Effective date: August 9th, 2025
Last modified: October 16th, 2025

This Privacy & Cookies Policy (“the Policy”) describes how TBC Sophonix LTD collects, uses, processes, and shares your information. It applies to any information you provide to us, whether through this website, via email, social media, telephone, or in person. By using our products and services, you agree to the use of your information as described in this Policy. If you do not agree, you must not use our services or provide us with your information.

Privacy Policy

1. Data Controller

The entity responsible for processing your personal data is the company that operates the JerkTok software platform.

• Company Name: TBC Sophonix LTD
• Address: Griva Digeni, 78, 2nd floor, Flat/Office B1 Neapoli, 3101, Limassol, Cyprus

For any questions or to exercise your data protection rights, you may write to the address provided.

2. Information We Collect and Process

To offer our services, we collect and process various types of information about you. This information may include:

• Information provided directly by you: This includes data such as your email address, date of birth, and any images you share, such as content related to age verification.
• Information from your activity on the Platform:
  • Your IP address.
  • Information regarding the accounts you have visited and the products or services you have clicked on or shown interest in¹².
  • Any information, communications, and content that you share, store, or save through your account.
  • Information about your interaction with the Platform, including advertisements.
• Technical and device information:
  • Information we collect using cookies stored on your device about your use of the Platform and/or selected third-party websites.
  • Information we collect or remember using technologies similar to cookies, such as your mobile device’s identifiers.
  • Technical information from your device related to the service you receive.
  • Information relating to the location of your device.
• Communications and third-party data:
  • Your communications with billing and support team members.
  • Information provided by other companies that have obtained your permission, through their own privacy policies, to share information about you.

3. How We Use Your Information

We use the collected information for the following purposes:

• General Site Administration and Service Provision: By accessing the Platform, you agree that we may collect, hold, and process your data (including personal information) for the purpose of providing you with the products and services you request, as well as for developing and operating our business.
• User Communications: By providing us with your email address, you agree to receive emails from us. These messages may include purchase or renewal confirmations, warnings, alerts (e.g., about user streams or content submissions), and newsletters.
• Payment Processing: We partner with various third parties to carry out payment processing for purchases you make on the Platform. The processing and storage of information you provide to such third-party payment processors is not governed by this Policy, so you will need to review the third party’s privacy policy on their website.
• Fraud Prevention Services: We use third-party services to prevent fraud and other abusive activities that could harm the Platform. We may provide these services with your IP address and access and device data to detect and prevent potential fraud. This information will be retained indefinitely for the protection of the Platform and its users.
• Use of Information Beyond Our Control: All content and information you share through the Platform is considered public information. If you decide to broadcast, upload, or share any content, you must understand that we cannot control the use of such public information by any user/observer of the Platform. We recommend that you exercise caution when sharing your location, name, account information, or other identifying data.

4. Legal Basis for Data Processing

We process your personal data based on the following legal grounds under the GDPR:

• Consent: We will request your express consent before installing non-essential cookies or sending you marketing communications.
• Performance of a Contract: The processing of your data is necessary for the provision of the services you request when using our platform, which implies acceptance of our terms of use.
• Legitimate Interests: We process certain data, such as your IP for fraud prevention, based on our legitimate interest in protecting the platform, provided that your rights and freedoms do not override this interest.
• Legal Obligation: We comply with Law 34/2002, of July 11, on Information Society Services and Electronic Commerce, and other applicable regulations, which may require the processing of your data to comply with legal or official requirements.

5. How We Share Your Information

Your information may be shared in the following circumstances:

• For service optimization: Your IP addresses, device data, and other usage information are used internally to optimize the Platform. Your usage history may also help our internal algorithm to recommend other users to you.
• With external service providers: Your information may be shared with third parties we contract with to provide certain services on our website, such as hosting and optimization services.
• To process payments: Your “pay to” information, if provided to us, will be shared with third parties (such as our banking and financial service providers) only when necessary to process payments to you.
• For legal and security requirements: We reserve the right to share any account information in response to written requests from law enforcement ; if we believe your account may be involved in illegal activities ; or if we determine it is necessary to protect the rights or property of JerkTok, Platform users, and/or third parties.

6. Data Retention and Deletion

If you request that your personal data be deleted, it will be done in accordance with our data retention policy and applicable law.

• To prevent abuse and impersonation, your email address will be retained.
• If your account is restricted or banned at the time of the deletion request, minimal records related to your account and the restrictions will be kept to maintain such restrictions for the applicable duration.
• By requesting deletion, you agree that all purchases, amounts, and content associated with your account will be forfeited, with no right to transfer or refund.
• A deletion request will not require the deletion of records that we deem necessary to comply with current regulations.
• You can request permanent deletion using the Platform’s deletion tool in your Profile.

7. Your Data Protection and Consumer Rights

In accordance with GDPR and European legislation, you have the following rights:

• Right of Access: To review and receive a copy of the personal information we hold about you.
• Right to Rectification: To correct any inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): To request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected.
• Right to Restrict Processing: To request that the processing of your data be restricted.
• Right to Data Portability: To receive your data in a structured format and transmit it to another controller.
• Right to Object: To object to certain types of data processing.
• Right of Withdrawal (as a consumer): You have the right to withdraw from a product purchase contract within fourteen calendar days of receipt, without any penalty. In this case, you must bear the direct cost of returning the good.

Cookies Policy

1. What are Cookies and What are They For?

A cookie is a small text file that a website saves on your computer or mobile device when you visit it. Cookies are used to make websites work more efficiently and to provide information to the site owners. A cookie does not identify a person, but rather a device-browser-user combination, and in our case, this information is anonymous and encrypted. They allow the web server to recognize the user’s browser to make navigation easier, for example, by allowing already registered users to access areas reserved for them without having to register on each visit. We also use similar technologies, such as “web beacons” (tracking pixels) or device identifiers.

2. What Types of Cookies Do We Use?

The cookies we use can be grouped into four main categories:

• Essential Cookies (Strictly Necessary): These are fundamental for you to move around the website and use its features. Without them, the services you have requested cannot be provided. These cookies are necessary for the proper functioning of the page.
• Functionality and Experience-Enhancing Cookies: These cookies allow the website to remember the choices you make (such as your language or region) and provide enhanced features, like content recommendations.
• Performance and Analytics Cookies: These allow us to track which pages are popular to help other users find such content. We collect anonymous information about user navigation to understand statistics on visits received, using services like Google Analytics.
• Advertising Cookies: We use these to show you ads that are relevant to you based on your viewing history. They also allow us to know how many ads we serve, how many times they are clicked, and how many customer actions they generate

We also use cookies in order to know how many advertisements we serve, how many times these are clicked or hovered over with a mouse cursor, how many advertisements we show to a given user and how many customer actions these generate.

We may also use cookies on the Site and advertisers’ sites to understand which customers reach a sale or other action page on an advertiser’s site. This allows us to monitor how effective our advertising is.

Some of our web pages will contain promotional links to other companies’ sites. If you follow one of these links and then register with or buy something from that other site, a cookie is sometimes used to tell that other site that you came from one of our sites. Such other site may then pay us a small amount for the successful referral. You will need to review the privacy policy of any website whose advertisement you click on as this Policy only applies to pages on our domain.

3. Your Consent for the Use of Cookies

The use of this webpage implies that you give your express and unequivocal consent to the use of cookies, under the terms and conditions provided in this Policy. Prior to their installation, your consent will be requested via a pop-up window. Please note that if you decide to block the installation of cookies, the website’s functionality may be reduced.

4. How to Disable and Delete Cookies

You can, at any time, choose which cookies you want to work on this website by configuring your browser. Below are the links to the instructions for the main browsers:

• Firefox: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-web
• Chrome: https://support.google.com/chrome/answer/95647
• Explorer: https://support.microsoft.com/es-es/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari: http://support.apple.com/kb/ph5042

You can also use third-party tools online, which allow users to detect and manage the disabling of cookies (for example, Ghostery).

5. Contacting us and accessing your personal information

If you have any queries or comments about this Privacy & Cookies Policy OR if you wish to review or receive a copy of the personal information we hold about you, please write to us at:

Attention: TBC Sophonix LTD Griva Digeni, 78, 2nd floor, Flat/Office B1 Neapoli, 3101, Limassol, Cyprus

We reserve the right to charge an administration fee in relation to fulfilling a request for access to personal information which fee shall not exceed the maximum fee allowed by law.

6. Changes to this Privacy & Cookies Policy

We reserve the right to make changes to our Privacy & Cookies Policy. The changes will be posted here and will take effect on the updated effective date. Your continued use of our website or platform will signify your acceptance of these changes.