PRIVACY POLICY

Last updated: 10/02/2025

I, Ricardo Murillo, in my capacity as the legal representative of a company under formation, located at [your full address, including city and state] (hereinafter, "GrupoPkdos" or "we"), am responsible for the processing of personal data in accordance with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP) and its Regulations.

In accordance with Article 3, Section VI, of the LFPDPPP, I am the person in charge of processing your personal data and I inform you that your data will be processed in accordance with the provisions of said law and its regulations, ensuring at all times the confidentiality, access, and rectification of the data in accordance with your established rights.

The Website is classified into the following categories of users:

a) Category 1: Visitor to the Website who accesses the site without creating an account and does not have the ability to upload videos or other content.

b) Category 2: Registered user on the Website who creates an account, but does not upload videos or other materials.

c) Category 3: Registered user who creates an account and uploads videos or other materials to the Website.

d) Category 4: Registered user who creates an account and participates in generating income from the content they upload to the Website.

Subject to the Terms of Service available at https://pajerotube.com/terms/terms (hereinafter, "Terms of Service") and as detailed in the Privacy Notice available at https://pajerotube.com/terms/privacy-policy (hereinafter, "Privacy Notice"), we do not process the personal data of users belonging to Category 1 (i.e., visitors to the Website who have not created an account). In these cases, we use the cookies described in our Cookie Policy, available at https://pajerotube.com/terms/privacy-policy (hereinafter, "Cookie Policy"). For more information, including details on how to manage your cookie preferences and disable them, please refer to our Cookie Policy.

For individuals who belong to the remaining three categories of users (i.e., Categories 2, 3, and 4 mentioned above), personal data will be processed in accordance with this Privacy Policy (hereinafter, "the Policy").

This Policy for Categories 2, 3, and 4 outlines how we collect, use, process, and disclose your data, including personal data, in relation to your access to and use of the Website. We process personal data solely in accordance with this Policy and applicable legislation, particularly the GDPR. By visiting the Website, you confirm that you have read this Policy and understand that your personal data may be processed, including data that may reflect or relate to your sexual life, sexual preferences, and sexual orientation. You also acknowledge that without your consent for the processing of your personal data, we will not be able to fulfill our contractual obligations, offer you the full range of products and services available on the Website, and therefore, you will not be able to create an account on this Website.

If you visit this Website and create an account, you agree that GrupoPkdos will process your personal data, including data that may reflect or relate to your sexual life, sexual preferences, and sexual orientation. By doing so, you give your consent under the understanding that GrupoPkdos is committed to processing such data only to the extent strictly necessary and reasonably to fulfill our contractual obligations and protect our legitimate business interests.

1. INFORMATION WE COLLECT

Personal data refers to any information that allows us to learn details about you or enables your identification, such as your name, location, online identifiers, among others.

In accordance with the Terms of Service and as detailed in the Privacy Notice, we do not process the personal data of visitors to the Website who have not created an account (i.e., users of Category 1, as described previously in this Policy). In these cases, we use cookies for the purposes described in our Cookie Policy, where you can find more information about cookies and an explanation of how you can manage your preferences and disable them if you wish.

For individuals who have created an account on this Website (i.e., users of Categories 2, 3, and 4, as described previously in this Policy), we process the personal data detailed in the following table:

Get more detailed information about the processing of the following categories of information:

1.1 Information that you will not provide.
We collect personal data that we obtain from you when you use our Website, including data you provide in various cases, such as: when viewing videos or other content on the Website, when making inquiries related to our services, when making requests for such services, when registering to use any of our services or when using them, and when you communicate with us via email, the Website, the portal, or other electronic means.

The mentioned data may include:

• Your full name, sex, date of birth, email address, billing address, username, password, photo, nationality, and country of residence, among others.
• Other personal data (e.g., those related to a person’s sexual orientation, if applicable or may be related).

Please refer to the table above for more details about the types of information we collect.

We do not take responsibility as joint controllers of third-party personal data (other than yours) that is available or contained in forms or provided to us otherwise (hereinafter, "Third-Party Personal Data"). We also disclaim any liability for compensation for damages related to Third-Party Personal Data.

1.2 Data we automatically collect from your use of the Website.
We collect information about the services you use and how you use them, such as when you watch a video on the Website or interact with our content. The data we collect includes:

• Device data. We collect information about the device you use, such as IP address, access date and time, type of internet connection, type of device used, as well as data related to cookie files.

• Geolocation data. When you use certain features of the Website, we may obtain information about your approximate location, determined through your IP address.

• Usage data. We collect information about your interactions with the Website, such as the content you view or interact with.

• Cookie files. We use cookies and other similar technologies, such as HTML5 web storage, to improve your experience. You can learn more about the use of these technologies in our Cookie Policy.

1.3 Data we collect from third parties and third-party links.
We may obtain data, including personal data, that others provide about you when they use our Website, as well as collect information from other sources and combine it with the data we obtain through the Website. We do not control or monitor the processing of your personal data by third parties providing this information, so any requests related to the disclosure of your personal data to us must be directed to those third parties.

Furthermore, as permitted by applicable laws, we may obtain additional data about you, such as those related to detecting fraudulent activities, and combine it with the information we already possess.

We inform you that this Website may contain links to third-party websites, software plugins, and applications. If you click on these links or enable these connections, third parties may collect or share data about you. We do not control or monitor these third-party websites and are not responsible for their privacy policies. We recommend that, when leaving our Website, you review the privacy policy of each page you visit.

1.4 Accuracy of the data.
It is essential that the data we hold about you is correct and up to date. We request that you inform us of any changes to your personal data throughout our relationship with you.

2. HOW WE USE THE DATA WE COLLECT

Use, retention, and processing of your personal data.
We use, retain, and process data about you, including your personal data, to offer, understand, improve, and develop our Website, as well as to protect ourselves and our users and comply with our legal obligations. Additionally, we use this data to offer you personalized content, such as showing you more relevant search results.

To avoid any misunderstanding, we make it clear that we do not accept being considered joint controllers of Third-Party Personal Data (other than yours) that is available or contained in a User Submission uploaded according to the Service Provision Terms, and we disclaim any liability for damages arising from Third-Party Personal Data.

2.1 Provision, improvement, and development of the Website.

• Facilitate access to and use of the Website.
• Enable communication between users.
• Manage, protect, improve, and optimize the Website, through performance analysis and research.
• Provide customer service.
• Send service-related messages, updates, security alerts, and account notifications.
• Customize and tailor the user experience, for example, through suggestions or sorting search results. For this, we create basic profiles (customer segmentation) based on your interactions with the Website and your browsing history.

Legal bases:
We process your personal data for the specific purpose of providing, improving, and developing the Website, as described above, based on the following three legal bases:

1. Contract performance: We process this data to properly fulfill the contract we have with you.
2. Legitimate business interests: We process your personal data based on our legitimate business interests, aiming to improve the Website and our users' experience. We believe this processing is reasonable in relation to your interests, rights, and freedoms.
3. Consent: We process special categories of personal data, to the extent necessary to fulfill our contract with you and personalize your experience, based on your consent.

2.2 Our protection, the protection of our users, and compliance with legal obligations

• Detect and prevent fraud, spam, misuse, security incidents, and other malicious activities.
• Conduct security investigations and risk assessments, including reports that third parties may provide about you or the content you uploaded according to the Terms of Service.
• Comply with our legal obligations, including cooperation in the prevention of crimes, such as blocking material related to child and youth sexual abuse, or non-consensual sexual relationships.
• Resolve disputes with our users and enforce agreements with third parties.
• Communicate with you regarding abuse reports (if not submitted anonymously) or requests for removal for copyright infringements or counter-notifications (which cannot be submitted anonymously), which you are authorized to submit according to the Terms of Service.
• Enforce our Terms of Service and other internal policies and regulations.

Legal bases:
We process your personal data based on the following three legal bases:

1. Compliance with legal obligations: We process your data to comply with our legal obligations, which may include disclosing your personal data to third parties or competent authorities.
2. Consent: In some cases, we process special categories of personal data, if necessary to fulfill the purposes mentioned above. This includes transferring certain data to third parties in the context of removal requests for copyright infringement under the Digital Millennium Copyright Act (DMCA), or when responding to a counter-notification related to copyrights, as set out in the Terms of Service.
3. Legitimate interests: We process your personal data based on our legitimate interests in protecting our business activity, including protecting the website and our reputation as a company that complies with applicable legal regulations. We believe that processing your personal data is reasonable in relation to your rights, interests, and freedoms.

2.2.1 Personal data processed when a removal request or counter-notification is submitted under clause 6C of the Terms of Service.

Although our company is based outside the United States, we respect copyright holders' rights and have adopted internal policies to voluntarily comply with laws such as the DMCA, which are detailed later in this text.

What is the DMCA?

The content removal procedure established by the DMCA allows copyright holders to request the removal and withdrawal of any material that infringes their copyrights from our website. In this procedure, the copyright holder (or their agent) sends a removal request to the service provider, asking for the removal of the content they consider infringing. Once the request is received, the website is obligated to forward it to the person who uploaded the content marked as infringing. The person who uploaded the content has the opportunity to respond to the request received. This process serves as an initial step to resolve the dispute between the copyright holder and the person who uploaded the protected content.

To carry out this process, WebGroup is required to process and transfer specific personal data between the copyright holder (or their representative) and the person who uploaded the content. According to the DMCA, we only accept removal requests from copyright holders or those authorized to act on their behalf.

For more information on the details and requirements for removal requests, see https://www.dmca.com/faq/What-is-a-DMCA-Takedown or consult your legal representative. (Please note that we do not offer nor can we offer legal advice, and nothing in this Privacy Policy or other content on our website should be interpreted as legal advice).

The data provided for removal requests or counter-notifications of copyright infringement will be provided to the person who uploaded the marked material.

On what legal basis do we process your personal data when you submit a removal request or counter-notification under the DMCA?

We only use your personal data to review your copyright removal request or counter-notification, in accordance with clause 6C of the Terms of Service. To make your request valid, you need to provide us with the following data:
a) The URL of the website subject to the removal request; and
b) A statement regarding the ownership of the content in question.

We process this personal data to protect our legitimate interests as a service company that respects intellectual property, to comply with the law, and to act appropriately in response to any copyright infringement report. We believe that this data processing is reasonable and necessary to investigate your removal request or counter-notification and to keep you informed about the status of your request.

On what legal basis do we transfer your personal data to the recipient of a removal request or counter-notification under the DMCA?

In accordance with the procedure established by the DMCA, we will share the following personal data with the person who submitted the removal request or counter-notification: your name, contact details, and the content of the request or counter-notification. We transfer your personal data to the recipients of your request based on your explicit consent for such transfer. By submitting a removal request, you consent to the transfer of your personal data to the person who uploaded the content, as detailed in the Terms of Service. Without your consent, we cannot process your removal request or counter-notification as established by the DMCA.

2.3 Direct contact with us through the Website, postal mail, phone, email, etc.

• We will respond to your questions about our services and address your complaints or claims.
• We will provide you with additional information about our personal data protection policies.
• Any other inquiry you have and contact us with.

Legal bases:
If you contact us through our Website, postal mail, phone, email, etc., whether to exercise your rights under the GDPR or file a complaint or report, we process your personal data based on the following legal bases:

1. Legitimate interests: We act in our legitimate interests as an entertainment company, seeking to improve the customer experience when interacting with our website, resolving complaints, and responding to requests for additional information. We process your personal data only to the extent necessary for these purposes.
2. Legal obligations: In cases where necessary, we also process your personal data to comply with our legal obligations, including disclosing personal data to competent authorities when required by applicable laws.

Additionally, in exceptional situations where we detect signs of abuse, harassment, or illegality in your communication with us or our employees, we may process your personal data and, if necessary, transfer it to the relevant authorities. We consider this processing to be reasonable and necessary in relation to your interests, rights, and freedoms.

3. COOKIE POLICY

On our Website, we use cookies and similar technologies, such as HTML5 web storage, to enhance your browsing experience. You can find more information about the use of these technologies in our Cookie Policy, where you will also find details on how to manage and customize your preferences regarding the use of cookies.

4. SECURITY AND PROTECTION

We store all data in a secure environment and protect your personal information through appropriate security procedures and measures, including, but not limited to, the following:

• SSL Encryption: We use SSL encryption to ensure the security of our services, ensuring that data transmission between the user and our website is protected. You can access the SSL-protected website through this link: https://pajerotube.com/.
• Firewall: We implement advanced firewalls to protect your data from unauthorized access.
• Constant Review: We perform regular audits of data collection, storage, and processing, including the implementation of physical security measures to prevent unauthorized access to our systems.
• Restricted Access: We limit access to personal data to only those employees, suppliers, and representatives who need to process it in order to perform their functions. These individuals are subject to strict contractual and legal confidentiality obligations.

If you have reason to believe that the security of your account has been compromised, such as the loss, theft, or unauthorized use of your credentials, we ask that you contact us immediately, following the instructions found in the "Contact Information" section below.

5. YOUR RIGHTS

You can exercise the rights described in this section by configuring your account on the Website or by contacting us at the address listed above. Before processing your request, we will ask you to confirm your identity. If we cannot identify you, we will not be able to process your request.

5.1 Data Management:
You can access and modify part of your data through your account settings. It is your responsibility to keep this information up to date.

5.2 Rectification of Inaccurate or Incomplete Data:
You can request the correction of inaccurate or incomplete data by contacting us at the address provided in the "Contact Information" section.

5.3 Data Access and Portability:
You have the right to request copies of the personal data we store about you. You may also request that we provide these data in a structured, commonly used, and machine-readable format or transfer them to another service provider if technically feasible. You can export your data directly from your account settings.

5.4 Data Retention and Deletion:
We retain your personal data for as long as necessary to fulfill our contracts, legitimate interests, or legal obligations. If you decide to cancel your account, most of the data will be deleted immediately, although some data, such as your email and IP address, will be kept for an additional period for legal and security purposes. We will also retain certain data if an account is suspended due to fraud or copyright infringement.

5.5 Withdrawal of Consent and Limitation of Processing:
If you have given consent for the processing of your data, you can withdraw it at any time through your account settings. Withdrawal of your consent does not affect the legality of the processing prior to the withdrawal. You may also limit how we process your data, for example, if you question its accuracy or if we no longer need it for our purposes.

5.6 Opposition to Processing:
You may object to the processing of your personal data for specific purposes, including profiling. If you object, we will cease processing your data unless we have compelling legitimate reasons.

5.7 Filing Complaints:

If you believe that the processing of your personal data does not comply with the regulations, you can file a complaint with the competent data protection authorities in Mexico, such as the National Institute for Transparency, Access to Information, and Personal Data Protection (INAI), or with the Czech Office for Personal Data Protection (https://home.inai.org.mx/), since GrupoPkds is established in Mexico.

6. GLOBAL SCOPE

When we transfer, store, and process your personal data outside the Mexican Economic Area (MEA), we ensure that appropriate security measures are implemented to guarantee a level of protection of your data. To do so, we use the standard contractual clauses approved by the EU and/or rely on adequacy decisions issued by European authorities. If we cannot apply these bases, we will transfer your data outside the MEA only in the following cases:
a) when necessary to fulfill our contract with you;
b) when necessary to conclude or execute a contract entered into in your interest with another individual or legal entity;
c) when necessary for the establishment, exercise, or defense of legal claims;
d) or when one of the exceptions mentioned in Article 49 of the General Data Protection Regulation (GDPR) applies, such as when you provide your explicit consent.

In addition, we share certain data with the following groups of recipients, whenever we deem it necessary to carry out our activities or when we are legally obligated to do so:

• Public authorities,
• External service providers,
• Financial institutions,
• Storage system providers,
• Technology service providers,
• Service providers necessary for the performance of our activities, such as administrative services, filing, legal advice, debt management, among others.

7. MODIFICATIONS TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time. In case of changes, we will publish the revised version on our Website and update the "Last Updated" date that will appear at the top of this Policy. Additionally, we will send an email to users who have created an account on the Website (i.e., users of Categories 2, 3, and 4, as described above in this Policy), informing them about the changes. If you do not agree with the revised version of the Policy, you may cancel your account. If you do not cancel your account before the effective date of the updated version, your continued access or use of the Website will be subject to the terms of the new Policy.

8. CONTACT INFORMATION

We have designated a personal data protection officer to handle any inquiries related to this Privacy Policy and our data protection practices. If you have any questions or concerns, please feel free to contact him/her at the following contact information:

CONTACT INFORMATION:

Ricardo Murillo
General email: hola@pajerotube.com