About

Circl is the platform that gives power back to Content Creators by allowing them to generate recurring revenue through Users who subscribe to paid subscriptions to access valuable content. On Circl, Creators are free to post when they want, at their preferred frequency, without being subject to algorithm constraints. They can thus manage their business autonomously. As for users, they access content through subscriptions they subscribe to directly from the platform's Creators. The Circl platform, available on "circl.my", is published and operated by KODIGI SAS ("KODIGI"), a simplified joint-stock company with a share capital of 10,000 euros, registered in the Paris Trade and Companies Register under number 925 375 289, with its registered office at 229 rue Saint Honoré, 75001 Paris - France.

User Safety on Circl

Aware of its responsibilities and role, KODIGI has, since its creation and from its conception, made user safety a priority. It relies particularly on solutions based on artificial intelligence (AI). Circl offers a secure environment based on very strict content certification and moderation processes:

1. Creator Certification

100% of Creators visible on the platform are certified, and Users are also invited to go through the certification process. This system guarantees the identity of each user. If the Creator's profile does not meet the platform's requirements, they will not be able to generate revenue.

2. Content Moderation

Creators offer their subscribers photo content, video, Lives, or private correspondence. The analysis of these media takes place daily through a strong process: content is verified and moderated by Artificial Intelligence (AI). In case of reporting, as a host, KODIGI promptly evaluates the "manifestly illegal" nature of the content and, if necessary, makes it unavailable. Additionally, KODIGI may, if needed, notify law enforcement of suspected law violations by users. Finally, to protect our users and protect minors, all users are subject to an age verification process before accessing potentially "sensitive" content.

Data Protection and Retention

KODIGI has made the protection of users' personal data, along with their security, a priority. KODIGI collects and stores user information in accordance with Circl's Terms of Service and Privacy Policy. This includes: identity documents, identification data, connection data, economic and financial information, transaction data, navigation data, and information related to the use of Circl. Data is retained in accordance with applicable legislation and as long as necessary to allow users to use Circl. In any case, as explained in Circl's Privacy Policy, users can access their data and know how it is used by contacting KODIGI' data protection officer by email at support@circl.my.

Legal Framework

KODIGI commits to cooperating with law enforcement investigations when appropriate under applicable law. As a French company, KODIGI discloses user data in accordance with applicable French and European law and as provided for in its Terms of Service, General Terms and Conditions, and Privacy Policy. In accordance with the law, KODIGI may provide information about its users to French law enforcement authorities (for example, judicial, police, or gendarmerie administrations) when requested. KODIGI may also respond to content removal injunctions on the Circl platform, issued by law enforcement or an authority (judicial or administrative) and consequently remove the targeted content. KODIGI will not respond to information requests from private parties, such as civil parties, unless they are part of an official judicial procedure.

Injunctions

From French Authorities

Injunctions from authorized authorities and law enforcement may concern information about a user (name, surname, date of birth, and phone number), their account (creation date and IP address), and content created by the user (media). In accordance with the law, authorities requesting information about a user are only organizations authorized by legislative or regulatory provision, as part of a specific mission (such as judicial, police, or gendarmerie administrations).

These data requests, or injunctions to act against content, must meet several conditions:

Formal requirements:

• Written in French or English
• On law enforcement letterhead and signed by an authorized law enforcement official
• Contain information identifying the issuing authority
• Contain information about the authority that should receive information about the orders' execution
• Submitted by mail and email to the address mentioned below (support@circl.my)
• Be occasional
• Include a valid official email address for communication with KODIGI

Substantive requirements:

• Specify the legal basis on which it is founded
• Explain the motivation for the injunction (except where exempted by law)
• Provide information allowing the provider to identify and locate the illegal content concerned
• Where applicable, indicate the categories of data to be communicated
• Finally, contain information about the appeal mechanisms available to KODIGI and the user subject to the injunction

If authorities do not meet the above requirements, KODIGI will not be able to process their requests.

From Foreign and International Authorities

KODIGI may require law enforcement members to submit a request for legal assistance to designated government authorities under Mutual Legal Assistance Treaties ("MLAT"), or through letters rogatory. This may occur when the requesting law enforcement is located in a country different from KODIGI' establishment. When submitting a request, law enforcement officers must ensure that the information provided is complete and accurate, and that the requested data communication (or any other measure) is necessary and proportionate for the purposes of preventing, detecting, or investigating offenses, or to prevent an emergency situation. KODIGI reserves the right to request reimbursement of costs associated with responding to law enforcement requests.

Emergency Procedures

In cases where a person would be exposed to imminent danger, such as death or serious physical injury, and KODIGI has information that could help prevent harm, law enforcement officers may also contact KODIGI directly while the official procedure is ongoing. An urgent request is only considered as such when there is an immediate risk of harm to a person's life or physical integrity. All urgent requests for data, injunctions to act, or data preservation must be made by an authorized law enforcement representative and come from an official law enforcement email domain if sent by email.

User Information

In accordance with personal data protection laws and regulations, KODIGI informs Circl users of the disclosure of their data to law enforcement, unless the injunction states that this information:

• Is prohibited by applicable law (provide legal basis)
• Would compromise an investigation
• Would endanger one or more persons

It is the responsibility of the issuing authorities to clearly indicate in the injunction the confidentiality of the procedure.