1. Introduction

E.U.P LTD (“we”, “us”, “our”) respects your privacy and we are committed to protecting the Personal Data we process about you. E.U.P LTD is the owner and operator of www.europeaches.com (“EuroPeaches”), 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); and (ii) “Fans” to subscribe to, and view, the content of Creators.
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 EuroPeaches and for the provision of the services that we offer from time to time via EuroPeaches (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.

1. 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.

1. Informing us of changes

The Personal Data we hold about you must be 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 EuroPeaches.

1. 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 EuroPeaches 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.

1. Third-party links

EuroPeaches 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.

1. 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.

1. 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 EuroPeaches. 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 EuroPeaches.

1. 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 DataDescriptionUser DataCreators 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 EuroPeaches)
  • 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

Third-Party Onboarding DataThe following types of Personal Data are collected directly by our third-party providers during onboarding:
Creators and Content Collaborators

• • a copy of the government identity document that you provide to our third-party providers
  • a short .gif, taken from a “selfie” that you provide to our third-party providers
  • the results of the third-party age and identity verification process (pass / fail and reason for failing)
  • metadata associated with the third-party age and identity verification process (e.g. start and finish time)

Fans

• • where we conduct third-party age and identity verification of Fans, a copy of the government identity document that you provide to our third-party providers
  • where we carry out third-party age estimation, or third-party age and identity verification of Fans, a short .gif, taken from a “selfie” that you provide to our third-party providers
  • the results of the third-party age estimation process or third-party age and identity verification process (pass / fail and reason for failing)
  • metadata associated with the third-party age estimation process or third-party age and identity verification process (e.g. user start and finish time)

Please see Section 9 (our onboarding processes) for further information. Third-Party Onboarding Data and Technical Data does not include Face Recognition Data, as set out below.
Account DataCreators

• • 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 DataCreators

• • 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 DataCreators

• • 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 DataCreators and Fans
Internet or other electronic network activity information, including:

• • internet protocol (IP) address (and country code)
  • user agent

Usage DataCreators and Fans
We use cookies where necessary to allow you to browse the Services and access certain pages of EuroPeaches. 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 DataCreators, 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.

1. Our onboarding processes

CREATORS
We have processes in place that are intended to ensure that Creators on EuroPeaches: (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 EuroPeaches 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 EuroPeaches. 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 EuroPeaches 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 EuroPeaches: (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 EuroPeaches 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 EuroPeaches 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

1. • Why does EuroPeaches 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 EuroPeaches 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 EuroPeaches.
   • 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 privacy@europeaches.com. 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.
2. How / why your Personal Data is used and lawful bases for processing

We process Personal Data for, or based on, one or more of the following legal bases:

• • Consent: Your consent is requested only in specific circumstances which includes, for example, the processing of: (i) Face Recognition Data by our third-party providers as part of the age and identity verification process for all Creators (and for Fans in certain circumstances or locations); and (ii) age estimation captures (which may involve the use of Face Recognition Data) by our third-party providers for Fans in certain locations. Please see Section 9 (our onboarding processes) for further information.
  • Performance of a contract: By using the Services, you have contracted with us through our Terms of Service, and we will process Personal Data to perform that contract (e.g. to fulfil transactions between Fans and Creators and process Creator earnings) and to enforce the terms of that contract.
  • Legitimate interests: We may process Personal Data if it is in our, or a third-party’s, legitimate interests (as detailed in the table below). This may include, for example, investigating and responding to a report made through our DMCA takedown procedure, to protect a Creator’s intellectual property rights.
  • Compliance with legal obligations: We may process Personal Data to comply with applicable law, rules and regulations in the locations where we operate (e.g. complying with financial / tax reporting requirements).
  • Task carried out in the public interest: We may process Personal Data as necessary for a task carried out in the public interest. This may include, for example, reporting illegal activity to relevant law enforcement authorities, other governmental authorities and non-governmental organisations.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
The table below indicates the purposes for which your Personal Data is processed and the legal justification for the processing. Some of the above grounds for processing will overlap and there may be several grounds which justify the processing:
Purpose / activityLawful basis for processingAccount creation (both Creators and Fans).Performance of a contract
Creator and Content Collaborator age and identity verification and where applicable, subsequent authentication (specifically in relation to the processing of Face Recognition Data).
Please see Section 9 (our onboarding processes) for further information.Consent
Fan age and identity verification and where applicable, subsequent authentication, in certain circumstances or locations (specifically in relation to the processing of Face Recognition Data).
Please see Section 9 (our onboarding processes) for further information.Consent
Fan age estimation, in certain locations (specifically in relation to the processing of the age estimation capture, which may involve the use of Face Recognition Data).
Please see Section 9 (our onboarding processes) for further information.Consent
Fan age verification (without third-party age and identity verification or third-party age estimation).Performance of a contract
Government identity document validity check and maintaining a record of the age and identity verification process.Performance of a contract
Maintaining a record of the age estimation process (for Fans in certain locations).Performance of a contract
Providing the Services, including the hosting of Creator content, the fulfilment of transactions between Fans and Creators and processing Creator earnings.Performance of a contract
Identifying Referring Users and Referred Creators under the Referral Program set out in our Terms of Service.Consent
More information can be found in our
Cookie Notice.
Providing technical support to Fans and Creators.Performance of a contract
Communicating with you about the Services, responding to support requests or, sharing information about the Services (e.g. providing you with updates to our Terms of Service and / or this Policy).Performance of a contract
Ensuring compliance with, and enforcing, our Terms of Service and other usage policies (e.g. our Acceptable Use Policy).Performance of a contract
Moderation and filtration:

• • text and content uploaded to EuroPeaches
  • livestreaming on EuroPeaches
  • content sent in chat messages on EuroPeaches

to monitor and investigate violations of our Terms of Service.Performance of a contract
Filtration of text sent in direct messages on EuroPeaches to investigate violations of our Terms of Service.Performance of a contract
Removal from the Services of text and content uploaded by users that is identified as illegal, and suspending or deactivating those user accounts.Compliance with legal obligations
Performance of a contract
Removal from the Services of text and content uploaded by users that is identified as violating our Terms of Service and where appropriate, suspending or deactivating user accounts.Performance of a contract
Maintaining a record of banned users, to prevent further access to EuroPeaches.Legitimate interests
Reporting illegal activity to relevant law enforcement authorities, other governmental authorities and non-governmental organisations.Compliance with legal obligations
Legitimate interests
Task carried out in the public interest
Providing relevant information to, or responding to requests from / investigations by, relevant law enforcement authorities, other governmental authorities and non-governmental organisations.Compliance with legal obligations
Legitimate interests
Task carried out in the public interest
Preservation and sharing of Personal Data in the context of legal proceedings (e.g. litigation).Legitimate interests
Complying with applicable laws, rules and regulations.Compliance with legal obligations
Legitimate interests
Monitoring transactions and company network, systems, applications, and data, to: (i) detect malicious, deceptive, fraudulent, or illegal activity to protect information security and integrity, and user safety; and (ii) respond to / investigate incidents where appropriate.Legitimate interests
Substantial public interest
As necessary or appropriate to protect the rights and property of our users, us, and other third parties.Legitimate Interests
System maintenance and testing, reporting and hosting of data, to maintain, develop and improve the provision of the Services (e.g. safety, performance and functionality).Legitimate Interests
As necessary in the context of a possible sale, merger, acquisition, business reorganisation or group restructuring exercise.Legitimate Interests
Processing of Personal Data in connection with sponsorships, and our relationship with service providers, professional advisers and other third parties for business purposes (e.g. business contact information and correspondence).Performance of a contract
Legitimate Interests

1. Obtaining your Personal Data

We collect your Personal Data from the following categories of sources:

1. • Directly from you: When you provide it to us directly to open an account and use the Services, when you update your Personal Data in your account, or by corresponding with us (e.g. User Data, Account Data). We may also process your Personal Data when you interact with us through our social media pages on third-party websites.
   • Automatically or indirectly from you: For example, through and as a result of your use of the Services (e.g. Transaction Data, Technical Data, Usage Data), if you sign-in to EuroPeaches via third-party single sign-in, or if you connect a third-party account to your EuroPeaches account.
   • From our service providers: For example, where permitted by applicable law, we receive Third-Party Onboarding Data and certain Technical Data from our third-party age and identity verification providers.
2. Sharing your Personal Data

We share Personal Data with the following categories of third parties:

1. • Our third-party service providers: Such as our IT, payment processing, customer support, content and text moderation, tax automation, and age and identity verification / age estimation service providers. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely the receipt of services to support business functionality).
   • Our professional advisers: Such as our legal advisors, bankers, auditors, accountants, consultants, and insurers. Our professional advisors will process Personal Data as necessary to provide their services to us. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely the receipt of professional services).
   • Corporate: Relevant third parties in the event of a possible sale, merger, acquisition, business reorganisation or group restructuring exercise. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our and the relevant third parties’ legitimate interests (namely assessing and putting into effect potential transactions).
   • Our group companies: For the centralised coordination and management of our business, in accordance with the purposes set out at Section 8 (categories of Personal Data). These recipients will process Personal Data in the same way as set out in this Policy. The lawful basis we rely on for sharing Personal Data with these recipients is that it is necessary for our legitimate interests (namely coordinating the global operations of our business).
   • Relevant authorities, regulators and organisations: Relevant governmental authorities (including law enforcement and tax authorities), regulators, and certain non-governmental organisations (such as the National Center for Missing & Exploited Children (NCMEC)). These recipients will use your Personal Data in the performance of their regulatory, legal or otherwise charitable or not-for-profit role. Depending on the context, the lawful basis we rely on for sharing Personal Data with these recipients may vary. The processing may be necessary to comply with a legal obligation to which we are subject, necessary for our, or a third-party’s, legitimate interests, or may be in the interest of the wider public to do so. This may include, for example, reporting illegal content to / assisting with requests from, authorities, regulators and organisations, to protect the safety of our users and third parties, and complying with our financial / tax reporting requirements (e.g. DAC7, in the European Union).
2. 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.

1. Your rights regarding Personal Data

You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights by contacting us using the contact details set out at Section 19 (assistance and contact information).
Under certain circumstances and subject to certain exemptions, you have the right to:

• • Withdraw your consent to the processing of your Personal Data: Please note that withdrawing your consent will not affect the lawfulness of any processing carried out before you withdraw your consent.
  • Request to know or access to your Personal Data: You may receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you: You may correct any incomplete or inaccurate Personal Data we hold about you.
  • Request deletion / erasure of your Personal Data: You may ask us to delete or remove Personal Data where there is no legitimate reason for us continuing to process it. You also may ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below). Please note that we may not always be able to comply with your request of deletion / erasure for specific legal reasons, for example if your account has been deactivated for violations of our Terms of Service. Please see Section 17 (retention of Personal Data) for further information.
  • Request the restriction of processing of your Personal Data: You may ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of some sections of your Personal Data to another party.

You also have the right to object to processing of your Personal Data where we are relying on a legitimate interest for the processing and there is something about your particular situation which makes you want to object to processing on this ground.
We do not process Personal Data that is subject to solely automated decision-making, where that decision-making is likely to have a legal or similarly significant effect on you.
You also have the right:

1. • To lodge a complaint with a data protection regulator. For example, in the UK, this is the Information Commissioner’s Office (ICO) and in Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC). If you are resident in the EEA, you may wish to contact your local country or state-specific data protection regulator.
   • Depending on your location in the United States, to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights, or to appeal a decision we have made in connection with your privacy rights request. Further information on appeals is set out at Section 18 (additional U.S. State Privacy Disclosures).
2. 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).

1. 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 EuroPeaches. 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 EuroPeaches. 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).

1. 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:

1. • 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.
2. Additional U.S. State Privacy Disclosures

Where required by law, these additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in the Policy by providing additional information about our Personal Data processing practices relating to individual residents of certain U.S. States. Unless otherwise expressly stated, all terms defined in this Policy retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, Personal Data does not include publicly available information or deidentified, aggregated or anonymised information that is maintained in a form that is not capable of being associated with or linked to you.
No sales for targeted advertising
We do not sell or share Personal Data for the purpose of displaying advertisements that are selected based on Personal Data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising”).
Sensitive information
Although sensitive information may be disclosed for a business purpose as described below, we do not sell or share sensitive information for the purpose of targeted advertising.
The following Personal Data elements we, or our service providers, collect may be classified as “sensitive” under certain privacy laws (“sensitive information”) including:

• • username and password;
  • social security number, driver’s licence number, and passport number;
  • government identifiers (such as driver’s licence numbers);
  • partial payment card number and the name registered with your payment card; and
  • Face Recognition Data (biometric information which is collected and processed by our third-party providers).

We use this sensitive information for the purposes set out at Section 10 (how / why your Personal Data is used and lawful bases for processing), to the extent necessary for the operation of our Services, to enter into and perform a contract with you, to comply with legal and regulatory requirements, to protect the safety of our users and third parties or as otherwise permissible for our own internal purposes consistent with applicable laws.
Deidentified information
We may at times receive, or process Personal Data, to create deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by applicable law.
Appeals
If you are a resident of certain U.S. States, you have the right to appeal decisions regarding your privacy requests. All appeal requests should be submitted using the contact details set out at Section 19 (assistance and contact information). If your appeal is denied, you may contact your local Attorney General.
Minors
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.
CALIFORNIA SPECIFIC DISCLOSURES
The following disclosures only apply to residents of the State of California:
Personal Data collection
California law requires that we provide disclosures to you about what Personal Data we collect by reference to the categories of Personal Data set forth within California law. To address this obligation, we have identified the relevant California Personal Data category for the Personal Data set out in more detail at Section 8 (categories of Personal Data):

• • Identifiers: such as your name, address, phone number, email address, passport or other government identity information including driver’s licence information, account information, or other similar identifiers.
  • Customer Records: Such as your driver’s licence number, passport number, partial debit card information, partial credit card information, bank account information or other payment or financial information.
  • Protected Classification Characteristics: Such as age, date of birth, and gender.
  • Commercial Information: Such as information about products or services purchased and your use of our Services.
  • Biometric Information: which is limited to Face Recognition Data, used by our third-party providers for age and identity verification purposes. Face Recognition Data remains with our third-party providers and we do not ourselves collect, receive, possess, or have access to this data.
  • Internet / Network Information: Such as device information, and log data.
  • Sensory Information: Such as pictures and videos (content) you upload to EuroPeaches.
  • Professional / Employment Information: Such as the business or organisation you are associated with and, where applicable, your title with that business or organisation and information relating to your role with the business or organisation.
  • Other Personal Data: Such as communication preferences, customer service and communication history, personal data an individual permits us to see when interacting with us through social media, Personal Data an individual provides us in relation to a question or request, and messages you send us through our Services or make available to us on social media.
  • Inferences: Such as information generated from your use of our Services.

We may disclose all of these categories of Personal Data for a business purpose to service providers or other third parties, as outlined in this Policy.
Disclosure of Personal Data
As set out at Section 12 (sharing your Personal Data), we may disclose the categories of Personal Data identified above to the following categories of third parties for various business purposes: our group and affiliated companies, service providers, our professional advisers, business partners, other businesses as needed to provide our Services, and certain third parties where you have provided consent, where it is in connection with a corporate transaction, or where we are required by law or in connection with other legal process.
Sources of Personal Data
We collect Personal Data directly from you, from your browser or device when you interact with our Services, and from our business partners and affiliates, third parties you direct to share information with us, and other third-party providers. For more information, please see Section 11 (obtaining your Personal Data).
Purpose for collection
We collect Personal Data about you for the purposes set out at Section 10 (how / why your Personal Data is used and lawful bases for processing).
Notice of financial incentives
As discussed above, 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. We do not currently send emails for direct marketing purposes.
We currently offer a Referral Program, whereby existing Creators of EuroPeaches can use their unique referral code to introduce people who are interested in becoming Creators on EuroPeaches, and the referring Creator will receive referral payments, based on the referred Creator’s earnings. The Referral Program is subject to our Terms of Service and any such referral payments are calculated, and limited, as described in the Referral Program Terms in our Terms of Service.
Any Personal Data associated with the referring Creator, or the referred Creator, is processed in accordance with this Policy.
We have determined that the value of the Referral Program is reasonably related to the value of the Personal Data we process in connection with the Referral Program (based on our reasonable but sole determination). We estimate the value of the Personal Data we receive and otherwise process in connection with the Referral Program by considering the expense we incur in collecting and processing the Personal Data, as well as the expenses related to facilitating the Referral Program.
You may exercise your rights in relation to your Personal Data as outlined in this Policy, and as applicable, by submitting a ticket through your account or by emailing privacy@europeaches.com.

Euro Peaches is the 18 + subscription platform empowering creators to own their full potential, monetize their content, and develop authentic connections with their fans.

Last updated: February 2025

Euro Peaches and its subsidiaries (“E.U.P LTD,” “we,” “us,” “our”) respect your privacy and we are committed to protecting the personal data we process about you. E.U.P LTD is the owner and operator of www.europeaches.com/ (“EuroPeaches“), 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); and (ii) “Fans” to subscribe to, and view, the content of Creators.

We use the following types of cookies on EuroPeaches:

• Essential Cookies: This includes, for example, cookies that allow you to access EuroPeaches through your account, to remember your logged in status where you have requested it, to remember your language preference, and to ensure the security of EuroPeaches and protect against fraud.
• Non-Essential cookies: If you give us your consent to do so, we use non-essential cookies to enable us to recognise Referring Users, and Referred Creators, under the Referral Program in our Terms of Service .

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.

For more information about what cookies are, why we use them, and how you can opt out of, manage, or delete them, please review this Cookie Notice. Any personal data associated with cookies is processed in accordance with our Privacy Policy .

WHAT ARE COOKIES?

“Cookies” are small strings of text or computer code stored locally on your device that allow us and our third- party service providers, to “remember” or “recognise” a particular browser or device and, in some cases, store information about that browser or device.

HOW LONG ARE COOKIES STORED ON MY DEVICE?

Session Cookies: “Session Cookies” are stored for the duration of a browser session. When you close the browser, the cookie is deleted.

Persistent Cookies: “Persistent Cookies” are stored for a set amount of time (often between 90 days and 2 years, depending on the application) and are typically not deleted when a browser session is closed.

Your choices may affect whether we use session or persistent cookies for a particular application. For example, if you select “Remember me for 30 days” when logging in to EuroPeaches, your two-step verification status is stored on a persistent cookie for 30 days to remember the device that you signed in from.

WHAT COOKIES DO WE USE, AND WHY?

Essential Cookies: Some cookies are necessary to allow you to browse EuroPeaches and access certain pages. Essential cookies enable EuroPeaches to work properly.

NameDescription
_cfuvid / __cf_bmto enable security functionality
auth_idto authenticate user ID
auth_uid_{userid}to remember two-factor authentication (for 30 days) where requested
cto enable profile promotion campaign functionality (free trials / discounted subscriptions)
CloudFront-Policy / CloudFront-Signature / CloudFront-Key- Pair-Idto enable digital rights management
cookiesAcceptedto remember your cookie preferences, i.e. “essential only” or “all”
csrftoken to establish a secure connection to EuroPeaches
fpbrowser fingerprint to enable security functionality
langto remember your language preference
pa_url_hashto grant user profile access
sessto enable ongoing user session authentication
st / streamsto enable access live streaming functionality / stream thumbnails
trial_personal / trial_code / trial_code_errorto enable trial subscription functionalityDisabling, clearing, or blocking these cookies on your browser (or browser add-on) may prevent EuroPeaches, or certain functionalities on EuroPeaches, from working correctly or at all.

Non-Essential Cookies:

We currently offer a Referral Program, where existing Creators of EuroPeaches can use their unique referral code to introduce people who are interested in becoming Creators on EuroPeaches. The Referral Program is subject to the Referral Program Terms in our Terms of Service and any referral payments are calculated, and limited, as described in the Referral Program Terms.

We use the following cookies to allow us to recognise the Referring User and the Referred Creator under the Referral Program. If you would like to participate in the Referral Program, the Referring User and the Referred Creator will need to accept non-essential cookies to ensure that any referrals are recognised. If the Referring User or the Referred Creator does not agree to these cookies, we will not be able to recognise the referral or make referral payments. Disabling, clearing, or blocking these cookies may also prevent our ability to recognise referrals made under the Referral Program.

NameDescription
ref_srcto establish source of referral ID (Referring User)
refto establish referral user ID (Referred Creator)
reg_ref_user_id / reg_refto recognise referral of Referred Creator by Referring UserThird-Party Functionality:

We do not control cookies or other features that third-party sites may use, and the information practices of those third party websites are not covered by our Privacy Policy or this Cookie Notice.

HOW DO I CONTROL OR MAKE CHOICES ABOUT COOKIES?

Accepting or Rejecting Non-Essential Cookies: We will only place the non-essential cookies mentioned above on your device if you click “Accept All” in the cookie banner when you first access EuroPeaches.

Managing Cookies: Check out your device and / or browser (or browser add-on) settings to disable, clear or block some or all cookies, or provide notifications when you receive a new cookie.

Check out the “Help”, “Tools”, or “Preferences” menus on your browser (or browser add-on), or the documentation for your device, for more information about how to do this.

BY USING OUR WEBSITE YOU AGREE TO THIS POLICY – PLEASE READ IT CAREFULLY

This sets out what is and is not permitted on EuroPeaches and forms part of your agreement with us. Any breach of this Acceptable Use Policy may result in deactivation of your Content and/or your account.

Defined terms in this Policy have the same meanings as in our Terms of Use.

Do not use EuroPeaches in any manner that features or facilitates:

1. Anyone under the age of 18 or anyone in explicit content who is over the age of 18 and who has not completed our Creator onboarding process or provided us with a properly completed release form.
2. Illegal activity including actual, claimed, or role-played: exploitation, abuse, or harm of individuals under the age of 18; incest; bestiality; necrophilia; or rape or sexual assault.
3. Prohibited items including weapons or controlled substances used in a manner that threatens or may cause harm to yourself or to a third-party.
4. Hateful conduct including attacking other people on the basis of race, ethnicity, national origin, caste, sexual orientation, gender, gender identity, religious affiliation, age, disability, or disease.
5. Abuse or harassment including stalking, doxxing, defaming, or the sharing of non-consensual, fake or manipulated intimate images or otherwise unauthorised images.
6. Violence or harm including prohibited role play, use of objects in any way that is likely to cause physical or mental harm, lack of express consent, extreme impact, extreme bondage, or suicide.
7. Prohibited bodily fluids including urine or excrement.
8. Inaccurate information including misleading descriptions of media or account information.
9. Any explicit image of another person without their consent including an artificially generated image.
10. Public nudity including explicit conduct in a place where the general public is present or where other people are reasonably likely to see, including in an avatar or header image.
11. Prohibited cyber activity including spamming, sharing other people’s personal data, linking to external media storage sites; referencing to an off-platform site that violates our Terms of Service; or behaves in any way interfering with EuroPeaches’ software, hardware, or network.
12. Copying content including scraping, downloading, sharing, or gathering information from EuroPeaches or any Creator for any reason.
13. In-person meetings including to facilitate any transaction other than a Creator Interaction.
14. Prohibited commercial activity including selling controlled or regulated items, representing that EuroPeaches has endorsed you or your content, or infringing a third-party intellectual property right.

Last updated: February 2025

1. Introduction: This Contract between Fan and Creator (“this Agreement“) governs each interaction between a Fan and a Creator on EuroPeaches.
2. Scope: This Agreement is legally binding and applies each time a Creator Interaction is initiated on EuroPeaches. This Agreement applies to the exclusion of any other terms which the Fan or Creator may propose.
3. Parties: The only parties to this Agreement are the Fan and Creator participating in the Creator Interaction. The Company and/or its Subsidiaries are not parties to this Agreement or any Creator Interaction except as set forth below.
4. Interpretation: In this Agreement, defined terms have the following meanings:
   1. “Company“: E.U.P LTD
   2. “Content“: any material Uploaded to EuroPeaches by any User, including any photos, videos, audio, livestream material, data, text, metadata, images, interactive features, emojis, GIFs, memes, and any other material whatsoever
   3. “Creator“: a User who has set up their EuroPeaches account to post Content for Fans to view
   4. “Creator Earnings“: the portion of a Fan Payment payable to a Creator pursuant to the Terms of Use
   5. “Creator Interaction“: an interaction on EuroPeaches that grants access to a Creator’s Content, including: (i) a Subscription; (ii) a payment for pay-per-view Content; and (iii) any other interaction or payment between a User and a Creator’s account or Content, including direct messages
   6. “Creator Interaction Licence“: the non-transferable, non-sublicensable, and non- exclusive rights each Creator grants to Relevant Content
   7. “Fan“: a User who has registered for an account and who can access a Creators’ Content via a Creator Interaction
   8. “Fan Payment“: any payment related to a Creator Interaction
   9. “FIL Fee“: the 20% of all Fan Payments charged to Creators in accordance with the Terms of Use
   10. “Include“, “Includes” and “Including” also mean “without limitation“
   11. “Indirect Sales Taxes“: any Tax that is statutorily applied to Fan Payments in any relevant jurisdiction
   12. “EuroPeaches“: the website accessed via www.europeaches.com or via any web browser, which is owned and operated by the Company
   13. “Paid Relevant Content“: any Content for which the Fan must make a Fan Payment
   14. “Referring User“: a User who participates in the EuroPeaches Referral Program
   15. “Relevant Content“: the applicable Content of a Creator to which a Creator Interaction relates
   16. “Subscription“: a Fan’s binding agreement to obtain access for a specific period of time to all Content that a Creator makes available to Fans in exchange for authorising automatic renewal payments. This excludes individually priced Content.
   17. “Subsidiary“: any legal entity which the Company or one of the Company’s subsidiaries, alone or with other Company subsidiaries, owns, or has the power to vote or control
   18. “Tax“: all forms of tax and statutory or governmental charges, duties, imposts, contributions, levies, withholdings, or liabilities wherever chargeable in any applicable jurisdiction
   19. “Upload“: publish, display, post, type, input, or otherwise share any photos, videos, audio, livestream material, data, text, metadata, images, interactive features, emojis, GIFs, memes, and any other material whatsoever
   20. “User“: any user of EuroPeaches, whether a Creator or a Fan or both (also referred to as “you” or “your“)
5. Pricing and payment: The Fan entering into a Creator Interaction agrees to pay the applicable Fan Payment plus any Indirect Sales Tax, which the Company and its Subsidiaries are authorised to collect. The Company is also authorised to deduct the FIL Fee, to pay out Creator Earnings, and to pay applicable referral payments.
6. Subscriptions and Renewals: When you select “Subscribe,” you agree to start a Subscription. A Subscription will automatically renew at the current rate (plus Indirect Sales Tax). You authorise the Company to charge you again after each Subscription, unless: (i) your payment is declined and you have not provided another payment; (ii) the Subscription price has increased; (iii) you switched off the “Auto-Renew” feature on the Creator’s account; or (iv) you close your EuroPeaches account before the new Subscription period begins. By selecting “Subscribe,” you agree to these provisions, and acknowledge that you will not receive further notice regarding the renewal of that Subscription.
7. Licence of Content: As part of a Creator Interaction, the Creator grants a Creator Interaction Licence. The Creator Interaction Licence permits a Fan access to Relevant Content.
8. Ownership of Content: The Creator Interaction Licence does not grant any Fan ownership rights to the Relevant Content.
9. Expiry of licence: The Creator Interaction Licence expires automatically without notice:
   1. if the Fan Payment related to the Creator Interaction was unsuccessful, charged back, or reversed;
   2. if the Creator deletes either the Relevant Content or their Creator account;
   3. when an active Subscription period ends;
   4. if the Fan’s account is suspended or terminated;
   5. if the Fan breaches the EuroPeaches Terms of Service;
   6. if Relevant Content is removed from the Creator’s account or the Creator’s account is suspended or terminated; and
   7. if the Fan closes their account.
10. Removal of Content: The Company reserves the right to remove any Content from a Creator’s account at any time. The Fan participating in the Creator Interaction acknowledges that Creators may remove Content, including pay-per-view Content at any time.
11. Cancellation and refunds: In respect of every Creator Interaction:
    1. The Fan will gain access to the Relevant Content within 14 days of the Creator Interaction. The Fan agrees that any statutory right to cancel the Creator Interaction under the Consumer Rights Act 2015, the UK Consumer Contracts Regulations 2013, EU Directive 2011/83, or any other equivalent applicable law is therefore not applicable regarding any Creator Interaction other than a Subscription.
    2. This Agreement does not affect any statutory right to a refund which a Fan may have under the Consumer Rights Act 2015, the UK Consumer Contracts Regulations 2013, UE Directive 2011/83 or any other applicable law.
    3. Cancellations and refunds also are subject to the Company’s Terms of Use.
12. Obligations between Creator and Fan in Creator Interactions:
    1. The Fan and the Creator agree to comply at all times with EuroPeaches Terms of Service.
    2. The Creator is solely responsible for creating and publishing Relevant Content.
    3. The Creator warrants that it possesses all necessary rights to grant a Creator Interaction Licence.
    4. The Creator agrees to provide Paid Relevant Content once the Fan has made the Fan Payment.
    5. The Fan acknowledges that third parties may assist Creators in operating their accounts and in Creator Interactions.
    6. The Fan agrees to make the Fan Payment required to access Paid Relevant Content.
    7. The Fan agrees not to initiate a chargeback unless the Fan disputes the Creator Interaction in good faith.
    8. The Fan assumes all risk of accessing the Relevant Content unless the Creator engages in negligence or another breach of duty.
13. No guarantees: The Fan participating in the Creator Interaction acknowledges that circumstances may prevent access to Relevant Content, including if the availability of all or any part of EuroPeaches is suspended or inaccessible.
14. Applicable law and forum for disputes:
    1. To the greatest extent permitted by the laws of the place where you live, this Agreement is governed by the laws of England and Wales, which will apply to any claim that arises out of or relates to this Agreement. The Fan will also be able to rely on mandatory rules of the law of the country where they live.
    2. Where claims can be brought:
       1. Any Fan resident in the United Kingdom or the European Union may bring a claim under this Agreement in the courts of England and Wales or the country where the Fan lives.
       2. All other Fans must bring a claim under this Agreement in the courts of England and Wales.
15. Severability: In the event any provision of this Agreement is found by a court of competent jurisdiction to be invalid or unenforceable, or is prohibited by law, the remaining provisions of the Agreement shall remain in full force and effect, and the remainder of this Agreement shall be valid and binding as though such invalid, unenforceable, or prohibited provision were not included herein.

Last updated: February 2025

BY USING OUR WEBSITE YOU AGREE TO THIS POLICY – PLEASE READ IT CAREFULLY

1. Introduction: We comply with the fairness and transparency requirements set out in EU Regulation 2019/1150 (the “Platform to Business Regulation“). Here are a few key things to note:
   • You must abide by our Terms of Service, obey all applicable laws, and comply with all applicable tax regulations.
   • At our sole discretion, we may promote or recommend Creators.
   • These Platform to Business Regulation Terms explain how Business Users may submit complaints and engage in mediation of disputes.
2. Interpretation: Unless specifically defined in these Platform to Business Regulation Terms, terms have the same meanings given to them in the Terms of Use.
3. Applicability: These Platform to Business Regulation Terms only apply to Creators who are established or resident in the European Union or the United Kingdom.
4. Promoting via social media: We may promote Creators via our social media accounts.
5. Suggesting Creators on EuroPeaches: We may suggest that Users follow Creator accounts.
6. Complaints: Submit a complaint to support@europeaches.com if it is about:
   1. our alleged non-compliance with any obligations in the Platform to Business Regulation which affect you;
   2. technological issues relating directly to EuroPeaches and which affect you; or
   3. measures taken by us or our conduct which relate directly to EuroPeaches and which affect you.
7. Complaint handling process: Following receipt of a complaint submitted under these Platform to Business Regulation Terms, we will:
   1. consider your complaint and any needed follow-up from us (including asking you for further information or documents) in order to adequately address the issue raised;
   2. process your complaint within a reasonable time, taking into account the importance and complexity of the issue raised; and
   3. communicate to you in plain and intelligible language by email or by message to your EuroPeaches account the outcome of the internal complaint handling process.
8. Mediation service: If your complaint under these Platform to Business Regulation Terms is not resolved to your satisfaction through our internal complaint-handling process as set out above, you may contact:Centre for Effective Dispute Resolution
   International Dispute Resolution Centre
   P2B Panel of Mediators
   70 Fleet Street
   London
   EC4Y 1EU
   United Kingdom
   https://www.cedr.com/p2bmediation/

   or

   International Centre for Dispute Resolution
   150 East 42nd Street, Floor 17
   New York, NY 10017
   https://www.icdr.org/

   You and we will act in good faith throughout any mediation. However, any attempt to reach agreement through mediation on the settlement of a dispute between us will not affect our or your rights to commence legal proceedings at any time before, during or after the mediation process, as such rights are set out in our Terms of Use.

Last updated: February 2025

WARNING!

In compliance with regulation 3 of the Trading Scheme Regulations 1997 (as amended) and section 120(1) of the Fair Trading Act 1973, please read the warning below in respect of the EuroPeaches Referral Program:

• It is illegal for us or for a participant in the EuroPeaches Referral Program (including Referring Users and Referred Creators) to persuade anyone to make a payment by promising benefits from getting others to join the EuroPeaches Referral Program.
• Do not be misled by claims that high earnings are easily achieved from participation in the EuroPeaches Referral Program.
• Although we do not demand any payment from Referring Users for the purposes of participating in the EuroPeaches Referral Program, we are legally required to inform you that if you sign this contract, you have 14 days in which to cancel and get your money back.

BY PARTICIPATING IN OUR REFERRAL PROGRAM YOU AGREE TO THESE TERMS – PLEASE READ THEM CAREFULLY.

1. Introduction: These Referral Program Terms are additional terms which apply if you use the EuroPeaches Referral Program. These Referral Program Terms form part of your agreement with us. Here are a few key things to note:
   • At all times, you must abide by our Terms of Service, all applicable laws, and all applicable tax regulations.
   • You must have a current User account to participate in the EuroPeaches Referral Program.
   • Referring Users will be paid a referral payment of 5% on Fan Payments generated by the Referred Creator in the 12 months after the Referred Creator becomes a registered User of EuroPeaches, up to a maximum referral payment of US$50,000 per Referred Creator.
   • We may withhold referral payments or terminate a Referred Creator’s participation for breaches of EuroPeaches Terms of Service.

   The EuroPeaches Referral Program is operated by E.U.P LTD with a company registration number 16239540 and a registered address at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

2. Interpretation: In these Referral Program Terms defined terms have the same meanings given to them in the Terms of Use. In addition:
   1. “Referring User” is also referred to as “you” or “your” in these Referral Program Terms;
   2. “Referred Creator” means the person who joins EuroPeaches as a new Creator via the Referring User’s unique referral link.
3. The EuroPeaches Referral Program: EuroPeaches offers a program (“Referral Program”) by which Users can introduce new Creators to EuroPeaches and are eligible to receive payments according to these Referral Program Terms.
4. Referral Program rules:
   1. Users can participate in the Referral Program. If a User’s account has been suspended or terminated by us for any reason or deleted by the User, that User is ineligible for the Referral Program.
   2. You must add bank account or payment method details to your account in order to receive referral payments under the EuroPeaches Referral Program.
   3. Each User has a unique referral link which the User may share with others. When sharing a referral link, do not impersonate EuroPeaches or give the impression that EuroPeaches is sharing or promoting your referral link. Do not use Google Ads or any similar advertising platform or search engine advertising service to share or promote your referral link. Upon our request, you must disclose the methods by which you share your unique referral link.
   4. The Referred Creator must click on your unique referral link and then register with EuroPeaches using the same browser that they used to click on your referral link. We also use certain cookies (as set out in our Cookies Notice) to allow us to recognise you and the Referred Creator. If someone registers with EuroPeaches other than by using your referral link, or you or the Referred Creator does not accept these cookies, we will not link that account to your referral and will not make referral payments to you. Disabling, clearing, or blocking these cookies may also prevent our ability to recognise referrals and make referral payments made under this Referral Program.
   5. Referral payments will be made to you only on Referred Creator accounts. No referral payments will be earned or made on Fan accounts that register via a referral link unless that Fan later becomes a Creator.
   6. If a Referred Creator sets up more than one User account using a referral link, referral payments will only be made on the earnings in the Referred User’s first-registered account. No referral payments will be made on any other of the Referred Creator’s accounts.
   7. No referral payments will be made to you on earnings in any account which we determine is owned or is operated by you, or is owned or operated by a Referred Creator with whom you have a commercial relationship. You must provide any information which we request to enable us to determine whether any account is owned or is operated by you, or is owned or operated by a Referred Creator with whom you have a commercial relationship.
   8. You agree that when promoting EuroPeaches in any way as a Referring User:
      • you will not give a false impression of EuroPeaches; and
      • you will not make any statements which suggest that a Creator will make a particular sum of money (or any money) on EuroPeaches.
   9. A Referred Creator can elect to withdraw from the Referral Program for any reason at any time. If a Referred Creator ceases to be part of the Referral Program, no further referral payments will be made to the Referring User.
5. Referral payments:
   1. Referral payment calculations: Once a Referred Creator establishes an account, the Referring User will be paid a referral payment for each Referred Creator that is the lesser of: (i) five per cent (5%) of Fan Payments generated by the Referred Creator in the twelve months after the Referred Creator’s registration date; or (ii) US$50,000.This means that if a Referred Creator generates Fan Payments with a total value of US$1 million or more in the twelve months after the Referred Creator’s registration date, then the Referring User’s payments in relation to that Referred Creator will be US$50,000.

      However, if the Referred Creator generates Fan Payments with a total value of less than US$1 million in the twelve months after the Referred Creator’s registration date, then the Referring User will be paid five per cent (5%) of the Fan Payments the Referred Creator generated in the twelve months after the Referred Creator’s registration date.

   2. Indirect Sales Taxes: All referral payments to each Referring User will be inclusive of any applicable Indirect Sales Tax (as defined in the Terms of Use) which is or becomes chargeable on any supplies made by you.
   3. Warning: In compliance with regulation 3 of the Trading Scheme Regulations 1997 (as amended) and section 120(1) of the Fair Trading Act 1973, please read the warning below in respect of the EuroPeaches Referral Program:
      • It is illegal for us or for a participant in the EuroPeaches Referral Program (including Referring Users and Referred Creators) to persuade anyone to make a payment by promising benefits from getting others to join the EuroPeaches Referral Program.
      • Do not be misled by claims that high earnings are easily achieved from participation in the EuroPeaches Referral Program.
   4. Payout methods: To receive referral payments you must first choose a payout method offered by EuroPeaches in your country of residence.
   5. Referral payment frequency: The referral payments due to you that accrue in one calendar month will be transferred to you on or around the first day of the next calendar month.
   6. Cost: We bear the cost of the referral payment, not the Referred Creator.
6. Our rights relating to the referral program.
   1. We may request you and/or Referred Creators to provide us with ID and other information reasonably required to verify any referral payment to be made and the person to whom any referral payment should be made. Failure to provide any information we request may forfeit your entitlement to referral payments in respect of the relevant Referred Creator.
   2. We may change any aspect of the EuroPeaches Referral Program (including how referral payments are calculated) or discontinue the EuroPeaches Referral Program at any time, but no change will deprive any Referring User of referral payments already earned based on Fan Payments made to Referred Creators before the changes came into effect.
7. Circumstances in which we may withhold referral payments: The provisions in the Terms of Use that apply to withholding and/or treating as forfeited Creator Earnings applies to unpaid referral payments.

Last updated: February 2025

BY USING OUR WEBSITE YOU AGREE TO THIS POLICY – PLEASE READ IT CAREFULLY

1. Introduction: This Policy forms part of your agreement with us. We will handle complaints in keeping with this Policy. Here are a few key things to note:
   • By making a complaint, you confirm that you believe that the information you have provided is accurate and complete.
   • This Policy explains how we handle complaints about:
     • how we enforce our Terms of Service;
     • Content on EuroPeaches that may be illegal or in breach of our Terms of Service; and
     • compliance with applicable laws.
   • This Policy does not apply to complaints regarding Content or account moderation decisions or copyright infringement.
2. Contact information: EuroPeaches is operated by E.U.P LTD, a limited company registered in England and Wales, with company registration number
   16239540. Our registered office address is located at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
3. Interpretation: Unless specifically defined in this Policy, the meanings given to words defined in the Terms of Use have the same meanings in this Policy.
4. Complaints about Content moderation decisions: We moderate Content according to our Terms of Service. To complain about a decision to deactivate Content, to deactivate an account, or to issue a final warning, you must complete an EuroPeaches Deactivation Appeal Form. Appeals against a Content moderation decision including any decision to remove Content, deactivate an account, or ban you from using EuroPeaches because we believe you have engaged in an illegal act are subject to our Appeals Policy.
5. Complaints about copyright infringement: Complaints about suspected copyright infringement are subject to our DMCA Takedown Policy.
6. How to make a complaint about anything else:
   1. You can make a complaint in any of the following ways:
      1. using our Contact Form select the reason for your complaint from the drop down menu and use the ‘Enter your message’ field to explain the issue you are complaining about;
      2. using the “Report” function on the Content page select the reason for your complaint from the drop down menu;
      3. emailing support@europeaches.com
      4. CCBILL Complaints/Take Down Request
      5. writing to E.U.P LTD 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
   2. You must provide enough information so we can investigate your complaint (including any relevant URLs). If a complaint is missing important information, we may not be able to properly consider it.
7. How we review complaints: At EuroPeaches, we are committed to maintaining a safe, respectful, and lawful platform for all users.
   This policy outlines how you can report content that may be illegal or otherwise violates our Standards, how we handle such reports, and the process for review and resolution.

            1. Review Timeline

   1. All reported complaints will be reviewed and resolved within seven (7) business days from the date of receipt.
      

      2. Review Process

      • Our moderation team will investigate the reported content.
      • We may request additional information from the complainant or the content uploader.
      • Based on our findings, we will determine whether the content violates our Standards or applicable laws.

      3. Appeals Process

      If you disagree with the outcome of our review, you may submit an appeal within seven (7) business days of receiving our decision. Appeals can be sent to appeals@europeaches.com and must include:

      • The reason you believe our decision was incorrect
      • Any new or additional information that supports your position

      4. Possible Outcomes

      • Content Removal – If the content violates our Standards or applicable laws
      • Content Restriction – Content may be age-restricted or hidden from public view
      • Warning Issued – The uploader may receive a formal warning
      • Account Suspension or Termination – For serious or repeated violations
      • No Action Taken – If the content does not violate our Standards or laws

       

8. Abuse of this complaints process: We do not tolerate complaints made in bad faith or complaints that are abusive, harassing, or otherwise intended to harm anyone. If you are an EuroPeaches User, and make an abusive or unfounded complaint we may terminate your account.
9. EU/EEA Consumer Mediation Services: If you are in the European Economic Area you may, but are not required to, seek resolution of any dispute with us through consumer mediation services using the European Online Dispute Resolution (ODR) platform. We are not obliged to participate in alternative dispute resolution proceedings (except in very limited circumstances).
10. Regulatory complaints under the DSA (EU/EEA): If you are in the European Economic Area and encounter an infringement of the EU’s Digital Services Act while using EuroPeaches, you have the right to complain to the Digital Services Coordinator of the country where you are located. You may also report or complain to us under this Complaints Policy and dispute our decision under our Appeals Policy.
11. Regulatory complaints: EuroPeaches is regulated by Ofcom and the Information Commissioner’s Office in the United Kingdom and the eSafety Commissioner in Australia. Users resident in Australia can contact eSafety to report concerns about the safe use of technology here.
12. Breach of contract claims under the Online Safety Act: Users in the United Kingdom are entitled to bring a breach of contract claim against us, including where we breach our Terms of Service in how we (i) take down or restrict access to your Content; or (ii) suspend or ban you from using EuroPeaches.
13. Your statutory rights: These provisions do not affect your statutory rights.

Last updated: February 2025

BY USING OUR WEBSITE YOU AGREE TO THIS POLICY – PLEASE READ IT CAREFULLY

1. Introduction: This Policy forms part of your agreement with us. Here are a few key things to note:
   • you must follow the procedures below to appeal a Content or account moderation decision.
   • EuroPeaches will handle appeals in keeping with this Policy.
2. Contact information: EuroPeaches is operated by E.U.P LTD, a limited company registered in England and Wales, with company registration number 16239540, and registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. If you have questions about this Policy please contact support@europeaches.com.
3. Interpretation: Unless specifically defined in this Policy, the meanings given to words defined in the Terms of Use have the same meanings.”Decision“: any action taken by EuroPeaches to:
   1. suspend or deactivate an account;
   2. suspend or deactivate Content shared to or from an account;
   3. impose a final warning for a violation on an account;
   4. restrict account features (for example, the ability to livestream); or
   5. suspend, terminate, or restrict the ability to monetise Content, including by preventing subscriptions or limiting your ability to accept certain types of payments.
4. Use: This Policy can be used in two ways:
   1. by EuroPeaches Users who want us to review or reverse a Decision; or
   2. by non-EuroPeaches-users in the EU/EEA who have complained about suspected illegal or non-consensual Content on EuroPeaches and who disagree with EuroPeaches‘ appeal response.
5. Appeal procedure: The only way to appeal a Decision is to complete and submit the Deactivation Appeal Form.
6. Required information: Only fully completed Deactivation Appeal Forms will be considered. Your Deactivation Appeal Form must include:
   1. the URL or username of the account;
   2. the URL of Content subject to the appeal;
   3. detailed reasons why you believe your Content or account is in keeping with the EuroPeaches Terms of Service and Acceptable Use Policy; and
   4. for non-EuroPeaches-users in the EU/EEA who disagree with our decision to permit Content to remain on EuroPeaches why you believe the Content is illegal or non-consensual.
7. Timing of appeals: All appeals should be filed within six months of a Decision.
8. Review process: If we receive a completed Deactivation Appeal Form:
   1. we will review the relevant EuroPeaches account information;
   2. we will consider the information and the supporting documents that you have provided;
   3. we may request additional information or documents from you or from third parties to help us decide the appeal; and
   4. based on the information, we will grant, grant in part, or deny your appeal, and we will notify you of our decision:
   1. If we grant your appeal, we will reverse each relevant Decision and any actions taken as a result of each Decision.
   2. If we grant your appeal in part, we will notify you of each Decision that has been reversed and any actions taken as a result.
   3. If we deny your appeal, no Decision will change.
9. No liability: We are not liable for any interruption of access to your EuroPeaches account, including any loss of earnings or subscribers, even where we grant some or all of your appeal.
10. Appeals team: Our Appeals Team will consider each properly filed appeal based on the information provided in a non-discriminatory, diligent, and non-arbitrary manner.
11. Situations where a Decision cannot be appealed: This Policy does not apply to any irreversible Decision (for example, a Decision to end a livestream).
12. Additional procedures for users in the EU/EEA:
    1. You may also file a complaint with a regulatory authority and/or seek a remedy via a certified third-party out-of-court dispute settlement body or the relevant courts in your country of residence/establishment.
    2. In certain circumstances, out-of-court dispute settlements under the EU Digital Services Act (“DSA“) may apply. Each EU member state must certify an out-of-court dispute settlement body to handle eligible disputes.
    3. You also have the option of judicial redress by pursuing your claim in a court which has jurisdiction.
    4. You may submit a report or complaint regarding Content which you believe is illegal or otherwise violates our Terms of Service. We will review all reports and complaints, and determine whether we agree that a violation of our Terms of Service has occurred.
    5. If we conclude that no violation of our Terms of Service has occurred and elect not to make a Decision regarding the relevant Content, you may be able to refer the matter to an out-of-court dispute settlement body. If you do, we will engage with the out-of-court dispute settlement body in good faith and as required by law.
    6. We are not bound by any decisions made by an out-of-court dispute settlement body, and may refuse to engage with an out-of-court dispute settlement body if a dispute concerning the same Content, and the same grounds of alleged incompatibility with our Terms of Service has already been resolved.

Last updated: February 2025

1. UK VAT and UK established Creators:
   1. For the purposes of UK VAT only, Creators are treated as providing their services to EuroPeaches, rather than to Fans directly.
   2. If you are a Creator registered for UK VAT:
      1. You will be treated, for VAT purposes, as charging EuroPeaches your Creator Earnings (80% of all and any Fan Payments), together with UK VAT at the prevailing rate in force at the time of the Fan Payment.
      2. EuroPeaches also agrees that, subject to the Terms of Service, any payments due to you under the Referral Program Terms (” Referral Payments“) will be deemed VAT inclusive.
      3. The VAT element added to your Creator Earnings (and Referral Payments, if any) (the “VAT Amount”) will be separately paid from your regular Creator Earnings, provided that you first provide:
         1. your VAT registration number, by completing this form: https://europeaches.com/my/banking/vat;
         2. a VAT invoice, using the EuroPeaches VAT invoice generator tool: https://europeaches.com/my/banking/vat/create-document; and
         3. a completed VAT return made to HM Revenue & Customs for the relevant period. You can find monthly earning details at https://europeaches.com/my/stats/earnings.
   3. You shall pay the VAT Amount which is paid to you directly to HM Revenue & Customs.
   4. If you need further information about how to receive the VAT Amount, email vat@europeaches.com, consult our Community Guidelines, or visit the HM Revenue & Customs guidance at https://www.gov.uk/vat-registration/when-to-register.
   5. You must provide us with copies of all VAT invoices and VAT returns in connection with your Creator Earnings (and Referral Payments, if any) upon request. It is your obligation alone to remain VAT compliant.

Last updated: February 2025

Introduction

This DMCA Takedown Policy is to be used only for reporting infringing content published on europeaches.com. To request assistance with removing infringing material found on other websites, please contact us here: https://europeaches.com/contact.

DMCA Notice & Takedown Policy and Procedures

Although our website (“Site”) is not based in the United States, we respect the intellectual property rights of copyright holders, and thus have chosen to voluntarily comply with the Notice and Takedown provisions of the Digital Millennium Copyright Act (“DMCA”).  This Site qualifies as a “Service Provider” within the meaning of 17 U.S.C. § 512(k)(1) of the DMCA.  Accordingly, it is entitled to certain protections from claims of copyright infringement under the DMCA, commonly referred to as the “safe harbor” provisions.  We respect the intellectual property of others, and we ask our users to do the same.  Thus, we observe and comply with the DMCA, and have adopted the following Notice and Takedown Policy relating to claims of copyright infringement by our customers, subscribers or users.

Notice of Claimed Infringement

If you believe that your work has been copied and published on europeaches.com in a way that constitutes copyright infringement, please provide Our Designated Copyright Agent (identified below) with the following information:

(a)     an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright or other intellectual property interest;

(b)     description of the copyrighted work or other intellectual property that you claim has been infringed;

(c)     a description of where the material that you claim is infringing is located on the Site (preferably including specific url’s associated with the material);

(d)     your address, telephone number, and email address;

(e)     a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and,

(f)     a statement by you, made under penalty of perjury, that the above information in your notification is accurate and that you are the copyright or intellectual property owner or authorized to act on the copyright or intellectual property owner’s behalf.

You may send your Notice of Claimed Infringement (“Notice”) to:

Lawrence G. Walters, Esq.

Walters Law Group

195 W. Pine Ave.

Longwood, FL 32750-4104

Fax: (407) 774-6151

Email: dmca [at] europeaches [dot] com

Please do not send other inquires or information to our Designated Agent.  This policy only applies to infringing content published on europeaches.com. To report infringing material on other sites, please contact us here: https://europeaches.com/contact.  Absent prior express permission, our Designated Agent is not authorized to accept or waive service of formal legal process, and any agency relationship beyond that required to accept valid DMCA Notices is expressly disclaimed. 

Further information regarding notification and takedown requirements can be found in the DMCA, here: http://www.law.cornell.edu/uscode/text/17/512

Abuse Notification: Abusing the DMCA Notice procedures set forth above, or misrepresenting facts in a DMCA Notice or Counter-notification, can result in legal liability for damages, court costs and attorneys fees under federal law.  See; 17 U.S.C. § 512(f). These Notice and Takedown Procedures only apply to claims of copyright infringement by copyright holders and their agents – not to any other kind of abuse, infringement or legal claim.  We will investigate and take action against anyone abusing the DMCA notification or counter-notification procedure.  Please ensure that you meet all of the legal qualifications before submitting a DMCA Notice to our Designated Agent.

Take Down Procedure

The Site implements the following “notification and takedown” procedure upon receipt of any notification of claimed copyright infringement.  The Site reserves the right at any time to disable access to, or remove any material or activity accessible on or from any Site or any materials claimed to be infringing or based on facts or circumstances from which infringing activity is apparent. It is the firm policy of the Site to terminate the account of repeat copyright infringers, when appropriate, and the Site will act expeditiously to remove access to all material that infringes on another’s copyright, according to the procedure set forth in 17 U.S.C. §512 of the DMCA. The Site’s DMCA Notice Procedures are set forth in the preceding paragraph. If the Notice does not comply with §512 of the DMCA but does comply with three requirements for identifying sites that are infringing according to §512 of the DMCA, the Site shall attempt to contact or take other reasonable steps to contact the complaining party to help that party comply with the notification requirements. When the Designated Agent receives a valid Notice, the Site will expeditiously remove and/or disable access to the infringing material and shall notify the affected user. Then, the affected user may submit a counter-notification to the Designated Agent containing a statement made under penalty of perjury that the user has a good faith belief that the material was removed because of misidentification of the material. After the Designated Agent receives the counter-notification, it will replace the material at issue within ten to fourteen (10-14) days after receipt of the counter-notification unless the Designated Agent receives notice that a court action has been filed by the complaining party seeking an injunction against the infringing activity.

DMCA Counter-Notification Procedure

If the Recipient of a Notice of Claimed Infringement believes that the Notice is erroneous or false, and/or that allegedly infringing material has been wrongly removed in accordance with the procedures outlined above, the Recipient is permitted to submit a counter-notification pursuant to Section 512(g)(2) & (3) of the DMCA.  A counter-notification is the proper method for the Recipient to dispute the removal or disabling of material pursuant to a Notice.  The information that a Recipient provides in a counter-notification must be accurate and truthful, and the Recipient will be liable for any misrepresentations which may cause any claims to be brought against the Site relating to the actions taken in response to the counter-notification.

To submit a counter-notification, please provide Our Designated Copyright agent the following information:

(a)     a specific description of the material that was removed or disabled pursuant to the Notice;

(b)     a description of where the material was located within the Site or the content (as defined within the Site’s Terms & Conditions or User Agreement) before such material was removed and/or disabled (preferably including specific url’s associated with the material);

(c)     a statement reflecting the Recipient’s belief that the removal or disabling of the material was done so erroneously.  For convenience, the following format may be used:

“I swear, under penalty of perjury, that I have a good faith belief that the referenced material was removed or disabled by the service provider as a result of mistake or misidentification of the material to be removed or disabled.”

(d)     the Recipient’s physical address, telephone number, and email address; and,

(e)     a statement that the Recipient consents to the jurisdiction of the Federal District Court in and for the judicial district where the Recipient is located, or if the Recipient is outside of the United States, for any judicial district in which the service provider may be found, and that the Recipient will accept service of process from the person who provided the Notice, or that person’s agent.

Written notification containing the above information must be signed and sent to:

Lawrence G. Walters
Walters Law Group
195 W. Pine Ave.
Longwood, FL 32750

Fax: (407) 774-6151
dmca [at] europeaches [dot] com

All DMCA notices and counter-notifications must be written in the English language. Any attempted notifications written in foreign languages or using foreign characters will be deemed non-compliant and disregarded.

Please do not send other inquires or information to our Designated Agent.  Absent prior express permission, our Designated Agent is not authorized to accept or waive service of formal legal process, and any agency relationship beyond that required to accept valid DMCA Notices is expressly disclaimed. 

After receiving a DMCA-compliant counter-notification, Our Designated Copyright Agent will forward it to Us, and We will then provide the counter-notification to the claimant who first sent the original Notice identifying the allegedly infringing content.

Thereafter, within ten to fourteen (10-14) days of Our receipt of a counter-notification, We will replace or cease disabling access to the disputed material provided that We or Our Designated Copyright Agent have not received notice that the original claimant has filed an action seeking a court order to restrain the Recipient from engaging in infringing activity relating to the material on the Site’s system or network.

Modifications to Policy

The Site reserves the right to modify, alter or add to this policy, and all affected persons should regularly check back to stay current on any such changes.

Customer Service Requests

Please note that the DMCA Agent is not associated with the Site in any other capacity, but is an attorney with a private law firm.  Customer service inquiries, payment questions, and cancellation requests will not receive a response.  All such communications must be directed to the Site’s customer service department.

This document prepared by Walters Law Group, www.FirstAmendment.com (© 2020). 

All rights reserved. 

This Content Creator Agreement (“Agreement”) sets forth the terms and conditions under which individuals (“Content Providers” or “Creators”) may upload and distribute content on europeaches.com. By uploading, submitting, or otherwise providing content to the Website, you agree to the following:

1. Prohibited Activities

Creators are strictly prohibited from engaging in any activity that is illegal, unlawful, or otherwise violates the Website’s Standards and Policies. This includes, but is not limited to:

• Uploading or distributing illegal content.
• Infringing on intellectual property rights of others.
• Engaging in conduct that may harm the Website, its users, or the general public.

2. Consent Requirements

Creators must obtain and maintain written consent from all persons depicted in any content uploaded to the Website. Such written consent must explicitly cover the following:

• Consent to be depicted in the content.
• Consent to allow public distribution of the content, including upload to the Website.
• Consent to allow downloads, if the content is made available for download by Website users.

Creators are responsible for ensuring all consent forms are accurate, up to date, and retained on file.

3. Age and Identity Verification

Creators are required to verify and confirm the identity and age of all individuals depicted in their content. Specifically:

• All persons depicted must be 18 years of age or older at the time of content creation.
• Creators must retain a copy of a valid, government-issued photo identification for each person depicted.
• Creators must provide such documentation promptly upon request by the Website or its authorized representatives.

4. Compliance

Failure to comply with this Agreement, or inability to provide the required consents and age verification documentation, may result in:

• Removal of the content.
• Suspension or termination of the Creator’s account.
• Reporting to the appropriate legal authorities if required by law.

5. Acknowledgment

By submitting content, the Creator affirms and represents that:

• They have obtained all necessary consents.
• All persons depicted are verified adults.
• They are solely responsible for compliance with this Agreement and all applicable laws.

Effective Date: 16/8/2025
By using the Website as a Content Creator, you agree to this Agreement.