security measures

to prevent minors from accessing or appearing in prohibited content.

If we receive a credible report concerning a minor, we may take immediate protective measures while investigating.

54. DATA RELATING TO CONTENT REMOVAL AND REPORTS

When users report content or accounts, we may retain information relating to the report, including:

• Reporter information;
• Report details;
• Reported account;
• Reported content;
• Relevant communications;
• Technical information;
• Moderation decisions; and
• Investigation records.

This information may be retained for safety, security, legal, fraud-prevention, and enforcement purposes.

55. DATA RELATING TO DISPUTES AND CHARGEBACKS

When a payment is disputed, reversed, charged back, or otherwise contested, SugarBabyOnline may process information necessary to:

• Investigate the transaction;
• Respond to payment providers;
• Prevent fraud;
• Protect users;
• Recover improperly credited funds;
• Resolve disputes; and
• Maintain accounting records.

This may include transaction information, account information, communications, and relevant technical records.

56. DATA RELATING TO CREATOR EARNINGS

Creator earnings information may include:

• Subscription revenue;
• Tip revenue;
• Paid-content revenue;
• Platform commission;
• Payment-provider adjustments;
• Chargebacks;
• Reversals;
• Payouts;
• Payout status;
• Tax-related information.

Creator earnings information is restricted and is not intended to be publicly displayed unless the Platform expressly provides a public feature for such information.

57. TAX AND ACCOUNTING INFORMATION

SugarBabyOnline may process information necessary for:

• Tax reporting;
• Accounting;
• Payment records;
• Creator payouts;
• Invoicing;
• Financial reporting;
• Compliance with applicable legal requirements.

Creators may be required to provide additional information before receiving payouts.

58. BUSINESS RECORDS

SugarBabyOnline may retain business records relating to:

• Purchases;
• Subscriptions;
• Tips;
• Paid content;
• Creator earnings;
• Payouts;
• Refunds where applicable;
• Chargebacks;
• Account activity;
• Tax records;
• Customer support;
• Complaints;
• Legal matters.

These records may be retained for the period required by applicable law or reasonably necessary for legitimate business, legal, accounting, security, or dispute-resolution purposes.

59. PRIVACY AND PAYMENT SECURITY

SugarBabyOnline intends to use appropriate technical safeguards when transmitting personal and financial information.

Payment information may be processed through specialized third-party payment providers.

Users should also maintain appropriate security practices, including:

• Using strong passwords;
• Not sharing login credentials;
• Using secure devices;
• Keeping devices updated; and
• Reporting suspicious activity.

No internet-based system can guarantee absolute security.

60. USER RESPONSIBILITY FOR ACCOUNT SECURITY

Users are responsible for maintaining the confidentiality of their account credentials.

Users should immediately contact SugarBabyOnline if they believe:

• Their account has been compromised;
• Their password has been stolen;
• Unauthorized transactions occurred;
• Their verification information was misused; or
• Another person accessed their account.

61. DATA BREACHES INVOLVING THIRD PARTIES

SugarBabyOnline may rely on independent providers for payment processing, identity verification, hosting, infrastructure, email, security, or other services.

If a third-party provider experiences a security incident, SugarBabyOnline may coordinate with that provider and take measures required by applicable law.

62. CHANGES TO THIS PRIVACY POLICY

SugarBabyOnline may update this Privacy Policy from time to time to reflect:

• Changes in law;
• Changes in technology;
• Changes in Platform functionality;
• New service providers;
• Changes in processing activities;
• Security improvements; or
• Business operations.

The updated version will be posted with a new “Last Updated” date.

Where applicable law requires additional notice or consent, SugarBabyOnline will provide it.

63. RELATIONSHIP WITH TERMS AND CONDITIONS

This Privacy Policy should be read together with the SugarBabyOnline Terms and Conditions.

The Terms and Conditions govern matters including:

• User conduct;
• Prohibited activities;
• Adult-content rules;
• Subscriptions;
• Payments;
• Tips;
• Paid content;
• Creator obligations;
• Account suspension;
• Termination;
• Intellectual property;
• Liability; and
• Disputes.

This Privacy Policy primarily governs the collection and processing of personal data.

Where mandatory privacy rights apply, applicable law will control.

64. CONSUMER AND ELECTRONIC COMMERCE INFORMATION

Where applicable consumer-protection law applies to a transaction, SugarBabyOnline intends to provide consumers with the information required before completing a purchase, including applicable information regarding:

• The service or digital content being purchased;
• Price;
• Currency;
• Applicable taxes or charges;
• Payment method;
• Subscription duration;
• Whether the subscription renews automatically;
• Applicable cancellation or refund conditions;
• Material purchase conditions; and
• Transaction confirmation.

Mexican consumer-protection authorities emphasize the importance of making the provider’s identity and contact information, purchase terms, prices/costs, payment methods, privacy information, and transaction receipts or confirmations available in electronic commerce.

Nothing in this Privacy Policy limits mandatory consumer rights.

65. ELECTRONIC TRANSACTION CONFIRMATIONS

For purchases and other transactions, SugarBabyOnline or its payment providers may generate electronic records or confirmations containing information such as:

• Transaction identification number;
• Date and time;
• Amount;
• Currency;
• Product or service purchased;
• Creator or account involved;
• Subscription period, where applicable;
• Payment status; and
• Applicable payment information.

Users should retain transaction confirmations for their records.

Where a legally required invoice, receipt, or other fiscal document is applicable, it will be provided according to the applicable process and requirements.

66. CONTACT INFORMATION FOR PRIVACY MATTERS

For privacy questions, ARCO requests, data-protection requests, or concerns regarding personal data, contact:

SugarBabyOnline

Legal Entity: [LEGAL ENTITY NAME]

Address: [LEGAL ADDRESS]

RFC: [RFC]

Privacy Email: [PRIVACY EMAIL]

Legal Email: [LEGAL EMAIL]

General Email: contact@sugarbabyonline.com

Telephone: [PHONE NUMBER]

Safety Email: [SAFETY EMAIL]

Copyright Email: [COPYRIGHT EMAIL]

67. PRIVACY COMPLAINTS AND CONCERNS

If you believe that your personal data has been processed improperly, disclosed without authorization, or otherwise mishandled, you may first contact SugarBabyOnline using the privacy contact information above.

Where applicable law provides additional administrative or regulatory remedies, individuals retain those rights.

68. PRIVACY BY DESIGN COMMITMENT

SugarBabyOnline intends to continuously improve its privacy and security architecture.

Because the Platform may process particularly sensitive information, we intend to consider privacy and security when developing new functionality, including:

• New payment methods;
• New verification methods;
• New communication tools;
• New creator features;
• New analytics;
• New recommendation systems;
• New moderation tools; and
• New administrative functionality.

Where reasonably feasible, sensitive information should remain separated from ordinary Platform functionality.

69. NO PUBLIC DISPLAY OF VERIFICATION OR BANKING INFORMATION

Government identification, verification information, biometric information, banking information, payout credentials, and other restricted financial information are not intended to be displayed publicly on user profiles.

Such information should only be accessible through authorized systems and personnel with a legitimate operational or legal need.

70. NO SALE OF SENSITIVE VERIFICATION INFORMATION

SugarBabyOnline does not intend to sell:

• Government identification documents;
• INE documents;
• Passport documents;
• Biometric verification information;
• Identity-verification records; or
• Banking or payout information

as commercial products.

Any disclosure will be limited to legitimate operational, contractual, legal, security, payment, verification, or other purposes described in this Privacy Policy and permitted by applicable law.

71. YOUR CONTROL OVER YOUR PERSONAL INFORMATION

Subject to applicable law, you may have rights concerning your personal information, including rights to:

• Know what information is processed;
• Request access;
• Request correction;
• Request deletion where legally available;
• Object to certain processing;
• Withdraw consent where applicable;
• Limit certain uses where legally available; and
• Submit privacy requests through the applicable procedures.

These rights may be subject to legal exceptions and verification requirements.

72. ACKNOWLEDGMENT

By creating an account or using SugarBabyOnline, you acknowledge that you have had the opportunity to review this Privacy Policy.

Where consent is legally required, the applicable consent will be requested through the appropriate mechanism.

You understand that SugarBabyOnline may process personal data to:

• Operate the Platform;
• Verify eligible users;
• Process transactions;
• Process creator payouts;
• Protect users;
• Prevent fraud;
• Moderate content;
• Maintain security;
• Provide customer support;
• Comply with legal obligations; and
• Perform the other purposes described in this Privacy Policy.

You also understand that certain information may be processed by third-party providers, including payment, identity-verification, hosting, security, analytics, and other technology providers.

73. IMPORTANT PRIVACY NOTICE REGARDING HIGHLY SENSITIVE INFORMATION

Because SugarBabyOnline is an adult-oriented digital platform, some users may voluntarily provide information that is particularly private.

This may include:

• Government identification;
• INE;
• Passport;
• Selfies;
• Facial verification;
• Biometric verification;
• Date of birth;
• Banking information;
• Payout information;
• Tax information;
• Private messages;
• Intimate photographs;
• Intimate videos;
• Sexual-content information; and
• Other highly private information.

SugarBabyOnline will apply safeguards appropriate to the nature of this information and will process it only for identified purposes permitted by applicable law.

Users should understand, however, that no online system can guarantee absolute security, and information voluntarily shared with another user may be copied or redistributed by that person.

74. FINAL STATEMENT

SugarBabyOnline is committed to responsible processing of personal data and to implementing reasonable privacy, security, access-control, and data-minimization measures appropriate to the information processed.

Because SugarBabyOnline may process identity documents, sensitive personal data, biometric or verification information, financial information, private communications, and adult intimate content, the Platform intends to apply enhanced safeguards to particularly sensitive information.

Nothing in this Privacy Policy is intended to waive, limit, or exclude any mandatory right or protection granted to individuals under applicable law.

If you have questions about this Privacy Policy or the processing of your personal data, please contact SugarBabyOnline using the information provided above.

Last Updated: October 2, 2026

Version: 1.0

SugarBabyOnline

[LEGAL ENTITY NAME]