PRIVACY POLICY

Baal holdding Limited ("we", "us", "our") respects your privacy and we are committed to protecting the Personal Data we process about you. Baal holdding Limited is the owner and operator of Tocmi, a social network and content sharing platform which enables:

(i) "Creators" to share and monetise their own content (as well as subscribe to, and view, the content of other Creators);

(ii) "Fans" to subscribe to, and view, the content of Creators.

Introduction

This privacy policy ("Policy") explains our practices with respect to the Personal Data processed about our Creators and Fans. It also explains our practices with respect to the Personal Data processed about individuals that feature in content uploaded by a Creator ("Content Collaborators"), and where we process Personal Data in the context of our business relationships.

We process your Personal Data when you use Tocmi and for the provision of the services that we offer from time to time via Tocmi (the "Services"). We are a "data controller" of the Personal Data that we process in connection with the Services. This means that we decide the reasons why we process Personal Data about you and how we do so.

If you have any questions about this Policy or our processing of your Personal Data, please see Section 19 (assistance and contact information) for information about how to contact us.

What is 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.

Informing us of changes

It is important that the Personal Data we hold about you is accurate and current. Please 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 Tocmi.

Applicability of this Policy (18+)

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

Our 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.

Third-party links

Tocmi 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.

We are 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 / notices of those third parties to find out how your Personal Data may be used.

If you do not wish to provide Personal Data

We need to collect certain Personal Data from you to provide you with access to the Services, or specific features and functionalities of the Services, in accordance with our contract with you (i.e. our Terms of Service). We are also required to process certain Personal Data in accordance with applicable laws. Please note that if you do not wish to provide Personal Data where requested, we may not be able to provide you with access to the Services or specific features and functionalities of the Services.

Updates to this Policy

We may update this Policy from time to time, and any updates will be effective upon our posting of the revised Policy on Tocmi. We will use reasonable efforts to notify you in the event that material updates are made to this Policy, such as sending you a feed notification or a chat message via your account on Tocmi.

Categories of Personal Data

We process, or our third-party providers process on our behalf, different kinds of Personal Data about Creators, Content Collaborators and Fans, which we have grouped together as follows:

Category of Personal Data	Description
User Data	Creators and Content Collaborators - full name* - alias, if applicable - residential address - city of birth - country of birth - country of residence* - email address - telephone number - a copy of the government identity document that you provide to us* - a "selfie" of you holding your government identity document* - third-party social media handle / personal website address (used to further verify your age and identity and to help us better understand the content which you are likely to share on Tocmi) - signature on release forms if you feature in a Creator's content* Please note: Items marked with * will be requested for Content Collaborators where you are required to provide a release form. Fans - email address - telephone number
Account Data	Creators - profile name - password - avatars and headers of your Creator account - your subscriptions, subscribers and referrals - posts that you have made to your Creator account - comments on posts made from your Creator account - chat messages between you and other users - customer support queries that you submit to us 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 queries that you submit to us
Financial Data	Creators - payment card details* - billing address - funds added to your wallet - bank account information - pay-out country - corporate or business entity name, country, identification number and identification type - VAT number - tax identification number and issuing country - W-9 form (for US Creators only) - 1099-MISC form (for US Creators only) - 1099-NEC form (for US Creators only) Fans - payment card details* - billing address - funds added to your wallet * Please note: Any payments made to view the content of Creators are processed by our third-party payment providers. We do not receive your full payment card number, payment card expiration date, or the security code. Instead, the payment provider provides us with a "token" that represents your account, your payment card's expiration date, payment card type and the first six and last four digits of your payment card number.
Transaction Data	Creators - earnings - pay-out 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 or other electronic network activity information, including: - internet protocol (IP) address (and country code) - user agent
Usage Data	Creators and Fans We use cookies where necessary to allow you to browse the Services and access certain pages of Tocmi. With your consent, we use non-essential cookies to enable us to recognise Referring Users, and Referred Creators, under the Referral Program in our Terms of Service. More information on our use of cookies can be found in our Cookie Notice. We currently do not 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 behavioural advertising. Face Recognition Data Creators, Content Collaborators and Fans where applicable - As described in more detail in Section 9 (our onboarding processes), during onboarding, our third-party providers may use face recognition technology, so they can digitally verify you. - Face Recognition Data is collected by and remains with our third-party provider. We do not ourselves collect, receive, possess, or have access to Face Recognition Data at any time.

Our onboarding processes

CREATORS

We have processes in place that are intended to ensure that Creators on Tocmi: (i) are at least 18 years of age; and (ii) verify their identity. Before you can start a Creator account, we will:

• Ask you to provide Creator User Data, as set out at Section 8 (categories of Personal Data).
• Check your country of residence. This check is intended to ensure lawful access to Tocmi and the Services.
• Ask you to provide Financial Data, as set out at Section 8 (categories of Personal Data). This is necessary so that payments can be made to Creators for content, and so that Creators can access their earnings via Tocmi. Financial Data is also collected as a verification and anti-fraud measure.
• Ask you to go through a third-party age and identity verification process, as described below.
• Check that you have not previously been banned from using Tocmi and our Services (e.g. for violating our Terms of Service).

CONTENT COLLABORATORS

We have processes in place that are intended to ensure that Content Collaborators on Tocmi: (i) are at least 18 years of age; and (ii) verify their identity. Before you can feature in content uploaded by a Creator we will ask you to go through a third-party age and identity verification process, as described below. You may also be required to provide a release form.

FANS

We have processes in place that are intended to ensure that: (i) all Fans on Tocmi are at least 18 years of age; and (ii) Fans in certain circumstances or locations verify their identity. Before you can start a Fan account, we will:

• Ask you to provide Fan User Data, as set out at Section 8 (categories of Personal Data).
• Check your country of residence. This check is intended to ensure lawful access to Tocmi and the Services.
• Ask 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.
• Ask you to go through a third-party process to gain further assurances of your age. This may include a third-party age and identity verification process, or third-party age estimation process, as described below. The specific process will depend upon your location, or other circumstances (e.g. if we detect suspicious activity on your account).

THIRD-PARTY AGE AND IDENTITY VERIFICATION

• We use third-party providers to conduct age and identity verification.
• 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 described at Section 8 (categories of Personal Data), we do 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, we receive from our third-party providers Third-Party Onboarding 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.
• As described at Section 8 (categories of Personal Data), we do not collect, receive, possess, or have access to any Face Recognition Data collected or processed by our third-party providers through this process.
• 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 the technology has predicted that you look under a set threshold), 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 Tocmi 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 and security on Tocmi 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 and preventing unlawful activity, and preventing fraudulent access to Tocmi.

• Periodic authentication of your age and 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 request the withdrawal of 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.

International data transfers

We share your Personal Data within our group companies and to our third parties, as set out at Section 12 (sharing your Personal Data).

In some circumstances, this will involve transferring your data outside the UK, the EEA and Switzerland. We make those transfers: (i) to countries that have been deemed to provide an adequate level of protection for Personal Data; (ii) using appropriate safeguards; or (iii) where otherwise authorised by applicable law.

Please contact us using the contact details set out at Section 19 (assistance and contact information) if you would like further information on the specific mechanism used by us when transferring your Personal Data outside the UK, the EEA and Switzerland.

Exercising your rights

If you would like to exercise your rights set out at Section 14 (your rights regarding Personal Data), you may do so by contacting us using the contact details set out at Section 19 (assistance and contact information).

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

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

If your request is made by a third-party authorised by you, we will also require proof that the third-party has permission to submit the request on your behalf (such as a signed document or a valid power of attorney evidencing that the third-party has authority to make the request).

Choices and control over your Personal Data

Modifying and deleting your Personal Data: If you have an account with us, you may update your account settings on Tocmi. Please note that changes to your settings may require some 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. For instance, you can withdraw permission for the Services to access your network devices and geolocation.

Email notification opt-out: We currently do not send emails for direct marketing purposes. However, we do send email notifications which are related to your account (e.g. for Creators, where you have a new subscriber, you have received a new tip, or somebody has renewed their subscription with you). You may opt-out of receiving certain types of email communications from us by changing your notification preferences on Tocmi. You may also email us using the contact details set out at Section 19 (assistance and contact information). Please include "E-mail notification opt-out" in the email's subject line and include your name and your account email address in the body of the email.

Please note that 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 / updates to features of the service, technical and security notices).

Retention of Personal Data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which it was collected, as set out in this Policy. 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.

We determine the periods for which we normally retain Personal Data as follows:

• Providing our Services: Where we need to use Personal Data to provide you with our Services, or specific parts of our Services, we will retain your Personal Data for the lifetime of your account or as long as necessary to provide you with the relevant feature or functionality of our Services.
• Trust and safety: If you have (or we reasonably suspect that you have) violated our Terms of Service, or where we otherwise need to retain information to identify and report illegal activity or protect the safety of our users and third parties, we will retain certain Personal Data for as long as necessary to conduct our investigations, assist with any investigations by law enforcement or non-governmental authorities (e.g. NCMEC), and enforce any removal of offending users or content.
• Compliance with applicable laws and regulatory obligations: For example: (i) identity record keeping / maintenance requirements in certain locations and financial / tax reporting requirements, which in some cases is up to 7 years; (ii) if we receive a valid legal request (such as a preservation order or search warrant, related to your account); (iii) complying with regulatory investigations or proceedings. We will delete your Personal Data sooner where a shorter retention period is required by applicable law.
• Legal claims: Personal Data will be retained in accordance with applicable statutory limitation periods. In certain circumstances we may need to retain this longer, for example, to defend ourselves in litigation about a claim or complaint related to you.

Assistance and contact information

We have appointed a Data Protection Officer ("DPO") whose responsibilities include, together with our team of privacy specialists, responding to questions, requests, and concerns in relation to this Policy and our use of Personal Data. If you have questions about this Policy, or how we process your Personal Data, please submit a ticket through your account or email us at [email protected].