Privacy and Communications Policy

This Privacy and Communications Policy ("Policy") is effective as of January 14th, 2020.

This Policy sets forth how CGC Entertainment, in operation of www.iCandyBabes.com ("Website") collects and uses the information you provide to us and certain other information that we automatically collect through your access and use of this Website, any mobile application offered by us or through any communications with us, whether you are a model-user, studio-user or individual subscriber-user of our model content.

If you have any general questions or concerns about this Policy, you may contact us by sending an email with your questions, comments or concerns to support@icandybabes.com.

MODIFICATIONS TO THIS POLICY

If we decide at any time to change this Policy, we will revise the effective revision date posted at the top of this Policy and we will also notify you by posting a notice of the change prominently on our home page and/or upon the next time you access this Website. Failure to opt-out after receiving notice and following the opt-out instructions contained in the notice shall be deemed to be your assent to any such changes.

HOW WE COLLECT PERSONAL INFORMATION

There are a variety of ways in which you may submit certain personal data (personally identifiable information) on this Website. We collect the following specific items of personally identifying information (collectively "PII") that you submit through your use of this Website: your email address, your first and last name, your social media username(s), any videos or photos depicting your image or any audio files containing your voice that you upload in connection with your use of our platform services as either a model-user, studio-suer or a subscriber-user. We also collect your mobile phone number upon registration if you are a model-user or studio-user in order to notify you via SMS messages upon any new subscriber-user Snapchat subscription.

Website Forms

When you provide any PII through any form contained on this Website in order to contact us or send us a message, we collect and store this information. We may use your email or any other PII you provide as expressly set forth in this Policy.

Basic Subscription/Account Information

When you register and create an account as a model-user or studio-user, or when you subscribe to view any model content as a subscriber-user, we collect the PII you provide during registration and use it as set forth in the remainder of this Policy.

Demographic Information

When you provide your age, gender, ethnicity and sexual orientation through your Model Profile biography as a model-user or studio-user (collectively known as "Demographic Information") we collect and store all Demographic Information. We will generally use this information internally to assist us analyze the profiles of who our Website users are and our web traffic in general. We also may share this information in association with your PII as specifically stated in this Policy.

Model Profile & Message Information Collection

WE STORE ALL CONTENT YOU UPLOAD TO YOUR MODEL PROFILE AND ALL PRIVATE MESSAGES YOU POST WITH ANY OF YORU FAN SUBSCRIBERS INCLUDING THE DATE AND TIME SUCH MESSAGES ARE POSTED BY YOU IN CONNECTION WITH YOUR USE OF THE SERVICES. WE ALSO COLLECT AND STORE ALL INFORMATION SUBMITTED DURING ANY CHAT OR MESSAGING CONDUCTED BY YOU WHEN YOU USE OUR PLATFORM TO INTERACT WITH ANY OF YOUR FANS IN CONNECTION WITH OUR SERVICES INCLUDING, WITHOUT LIMITATION, PII (AS DEFINED IN OUR PRIVACY POLICY), THE REAL TIME “CHAT” TEXT OR MESSAGE DIALOGUE BETWEEN YOU AND ANY OF YOUR FANS, YOUR SCREEN NAME YOU USE IN CONNECTION WITH YOUR MODEL PROFILE OR ANY OTHER DATA OR INFORMATION THAT IS DISPLAYED OR TRANSMITTED THEREON. The laws of some jurisdictions require the giving of notice to, or receipt of consent from, individuals prior to intercepting, monitoring and/or recording their communications.

Personal Information from Children Under 13

No person under the age of 18 is permitted to access or use this Website. Children under the age of 13 are expressly prohibited from submitting or posting any PII on this Website. If it does come to our attention that any child under the age of 13 has submitted any personal information to this Website, we will delete all such information that we have collected immediately. If you are a parent or guardian and you discover that your child under the age of 13 has submitted any of his or her PII without your permission or consent, we will remove the information immediately upon your request. All requests should be made by email and sent to support@icandybabes.com. Please include your child's name and a description of the type of information you think he or she may have submitted to this Website.

"Covered Information"

Our platform allows pay-subscribers to upload their avatar and use a screen name when interacting privately with our model-users or studio-users. When you access and use our Website as a subscriber, we collect any screen name/user name you use and display. The manner in which we use, share or disclose this information is expressly stated in this Policy and is referred to as "Covered Information.”

Model-User SMS Notifications

WE COLLECT ALL MOBILE NUMBERS PROVIDED TO US BY OUR MODELUSERS OR STUDIO-USERS AND WILL USE SUCH MOBILE NUMBERS TO SEND SMS/MMS MESSAGES TO OUR MODELS. We will send such SMS/MMS messages to any mobile phone number provided to us each time a new subscriber-user subscribes to view such model’s content via Snapchat. We will at all times comply with the Telephone Consumer Protection Act (“TCPA”), the Federal Trade Commission Act, all rules and regulations promulgated by the Federal Communications Commission, the DNC list registry rules (http://www.donotcall.gov) and various state laws, rules and regulations that place restrictions on our SMS or MMS message campaigns. We will include clear opt-out/unsubscribe information. You represent to us that You are either the owner/account-holder of any phone number(s) provided to us by You pursuant to this Agreement, or are otherwise authorized to consent to the receipt of such SMS/MMS messages to any such number(s) you has provided on behalf of the recipient.

HOW WE AUTOMATICALLY COLLECT NON-PERSONAL INFORMATION

When you access our Website, we collect and store through our host provider certain non-personally identifying information sent automatically by your browser using standard web server logs and automatic data collection tools such as cookies and web beacons. This information may include your IP address, which may tell us your general location information such as your country and sometimes your city, state and/or zip code, the domain name from which you access our Website, your browser type and language, the pages you access, the date and time you access pages on our Website and your operating system version. We also may determine what technology is available through your browser in order to provide you with the most appropriate version of any of our web pages.

Cookies & Similar Tracking Technologies

We along with third parties that assist us to operate this Website may monitor your use of this Website through cookies, web beacons and other “automatic data collection tools." Unless you have adjusted your browser setting to refuse all cookies, some cookies are placed on your browser immediately as soon as you visit our site. Cookies and similar collection tools are files with a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and transferred to your device. We reserve the right to monitor your use of this Website and track you as described in this Cookies policy by the use of any automatic data collection tools at all times and you consent to the use of these tools when you use and access our Website.

This Website uses both "first-party cookies" and "third-party cookies." Firstparty cookies are those used by our Website each time you visit our Website.

Third-party cookies are cookies that are set by a third-party source other than our Website. We do not have access or control over these cookies. We also use both "persistent cookies" that remain on your device for the period of time specified in the cookie (these cookies are activated each time you visit our Website), and "session cookies," which allows us to track your actions on this Website during a browser session. Each time you open up a browser window and close the browser window represents a single browser session. All session cookies are created temporarily and are deleted once you close your browser window.

Both the first-party and third-party cookies and tracking technologies used on this Website can be broadly divided into the following categories

-Necessary cookies help make our website usable by enabling basic functions like page navigation and access to secure areas of the website. Our website cannot function properly without these cookies.

-Statistic cookies helps us understand how visitors interact with websites by collecting and reporting information anonymously.

-Marketing cookies are used on this Website by Google, YouTube and other third-parties to track visitors across different websites. The intention is to display ads that are relevant and engaging for the individual Google user.

First-Party Cookies/Tracking Technologies

Your Website Use: We use automatic data collection tools to track and record your Website use and activity data, including the pages you view and how long you spend on each page or portion of our Website, the links you click on, the features of this Website you access, whether you are a new vs. repeat visitor or in order to monitor your interactions with any video or other content that you access on this Website ("Use Information"). This is done primarily for website traffic and general user analysis purposes. We also do this to help measure and research the effectiveness of the features contained on this Website.

Analytics Services: We may use third party web analytics services, such as Google Analytics, in order to collect information about your use of this Website. We pass a "first party cookie" onto your browser directly from our Website when we use Google Analytics. You may opt-out of Google Analytics by using Google's Browser Add-on at https://tools.google.com/dlpage/gaoptout.

User Preferences: We use automatic data collection tools to identify and recognize your browser as a previous visitor to our Website and save and remember any user preferences and log-in information. We store specific user preferences and settings on this Website and/or stores similar session identifiers to help you navigate and access certain features on this Website.

Email Retargeting: We may also use clear gifs (imbedded web beacons) to understand whether users read email messages or newsletters and/or click on links contained within those messages or newsletters so that we can deliver relevant content or product offers. Through the use of unique identifiers contained in the URL of the web beacons, we are able to record the exact time that you read our emails, as well as your IP address. Some emails and web pages may refer to content on another server rather than including the content directly. Requests to the server to send the additional content typically includes the IP address of the requesting computer, the time the content was requested, the type of web browser that made the request and the existence of cookies previously set by that server, which may be linked to a unique tracking “token.”

Third-Party Cookies/Tracking Technologies

Here are the specific third-party cookies we use on this Website:

A. YouTube. GPS location data is collected by YouTube to track you on different websites to see what videos you watch and how they are used. Learn more about how Google may use this information.

B. Other Specific Third-Party Cookies & Providers List

Category: Marketing (12)

How To Manage Cookies

You can block our cookies or third-party cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to use all or parts of our site in the manner intended.

Your Internet browser allows you to change your cookie settings in the 'options' or 'preferences' menu of your browser. Please visit the following link for more information on these settings in various browsers:

https://www.thewindowsclub.com/disable-enable-cookies-internet-explorer

For even more information about deleting or blocking cookies, please visit: https://www.aboutcookies.org/page/2/

Social Media Features and Widgets

We may also provide access to services or features on our Website that enables you to share information with certain social networks and interact with us on our social media fan pages or other social media platforms that we may utilize. This may include the Facebook "Like" or share buttons or the Facebook "Comments" feature, social media "follow-us" buttons, etc., all of which are administered via third party applications or scripts that run on our Website. (For example, Facebook will attempt to track your use on our Website by placing Javascript code through the "like" button and that piece of code then allows Facebook to run a script on your browser which can set cookies and make more tracking requests.) Your use of these features may result in the collection or sharing of information about you by these third arty social media websites. This may include collecting your IP address, tracking your use on our Website and other third party websites containing the same social media features, including the pages you visit, duration, time, etc., through the use of a cookie or other unique identifier placed on your browser by such third parties. Your interactions with these social media features are governed by the privacy policy of the party that provides the specific feature or application. You should carefully review the privacy policies and settings on those specific social media sites. In addition, these standalone plugins that integrate into our website may also communicate with an external server controlled by the plugin provider as part of their service. We shall, under no circumstances, have any liability to you whatsoever for the information collection and use/disclosure practices of any such third party that has provided or 7 made available any social media feature or application that you use on our Website.

SOCIAL MEDIA & THIRD PARTY PRIVACY PRACTICES

YOU ARE GIVEN THE OPPORTUNITY THROUGH THIS WEBSITE TO ACCESS OUR MODEL-USER OR STUDIO-USER PRIVATE CONTENT ON SOCIAL MEDIA BY CLICKING ON ANY THIRD PARTY LINKS CONTAINED ON THEIR RESPECTIVE MODEL PROFILES. WE ALSO RELY ON THIRD PARTY SERVICE PROVIDERS TO OPERATE THIS WEBSITE THAT MAY HAVE LIMITED ACCESS TO YOUR INFORMATION. BY USING THIS WEBSITE INCLUDING SUBMITTING ANY REQUESTED INFORMATION AND ACCESSING ANY THIRD-PARTY SOCIAL MEDIA ACCOUNT OF ANY OF OUR MODEL-USERS OR STUDIO-USERS, YOU AFFIRMATIVELY CONSENT TO HAVE THAT INFORMATION SHARED WITH THESE THIRD PARTIES FOR THE LIMITED PURPOSES STATED HEREIN. ANY INFORMATION USED BY ANY THIRD PARTIES MAY BE SUBJECT TO A DIFFERENT SET OF PRACTICES THAN THOSE DESCRIBED UNDER THIS POLICY AND WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY OF SUCH THIRD PARTIES. YOU SHOULD READ THE PRIVACY POLICY CONTAINED ON THE WEBSITE OF ANY THIRD PARTIES BEFORE YOU PROVIDE ANY INFORMATION TO THAT PARTY. YOU AGREE THAT WE SHALL NOT, UNDER ANY CIRCUMSTANCES, HAVE ANY LIABILITY TO YOU FOR ANY DAMAGES OF ANY KIND WHATSOEVER FOR THE MANNER IN WHICH ANY SUCH THIRD PARTIES USE OR DISCLOSE ANY PERSONAL, BILLING OR OTHER INFORMATION YOU ROVIDE VOLUNTARILY, OR THAT IS COLLECTED BY THOSE WEBSITES, THROUGH YOUR ACCESS OR USE OF THIS WEBSITE.

Our Data Processors & Subprocessors

A data processor is any third-party that we use to operate this Website or provide our Services to you who has or potentially will have access to or process any personal data you provide to us. These data processors may engage different types of subprocessors to perform various functions. This limited access is incidental to the services being provided by such third parties to us to operate this Website and/or to provide our Services to you and no permission or consent is granted by us to use or disclose this information in any manner other than as necessary to provide the pplicable services to us or to facilitate any transactions with you.

In addition, we require all of our data processors and subprocessors to satisfy the requirements of the GDPR in terms of data protection and use, including but not limited to the requirements to:

• Process personal data in accordance with our documented instructions;
• Use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws including the GDPR, in connection with their subprocessing activities;
• • Provide regular training in security and data protection to personnel to whom they grant access to any personal data;
• • Implement and maintain appropriate technical and organizational measures (including measures consistent with those to which we may be contractually committed to adhere to insofar as they are equally relevant to the subprocessor’s processing of personal data on our behalf);
• Promptly inform us about any actual or potential data breaches; and
• Cooperate with us in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

We use the following data processors:

1. Infrastructure & Data Storage

Amazon Web Services (AWS) Hosting/Data Storage. We use AWS to host this Website and store your data on their cloud based servers.

2. Specific Services

Epoch Payment Processing. When you subscribe as a subscriber-user to access any private model content on this Website, You also share the PII you provide, your credit/debit card or bank account information you provide with Epoch Payment Solutions, our third party payment processor. Any disclosure of this information is necessary to facilitate the specific transaction and will only be used by us for that strict purpose, unless otherwise stated in this Policy. This limited access is incidental to the services being provided by Epoch and no permission or consent is granted by us to use or disclose your information in any manner other than as necessary to process any payment(s) you initiate.

Email Marketing. We use email marketing service for providing our email marketing services and similar content marketing services to our users.

Administrative/Subscriber Service Support. We reserve the right and may share our files and some PII we collect through this Website directly with third party independent contractors that provide subscriber support and other administrative services on our behalf. We will only contract such third parties for the limited purpose of assisting us to operate this Website and/or provide support or administrative services in conjunction with any products or services that we may offer through this Website from time to time. This limited access would be incidental to the services being provided by such third party contractors and no permission or consent shall be granted by us to use or disclose this information in any manner whatsoever, other than as necessary to provide the applicable services to us. We will require that our independent contractors commit to uphold the privacy of any PII or other information regarding our Website visitors or subscribers that we may share with them. We will require that each of our contractors agree not to use or disclose any Identity Information, which may be disclosed to or shared with these parties during the course of their duties to us, except as absolutely necessary to perform their duties to us.

CRM/Content Management. We use Indianic (indianic.com) for our CRM, content management and other backend functions such as API Development.

Pilvo SMS Notifications. We use Pilvo (www.plivo.com) to assist us in sending SMS text notifications each time a new subscriber-user subscribes to access/ view their Snapchat profile. Pilvo collects this information through an integration accessible to each model-user or studio-user via their model profiles when they provide their mobile numbers.

Your California Resident Privacy Rights: California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of their personal information to third parties for their direct marketing purposes. California law also allows California residents to opt-out of having this information disclosed. If You are a California resident and desire to make such a request, please contact support@icandybabes.com. Please include the words "California Privacy Disclosure Request" in the subject line.

Your Rights Under The GDPR

Under the General Data Protection Regulation (GDPR), EU citizens (and individuals located in the EU during data collection) have the following rights:

• The right to access stored personal data and have it provided to you in an electronic, machine-readable format.
• The right to rectify errors in your personal data.
• The right to know how you personal data will be used.
• The right to know how long you personal data will be stored.
• The right to know with whom your personal data is being shared.
• The right “to be forgotten” and have any stored personal data permanently deleted.
• The right to withdraw your prior consent to and/or restrict certain uses of personal data we collect.
• The right to know the source of your personal data collection if informed consent was not given.

If you are an EU natural citizen, please email support@icandybabes.com to contact us in order to exercise any of these rights.

HOW WE USE/SHARE YOUR INFORMATION

Promotional & Informational Use of Emails

We use the e-mail address provided by our registered members and users who check-out to send periodic promotional e-mails and/or newsletters about our services and products or about any new or upcoming products, but only if you have elected to receive such email communications from us. You can opt-out of receiving any promotional emails or newsletters at any time by either clicking "unsubscribe" in the body of the email communication and following the opt-out procedure contained in the email or by sending an email to support@icandybabes.com and requesting to opt-out of receiving such communications

Marketing & Business Consultants

We may share Use Information and Demographic Information in association with certain Identity Information, or certain PII by itself, that we collect through your use of this Website with our marketing and/or business consultants (or partners) and any other similar such parties. This information may also include your IP address. We do this strictly in order to improve upon any aspect of our marketing strategies, sales practices or upon some other business practice. We may also share this information with third party website and SEO consultants in order to help improve the functionality or accessibility of this Website, search engine visibility or to help us increase our web traffic. This limited access is incidental to the services being provided by such third parties and no permission or consent is granted by us to use or disclose this information in any manner other than as necessary to provide the applicable services or responsibilities to us. In such instances, we require that all such third party consultants or partners are committed to securing your PII and any other information that we may share with them.

Do We Sell Your Identity Information?

We make every effort to respect your privacy and we will never sell, license or disclose any of your Identity Information, by itself or bundled with any Use Information or other information you provide or that we collect to any third parties for any purpose not expressly set forth in this Policy without your express written consent. We only share or disclose any PII or other information collected from You as expressly set forth in this Policy.

Required Disclosures

We may disclose certain PII if: i) requested via a subpoena, court order, or local, state, federal or international law enforcement request to release any such information; or ii) in order to investigate and help prevent security threats, fraud or other malicious activity; or iii) to protect our rights or protect our property, or any or the rights of our subscribers or other third parties.

Communications

When you visit this Website or send e-mails to us, you are communicating with us electronically. You consent to receive communications from us electronically. You agree that all agreements, notices and other communications that we provide to you electronically satisfy any legal requirement that such commu11 nications be in writing. If you send us an email communication, call us or send a written correspondence for any reason, we may create a file and store your email and other PII specific to you. We generally will maintain a record and keep notes of all communications with you. All messages transmitted by you on this Website or to us shall not be treated as confidential and shall be deemed to be accessible to the general public. You should not transmit any communications or correspondences to us that you intend only the intended recipient(s) read. Notice is hereby given that all messages or electronic data transmitted onto this Website can and may be read by us, regardless of whether we are the intended recipient of any such message(s).

HOW WE PROTECT YOUR INFORMATION

We use industry standard security measures to protect all PII and billing information you provide. For instance, when you provide any credit card or other billing or shipping information through our checkout process, we encrypt that information during transmission using Secure Sockets Layer (SSL) encryption. We make no guarantee, warranty or representation that your credit card or other billing information, or any other information you provide through this Website, will remain secure at all times from any illegal or unauthorized access of the information by third parties. We shall not, under any circumstances, be held responsible or liable for information or transmissions that are accessed by third parties illegally or without authorization through this Website and/or network. We will report any unauthorized access of your information promptly upon discovery, and we will use our best efforts to remedy any security vulnerability that contributed to the unauthorized access.

GENERAL INFORMATION

Information Storage And International Transfer

Any PII and all other information which we collect on this Website will be stored and processed in our servers located in the United States. If you reside outside the United States, you consent to the collection, transfer, storage and processing of any information from your country to the United States.

How to Update, Change or View Your Identity Information

If you would like to request any changes or updates to any PII you have provided to us, or if you would like to view any information we have collected from your use of this Website, please contact us and request the same by sending an email to support@icandybabes.com. Please include the words "Personal Information Request." If you make any information requests, we will require that you provide proof of your identity, which may include providing us with a copy of a driver's license, social security card and/or birth certificate. We also reserve the right to require that you sign and provide us with a notarized affidavit verifying your identity before we update or release any information to you.

Successors

Upon any acquisition, merger, sale or other change of control of our business/ organization, we reserve the right to transfer any PII you have submitted to this Website as part of the property owned by us to our successor resulting from such merger, acquisition, sale, etc. In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, We reserve the right to transfer your PII to protect any of the our rights or as required by law.