PRIVACY POLICY

Last Updated: September 21, 2026

Introduction

Unlockt.me, LLC and Unlockt.me SAS operate the Unlockt platform, including www.unlockt.me, its affiliated websites, mobile applications and related services (collectively, the “Site” or the “Services”).

We respect your privacy and are committed to protecting your personal information. This Privacy Policy (“Policy”) explains what personal information we collect, how we collect and use it, when we may disclose it, how long we retain it, and the rights available to you in relation to your personal information.

The Unlockt entity responsible for providing the Services may depend on your location.

For Creators located in France, the European Economic Area (“EEA”) and the United Kingdom, the relevant entity is:

Unlockt.me SAS
14 rue Charles V
75004 Paris
France

For Creators located in the United States, Canada and other jurisdictions outside the EEA and United Kingdom, the relevant entity is Unlockt.me, LLC.

For purposes of applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and UK GDPR, Unlockt.me SAS is responsible for the processing of personal information relating to users in France, the EEA and the United Kingdom where applicable.

Unlockt.me, LLC and Unlockt.me SAS may also process information as affiliated entities where necessary to operate, secure and provide the Services.

This Policy applies to users of the Services, including Creators, Uploaders, Fans, Downloaders and other visitors, regardless of whether they are located in the United States, Europe, the United Kingdom or another jurisdiction in which the Services are available.

Please read this Policy carefully to understand our practices regarding your personal information.

We may update this Policy from time to time. Any updated version will be posted on the Site together with the applicable “Last Updated” date.

1. How old do you have to be to use the Services?

The Services are intended only for persons who are at least eighteen (18) years old.

We do not knowingly permit persons under the age of eighteen (18) to create Creator accounts or access age-restricted content through the Services.

Where required by applicable law, we may use age assurance, age estimation, identity verification or other age-verification measures before allowing access to certain content or functionality.

If we become aware that we have collected personal information from a person who is not permitted to use the Services, we may delete or restrict that information as required by applicable law.

If you believe that we may have collected information from a person under eighteen (18), please contact us at support@unlockt.me.

2. What types of personal information do we collect?

Depending on how you use the Services, we may collect information including:

• name;
• alias, username or account identifier;
• email address;
• billing or postal address;
• account credentials;
• IP address;
• device information;
• browser and network information;
• usage and interaction information;
• approximate or precise location information where permitted;
• transaction and purchase history;
• payment-related information;
• bank or payout information;
• tax identification information where required;
• government-issued identification information;
• date of birth;
• identity and age-verification information;
• photographs, videos or other content submitted through the Services;
• communications with Unlockt;
• fraud, risk and security information; and
• other information you choose to provide to us.

Where necessary for identity verification, age assurance, fraud prevention, security or content moderation, we or our service providers may process information derived from photographs, videos or identification documents, including facial characteristics or other biometric-related information, where permitted by applicable law.

We seek to limit the collection of personal information to information that is reasonably necessary for the operation, security and legal compliance of the Services.

3. How do we collect your personal information?

We may collect personal information directly from you when you:

• create or manage an account;
• complete an identity or age-verification process;
• upload or publish content;
• make a purchase;
• receive or request a payout;
• submit tax or payment information;
• complete a questionnaire or survey;
• contact customer support;
• report content or another user;
• communicate with us; or
• otherwise use the Services.

We may also collect certain information automatically through:

• servers and log files;
• cookies and similar technologies;
• device identifiers;
• security technologies;
• fraud-prevention systems;
• analytics services; and
• content moderation and risk-detection technologies.

We may also receive information from service providers that assist us with payments, identity verification, age assurance, fraud prevention, moderation, analytics, security or other functions necessary to operate the Services.

4. Information collected by third parties

Certain features of the Services rely on third-party providers, including payment processors, financial institutions, identity and age-verification providers, fraud-prevention providers, cloud-hosting providers, analytics providers and other technical service providers.

These third parties may process personal information in accordance with their own privacy policies and contractual obligations.

The Site may also contain links to third-party websites or services that are not operated or controlled by Unlockt.

We are not responsible for the privacy practices of independent third-party websites or services. We encourage users to review the applicable privacy policies before providing personal information to those third parties.

5. How do we use your personal information?

We may use personal information as reasonably necessary to:

• provide and operate the Services;
• create and manage accounts;
• authenticate users;
• verify identity and age;
• process transactions;
• facilitate Creator payouts;
• provide customer support;
• personalize and improve the Services;
• maintain the security and integrity of the Services;
• detect and prevent fraud, abuse and unauthorized activity;
• detect, review and moderate prohibited or potentially unlawful content;
• enforce our Terms, policies and community rules;
• investigate reports and complaints;
• comply with legal and regulatory obligations;
• comply with payment-network and financial-partner requirements;
• respond to lawful requests from authorities;
• maintain records required by law;
• analyze the performance and use of the Services;
• communicate important service or policy updates;
• send marketing communications where permitted by law; and
• carry out other purposes disclosed to you at the time your information is collected.

6. Legal bases for processing personal information in the EEA and United Kingdom

Where the GDPR or UK GDPR applies, we process personal information only where we have an appropriate legal basis.

Depending on the circumstances, these legal bases may include:

Performance of a contract.
We may process your personal information when necessary to provide the Services you have requested or to perform our contractual obligations to you.

Compliance with legal obligations.
We may process information where necessary to comply with applicable laws, regulations, tax requirements, financial requirements, court orders or other legal obligations.

Legitimate interests.
We may process information where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your fundamental rights and freedoms. These interests may include preventing fraud, maintaining platform security, enforcing our policies, improving the Services and protecting our users.

Consent.
Where required by applicable law, we may ask for your consent before processing certain categories of information or using information for particular purposes. Where processing is based on consent, you may withdraw your consent at any time, without affecting processing carried out before withdrawal.

7. Do we share your personal information with third parties?

We may share personal information with our affiliated companies and with third parties where reasonably necessary to provide and protect the Services.

These recipients may include:

• payment processors;
• acquiring banks and other financial institutions;
• payout providers;
• identity-verification providers;
• age-assurance providers;
• fraud-prevention providers;
• content-moderation providers;
• cloud and infrastructure providers;
• cybersecurity providers;
• analytics providers;
• customer-support providers;
• professional advisers, including lawyers, accountants and auditors;
• regulators and government authorities; and
• law-enforcement authorities where legally required.

We may also disclose information:

• where necessary to comply with applicable law;
• in response to lawful legal process;
• to investigate suspected fraud, illegal conduct or violations of our policies;
• to protect the rights, property or safety of Unlockt, its users or others;
• as part of a merger, acquisition, financing, restructuring or sale of all or part of our business; or
• with your consent.

We may share aggregated or de-identified information where permitted by applicable law.

8. International transfers of personal information

Unlockt operates internationally, and personal information may therefore be processed in countries other than the country in which you reside.

This may include transfers between Unlockt.me SAS, Unlockt.me, LLC and service providers located in other jurisdictions.

Where personal information protected by the GDPR or UK GDPR is transferred outside the EEA or United Kingdom, we will take appropriate measures required by applicable data protection law to protect the information.

Where required, this may include the use of an applicable adequacy decision, contractual safeguards or another lawful transfer mechanism.

9. What choices do you have regarding your personal information?

Depending on your account type, you may be able to review, modify or delete certain information directly through your account.

Creators may also delete certain content or account information made available through their account.

You may contact us at support@unlockt.me regarding your personal information or to request the deletion of your account.

Certain information may continue to be retained after an account deletion where necessary to:

• comply with legal or regulatory obligations;
• prevent fraud;
• resolve disputes;
• enforce our agreements;
• maintain financial and transaction records; or
• protect the security and integrity of the Services.

You may also manage cookies through your browser settings. Disabling certain cookies may affect the functionality of the Services.

10. Rights of users in the EEA and United Kingdom

If you are located in the EEA or United Kingdom, you may have certain rights under the GDPR or UK GDPR, subject to the conditions and exceptions provided by applicable law.

These may include:

• Right of access: the right to request confirmation as to whether we process your personal information and obtain access to that information;
• Right to rectification: the right to request correction of inaccurate or incomplete personal information;
• Right to erasure: the right to request deletion of personal information in certain circumstances;
• Right to restriction: the right to request that processing of your personal information be restricted in certain circumstances;
• Right to object: the right to object to certain processing based on legitimate interests and to processing for direct marketing;
• Right to data portability: the right, in certain circumstances, to receive personal information you have provided to us in a structured, commonly used and machine-readable format and to transmit it to another controller;
• Right to withdraw consent: where processing is based on your consent, the right to withdraw that consent at any time; and
• Right to complain: the right to lodge a complaint with the competent data protection supervisory authority.

You may exercise these rights by contacting us at:

support@unlockt.me

We may request information reasonably necessary to confirm your identity before processing a request.

We will respond to applicable privacy and data-protection requests without undue delay and, in principle, within one month of receiving the request.

As an operational objective, we aim to handle requests within 30 days wherever possible.

Where permitted by applicable law, the response period may be extended where a request is particularly complex or where multiple requests have been submitted. If an extension applies, we will inform you within the initial applicable response period.

The GDPR expressly provides rights including access, rectification, erasure, restriction, portability and objection.

11. How long do we retain your personal information?

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to:

• provide the Services;
• maintain account and transaction records;
• meet legal, tax, accounting or regulatory obligations;
• prevent fraud and abuse;
• resolve disputes;
• enforce our agreements; and
• protect our legal rights.

Retention periods may vary depending on the type of information, the reason it was collected and applicable legal requirements.

Where personal information is no longer required, we may delete, anonymize or otherwise securely dispose of it, subject to applicable law.

12. How do we protect your personal information?

We maintain technical, organizational and administrative safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration or disclosure.

Access to personal information is limited to personnel and service providers who reasonably require access for legitimate business purposes.

However, no method of transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

13. Automated systems, fraud prevention and content moderation

We may use automated technologies to assist with fraud prevention, identity and age assurance, platform security, risk assessment and content moderation.

These systems may identify transactions, accounts, content or activity for additional review.

Where applicable data protection law provides rights relating to decisions based solely on automated processing that produce legal or similarly significant effects, those rights will apply.

14. U.S. State Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws.

Where those laws apply to Unlockt and to a particular user, we will provide the rights required by applicable law.

Requests concerning applicable U.S. privacy rights may be submitted to:

support@unlockt.me

California

Where applicable, California residents may have rights concerning access, correction, deletion and other processing of personal information under applicable California privacy law.

We do not sell personal information in exchange for monetary consideration.

Other U.S. States

Residents of other U.S. states may have additional privacy rights where the relevant state privacy legislation applies to Unlockt.

These rights may include, depending on applicable law, rights to:

• confirm whether personal information is being processed;
• access personal information;
• correct inaccurate personal information;
• request deletion;
• obtain a portable copy of certain information; and
• appeal certain decisions concerning privacy-rights requests.

15. Marketing communications

Where permitted by applicable law, we may send communications concerning Unlockt and its Services.

Where consent is legally required, marketing communications will be sent only where the required consent has been obtained.

You may unsubscribe from marketing communications by using the unsubscribe mechanism provided in the relevant communication or by contacting us.

Service-related communications, including security, transaction, account and legal notices, may still be sent where necessary.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our Services, operations or legal obligations.

When we make material changes, we may provide additional notice where required by applicable law.

The date at the top of this Policy identifies when it was most recently updated.

17. Contact Us

Questions, requests or concerns concerning this Privacy Policy or the processing of personal information may be sent to:

Email: support@unlockt.me

For users located in France, the EEA or the United Kingdom:

Unlockt.me SAS
14 rue Charles V
75004 Paris
France

For other applicable jurisdictions:

Unlockt.me, LLC
United States

Users in the EEA or United Kingdom also have the right to contact or lodge a complaint with the competent data protection authority in their country of residence, employment or where they believe a violation of applicable data protection law occurred.

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