Public Policies

Global Privacy Policy

SHOBBL LLC GLOBAL PRIVACY POLICY

Effective Date: July 1, 2025

Last Updated: August 5th, 2025

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1. INTRODUCTION AND SCOPE

We at Shobbl LLC ("Shobbl," "we," "us," or "our") are committed to minding and protecting the privacy and personal information of all those who interact with our Services ("Users") and Users who register an account for and access our Services ("Customers") or further set up a creator page and/or licensed product listing ("Creators") (together referred throughout our policies by the terms “you” and “your”).

We adjust what data we collect from you for compliance with the requirements of each supranational entity, country, state, province, territory, overseas territory, dependency, special administration region, municipality, local government, or indigenous jurisdiction you operate within (each identified jurisdiction you are accessing us from together referred to throughout our policies by the term "Compliance Region").

This Privacy Policy outlines how we collect, use, process, share, and protect personal information when you:

• Interact with our websites that reference or link to this Policy.
• Utilize our products, services, software, technology platform, or mobile applications, where we manage your personal data.
• Communicate with us or receive messages from us.
• Opt in to receive our newsletters, updates, or other notices.
• Act as a vendor, supplier, or service provider for us.
• Sign up for, participate in, or attend our events, programs, promotions, or contests.
• Take part in surveys, research, or similar data collection initiatives conducted by us.
• Visit our offices as a service provider, customer, or guest at an event hosted or co-hosted by us.

Our platform serves as a marketplace connecting independent creators with users and customers, providing tools for content distribution, community engagement, payment processing, and creator monetization. We recognize the trust you place in us with your sensitive personal and financial information, and we take this responsibility seriously.

By using our services, you acknowledge that you have read, understood, and agree to the collection and processing of your personal information as described in this Policy. If you do not agree with these practices, please discontinue use of our platform and services.

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2. INFORMATION WE COLLECT

We collect specific categories of personal information in order to provide our marketplace services, ensure platform security and legal compliance, process payments, and to enhance your user experience ("UX"). The specific information collected depends on how you interact with our platform, where you are from, your real or inferred age, and which services you use.

2.1 Information You Provide Directly

Shobbl operates with a "Regional Compliance" strategy in order to enhance the privacy rights of our users by mitigating international compliance entanglements; we collect only the information necessary for the capacity of service we provide for your Compliance Region.

2.3 Information from Third Parties

We may receive information about you from external sources for the purpose of improving our services as well as platform security.

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3. HOW WE USE YOUR INFORMATION

We process your personal information for specific, legitimate purposes that enable us to improve the security and quality of our services. Our processing activities are based on appropriate legal grounds as required by applicable privacy laws relevant to your Compliance Region.

3.1 Platform Operations and Service Delivery

3.2 Creator Services and Monetization

For Creators using our platform, we process information to provide specialized services including:

• Revenue analytics and performance reporting
• Audience insights and engagement metrics
• Tax document generation and compliance reporting
• Creator verification and credibility assessment
• Content optimization recommendations

3.3 Community Features and Engagement

We use information to facilitate community interactions, including forum management, event coordination, Creator to User connections, and content discovery recommendations. This processing is based on our legitimate interest in providing the best service we possibly can.

3.4 Legal Compliance and Regulatory Requirements

4. INFORMATION SHARING AND DISCLOSURE

We maintain strict controls over how personal information is shared and disclosed. We do not sell personal information to third parties for marketing purposes. Information sharing occurs only in specific circumstances necessary for platform operations, legal compliance, or with your explicit consent.

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4.1 Service Providers and Business Partners

We engage trusted third-party service providers to help deliver our services:

4.2 Legal and Regulatory Disclosures

We may disclose personal information when required by law or to protect legitimate interests:

• To comply with legal process (subpoenas, court orders, search warrants)
• To comply with regulatory investigations or examinations
• To prevent fraud, illegal activity, or violations of our terms of service
• To protect the safety and security of our users and platform
• To process business transfers, acquisitions, or restructuring

4.3 User Interactions

Certain information is shared to enable and enhance user interactions in accordance with applicable privacy settings and regional compliance requirements:

• Published content, interactions, and associated metadata are visible to users as permitted by privacy settings, parental controls, and regional compliance standards.
• Necessary purchase details, such as transaction information, are shared with sellers and creators to support order processing, fulfillment, and dispute resolution.
• Aggregated and anonymized audience analytics may be provided to content owners to help them understand engagement trends and improve their offerings.

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5. INTERNATIONAL DATA TRANSFERS

Our services operate across multiple jurisdictions and may transfer personal information internationally.

5.1 Transfer Mechanisms

To ensure the security and compliance of personal data transferred internationally, we implement the following safeguards:

• Standard Contractual Clauses (SCCs): For transfers from the European Union (EU), European Economic Area (EEA), or other regions requiring specific safeguards, we utilize Standard Contractual Clauses approved by the relevant authorities to ensure data protection compliance.
• Adequacy Decisions: Where applicable, we utilize adequacy determinations issued by relevant authorities to transfer data between jurisdictions recognized as providing an adequate level of data protection.
• Data Processing Agreements (DPAs): We require third-party service providers and partners involved in processing personal data to enter into comprehensive Data Processing Agreements that align with applicable data protection laws, including GDPR and other regional regulations.
• Technical and Organizational Safeguards: We employ adequate measures, such as encryption of data in transit and at rest, secure protocols, and access controls, to protect personal data during transfer and throughout its lifecycle.

5.2 Data Processing Locations

Your information may be processed by relevant authorities based on our legal requirements for your Regional Compliance outcome. Our headquarters is located in the United States, while our primary Data Centers are managed by ??? in ???.

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6. DATA RETENTION

We retain the Personal Data which we have legally obtained to fulfill the purposes for which it was collected, in order to comply with legal obligations, to resolve disputes, and to enforce our agreements.

6.1 Retention Periods by Category

6.2 Data Deletion

When retention periods expire or upon receiving valid deletion requests, we implement secure deletion procedures, including:

• Secure overwriting of data storage media
• Destruction of cryptographic keys for encrypted data
• Coordinated deletion across backup systems and archives
• Verification of complete data removal

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7. SECURITY AND PROTECTION MEASURES

We implement enterprise-grade security measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. Our security program is designed to meet industry standards and regulatory requirements for the regions in which we offer service.

If you wish to report a security violation or inadequacy, please email security@shobbl.com.

7.1 Technical Safeguards

• Encryption: AES-256 encryption for data at rest, TLS 1.3 for data in transit
• Access Controls: Multi-factor authentication, role-based access, principle of least privilege
• Network Security: Firewalls, intrusion detection, DDoS protection
• Data Loss Prevention: Automated monitoring, data classification, egress controls
• Secure Development: Security code reviews, vulnerability testing, secure SDLC

7.2 Security Measures

• Security Training: We conduct regular privacy and security training sessions for all personnel.
• Background Checks: We implement comprehensive screening and vetting processes for employees with data access.
• Incident Response: We maintain a 24/7 security operations center and establish clear incident response procedures.
• Vendor Management: We perform security assessments, enforce contractual obligations, and conduct ongoing monitoring of our third-party services, sellers, and creators.

7.3 Compliance Certifications

We aim to achieve or maintain the following security certifications and compliance standards:

• SOC 2 Type II: Annual audits of security, availability, and confidentiality controls (in progress)
• PCI DSS Level 1: Payment card industry compliance for financial data protection (in progress)
• ISO 27001: Information security management system certification (in progress)
• GDPR Compliance: Adherence to European data protection regulations (in progress)

 

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8. YOUR PRIVACY RIGHTS AND CHOICES

We provide comprehensive tools and mechanisms for users to control their personal information and exercise privacy rights as required by applicable laws.

8.1 Privacy Rights

You have the following rights with regards to your personal information:

You may email any privacy-related request to privacy@shobbl.com where we have (1) month to service your needs in accordance with applicable privacy laws.

8.2 Communication Preferences

You can manage our marketing communications through the following options:

• Email: Use the unsubscribe links in our promotional messages.
• Account Settings: Adjust your communication preferences in your account settings.
• Mobile Applications: Modify push notification settings in our mobile apps.
• Manual Opt-Out: Contact us at privacy@shobbl.com for assistance with manual opt-out.

8.3 Jurisdictional Rights & SCCs

Shobbl offers extensive jurisdictional privacy rights as identified by your Compliance Region and any applicable laws therein, as further specified through our Privacy Addendum for International Data Transfers & Standard Contractual Clauses (SCCs).

We honor similar privacy rights as required by applicable laws in the jurisdictions where we operate.

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9. COOKIES POLICY

Shobbl seeks your informed consent for the use of non-essential cookies and similar technologies, as outlined in our Cookies Notice.

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10. CHILDREN'S PRIVACY

Our platform is not intended for children under 13 years of age. We do not retain any information on individuals under 13 without parental consent, except for inferred age to ensure they do not operate an account or access restricted content.

If we discover that we have collected personal information from a child under 13 without parental consent, we will promptly delete that information from our system and close the associated account.

Children aged 13 to 17 must have their accounts managed by a parent or legal guardian. Certain platform interactions may be restricted for them based on the applicable laws of the region from which they access our platform. We implement additional security measures for children, including parental notification systems, and restrict access to certain platform features such as financial transactions, outbound links, or content inappropriate for their age.

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11. PAYMENT PROCESSING

Shobbl provides non-custodial USDC "Stablecoin" transactions via third-party services. These include OnRamper, the payment processor chosen by OnRamper, Privy, and any credit card payment providers we evaluate as secure and legally compliant for their respective service areas.

How Payments Work

When you make a purchase on Shobbl, you can pay using a credit card or digital currency. Here’s how your payment is processed:

• If you pay with digital currency, your funds are processed through OnRamper and Privy, which securely convert your payment into USDc (a Stablecoin) and then into Shobbl USDc Notes for use on our platform.
• If you pay with a credit card, your payment is processed by our trusted payment partners and converted into Shobbl USDc Notes which are then used for payment.

Payment Flow Diagram:

Purchase (Credit Card or Digital Currency) → OnRamper/Payment Processor → Privy (USDc) → Shobbl (USDc Notes)

How Payouts Work

When you withdraw your earnings as a creator or seller:

• Only Shobbl USDc Notes earned through sale of products, creator pages, or services on our platform may be used for payout.
• Your earned Shobbl USDc Notes are converted back into USDc via Privy.
• If you want to receive traditional currency, USDc is converted through OnRamper and the payment processor they identify to your chosen payout destination.

Payout Flow:

Shobbl (USDc Notes) → Privy (USDc) → OnRamper/Payment Processor → Your Bank or Wallet

Note:

All transactions are tracked and audited for security and compliance. Sellers must complete identity verification (KYC) to withdraw funds.

11.1 Transaction Auditing

Your transactions are monitored and regularly audited by our financial moderation team to prevent fraud and ensure compliance with all applicable Anti-Money Laundering (AML) regulations.

11.2 Seller-Only Know Your Customer (KYC)

Our non-custodial transaction system uses a "closed-loop" virtual currency that represent non-custodial USDc. This virtual currency ("Shobbl USDc Notes") is exempt from buyer-side KYC requirements under FinCEN and EU guidelines. We verify buyers only when necessary to comply with applicable laws and to support our services.

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12. UPDATES TO THIS POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. When we make material changes, we will:

• Provide at least 30 days' advance notice through email or platform notifications
• Update the "Last Updated" date at the top of this policy
• Highlight significant changes in our notification communications
• Obtain renewed consent for certain changes, as required by law

We encourage you to review this Policy regularly to stay informed about how we protect your personal information.

13. CONTACT INFORMATION AND SUPPORT

Shobbl Privacy Team

Email: privacy@shobbl.com

Address: SHOBBL LLC, PRIVACY DEPARTMENT

732 S 6TH ST STE N

LAS VEGAS, NV 89101

United States

Data Protection Officer (EU/UK)

TEMPORARY NAMINGTON

Email: dpo@shobbl.com

Address: WORK & PROGRESS

45 WORKINPROGRESS Street

London, EC1A 1AA

United Kingdom

Privacy Request Portal

Submit privacy requests through our online portal: privacy.shobbl.com

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14. JURISDICTION-SPECIFIC PROVISIONS

We maintain jurisdiction-specific provisions in a supplemental document. For our comprehensive international data transfer and SCCs privacy policy, please refer to our Supplemental Privacy Addendum: International Data Transfers & Standard Contractual Clauses (SCCs).

14.1 European Economic Area and United Kingdom

For users in the UK, Shobbl does not presently offer service nor does it collect information from those residents. If you are found to be from the UK, your account will be closed and we will remove any information about you from our service.

14.2 Other Jurisdictions

Shobbl currently only offers service to the United States of America, the EU (excluding the UK), and Canada. Shobbl plans to expand into other jurisdictions responsibly as part of its global compliance strategy and will update this privacy policy and its Privacy Addendum(s) accordingly. We comply with applicable privacy laws in all jurisdictions where we operate.

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15.0 OUR RIGHT TO CHANGE THIS POLICY

We reserve the right to amend this Privacy Policy as necessary for any reason, including enhancing clarity or ensuring compliance with applicable laws.

This Privacy Policy reflects our commitment to safeguarding your personal information while supporting the global creative economy through our services. We welcome your feedback and questions about our privacy practices. You can reach us at privacy@shobbl.com.

© 2025 Shobbl LLC. All rights reserved. This document is effective as of July 1, 2025.

Privacy Policy Notes

Shobbl LLC Privacy Policy

Introduction

Welcome to Shobbl!

At Shobbl, we believe that privacy is a right. It is our sole wish to provide a private, compliance-first experience

Shobbl Is a Compliance-First Platform

We initially collect the information necessary to verify the state, country, territory, federal district, dependency, protectorate, or special administrative region a visitor is from in order to offer them a legally compliant experience, a process we refer to as "regional compliance."

Shobbl tailors its user and creator experiences to the best possible privacy outcome we are able to provide for the real or inferred age, compliance region, and preferences of its guests, users, and creators. This means that the privacy standards of one are are less likely to degrade the service or measure of privacy we can provide, ensuring a fortified marketplace and platform experience for the legal and appropriately described content we allow on our platform.

Non-Compliant VPNs Disabled . . . for now.

While we recognize that VPN's are a vital part of keeping the internet safe for everyone, Shobbl is sadly unable to offer service to customers utilizing them at this time. Like all privacy flaws, we are actively researching a regionally compliant solution that will protect our users without being forced into non-compliance by users who are illegally accessing regionally restricted content on our website. If this is not enough to satisfy your privacy needs, we hope that we can still one day offer you service as soon as we understand how. We may consider enabling VPN services that at least identify the region a user is from for compliance purposes when accessing Shobbl.

We are privacy advocates.

Shobbl will never sell your data, but it may be revealed to third-parties as necessary for legal compliance, payment processing, age verification, or when compelled to do so by the laws of the country we are operating from. We hold third parties to a high privacy standard and prioritize working with third parties who do the same.

We will not be compelled to reveal information about the citizen of one country by the laws of another unless required for a vital service we trust, and we will cease all operations in that country if compelled to do so except when this is done lawfully by the United States Federal Government or Nevada State Government where our business is based.

We are anti-censorship advocates.

We believe in users setting their own content preferences for legal, age-appropriate content. We use "Stablecoin" to support non-custodial transactions involving legal but controversial subject matter such as politics, conspiracy, art, comedy, or fictionally explicit content without being pressured by third-party payment processors. Our users are empowered to set content preferences that filter out the categories or tags of regionally compliant content they might disagree with.

We believe in parental rights.

Users who are under the age of 18 may only access accounts managed by their legal guardians. Shobbl restricts content and features for minors on our platform, with regionally compliant, age-appropriate content and features for guests, 13+, and 16+ users. We do not currently allow children under the age of 13 on our platform, and we do not keep data on them either.

This Privacy Policy explains how we collect, use, and share your personal information when you interact with our services. By using Shobbl, you agree to the practices outlined below.

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1. Information We Collect

We collect information to provide and improve our services. This includes:

• Information You Provide: Name, email, phone number, payment details, content preferences, and any content you upload.
• Age Verification: All necessary documents for the regional requirements a user is from for the content they are attempting to access.
• Usage Information: Interactions with our platform, including posts, likes, and messages.
• Device Information: IP address, browser type, operating system, and device identifiers.
• Location Information: Approximate location based on your IP address.
• Third-Party Information: Data from linked accounts or external services you connect with Shobbl.
• Product Content: Data found within the content you upload through our service, such as metadata.
• Public Content: Any content you post, share, or interact with on public areas of our platform, such as posts, comments, product pages, creator pages, or profile details.
• Access-Limited Content: Any content you post, share, or interact with on access-limited (meaning "regionally compliant service for age, preferences, and/or verification status") areas of our platform, such as posts, comments, product pages, creator pages, or profile details regionally restricted by user account permissions in our User-Specific, Guest, 13+, 16+, 18+, 21+, and Explicit content categories.
• Inferred Information: We infer the age range, gender, preferred languages, and/or content preferences based on the information we collect about you.

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2. How We Collect Information

Shobbl collects information via IP Address, Forms, Cookies, interactions with the platform, and third-party data processors.

Methods of collection (e.g., forms, cookies, third-party processors like CoinPayments/CCBill).

2. How We Use Your Information

We use your information to:

• Operate and improve our platform.
• Provide personalized experiences and recommendations.
• Process payments and deliver services.
• Ensure safety, security, and compliance with legal obligations.
• Communicate updates, promotions, and support.
• Enhance community engagement by making public content visible to other users and search engines.

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3. Sharing Your Information

We may share your information in the following cases:

• With Service Providers: To support operations like payment processing and hosting.
• With Other Users: Content you post or share in public areas may be visible to others, including your username and related metadata.
• For Legal Reasons: To comply with laws, regulations, or legal requests.
• With Affiliates: To provide seamless services across our business.
• In Business Transfers: During mergers, acquisitions, or asset sales.
• With Third Parties: For integrations, such as social sharing features or API-based services, while adhering to our Public Content Policy.

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4. Public Nature of Content

Shobbl is a public platform. Content you submit to public areas of the platform, such as posts, comments, and profile details, is accessible to anyone, including through search engines or third-party tools. Please consider this before sharing content publicly.

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5. Access-Limited Nature of Content

 

Shobbl is access-limited by region and age platform. Content you submit to access-limited areas of the platform, such as posts, comments, product pages, creator pages, or profile details regionally restricted by user account permissions in our User-Specific, Guest, 13+, 16+, 18+, 21+, and Explicit content categories, is accessible to anyone we identify as being in total mutual compliance with regional-specific laws and standards in terms of verified age, consent, and the national or regional laws we are being accessed from, including through search engines or third-party tools. Some service or content may not be visible to users who are operating under access-limited terms, and some regions may be blocked from accessing our platform entirely. Please consider this before sharing content publicly.

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5. Data Transfers

As an international business, we may transfer your data to countries with different privacy laws. We ensure appropriate safeguards, such as standard contractual clauses, to protect your information.

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6. Cookies and Tracking

We use cookies and similar technologies to enhance your experience. You can manage your cookie preferences in your browser settings. For more details, see our Cookie Policy.

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7. Your Rights

Depending on your location, you may have the right to:

• Access, correct, or delete your personal information.
• Object to or restrict certain data processing activities.
• Withdraw consent where applicable.
• Request data portability.

To exercise your rights, contact us at privacy@shobbl.com.

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8. Data Retention

We retain your information as long as necessary to provide our services or comply with legal obligations. Specific retention periods include:

• Account information: Until account deletion.
• Transaction records: As required by law.
• Cookies: Up to 13 months.
• Public content: Retained indefinitely unless deleted by you.

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9. Security

We implement industry-standard measures to protect your data. However, no system is completely secure, and we cannot guarantee absolute security.

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10. Children

Shobbl is not directed to users under 13. If we learn that we have collected information from a child under 13, we will delete it. Parents can contact us at privacy@shobbl.com for assistance.

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11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated before they take effect. Continued use of Shobbl indicates your acceptance of the updated policy.

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12. Third-Party Links

Our platform may contain links to third-party websites or services. We are not responsible for their privacy practices or content. We encourage you to review their privacy policies before interacting with them.

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13. Do Not Track Signals

Shobbl does not currently respond to "Do Not Track" signals from web browsers. You can manage your tracking preferences through browser settings or third-party tools.

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14. International Users

If you are accessing Shobbl from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where we operate. By using Shobbl, you consent to such transfers.

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15. Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee our privacy practices. You may contact the DPO at privacy@shobbl.com for any privacy-related concerns.

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15. Information Collected by Third Parties

 

We have appointed a Data Protection Officer (DPO) to oversee our privacy practices. You may contact the DPO at privacy@shobbl.com for any privacy-related concerns.

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16. Contact Us

16. Contact Us

For questions or concerns about this Privacy Policy, contact us at:

Shobbl LLC

privacy@shobbl.com

shobbl.com

Payment Processing Notes

Safety & Payment Processor Proposal

WARNING:

THIS DOCUMENT IS AN AI-GENERATED OUTPUT AND CANNOT BE TAKEN AT FACE VALUE, NOR MAY IT BE DISTRIBUTED.

Overview

This document outlines a compliant, user-friendly, and secure payment infrastructure for a creator-focused content marketplace, allowing both SFW and NSFW content, inspired by platforms like Steam, Second Life, and itch.io. The system is designed to avoid excessive friction for buyers while ensuring robust compliance for sellers.

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1. Buyer Onboarding & Payment Flow

Key Principles

• No KYC for buyers
• Age-gating enforced by interface
• Buyers cannot cash out
• Platform credits used (e.g., “USDc”)

Workflow

1. Buyer signs up with email or managed wallet (Privy/MagicLink).
2. Inputs birthdate (age must be ≥ 18 for NSFW).
3. Uses debit/credit card to purchase USDc.
4. USDc / $ can be used to buy games/assets on the platform.
5. USDc cannot be withdrawn or exchanged for fiat (unless you are a KYC seller).

Legal Classification

• Not a money service business (MSB).
• Classified as “closed-loop” digital credits.
• Exempt from buyer-side KYC under FinCEN and EU guidelines.

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2. Seller Onboarding & Payouts

Key Requirements

• Sellers must complete full KYC (ID + proof of address).
• Only approved sellers can earn and withdraw funds.

• Funds can be withdrawn in:

  • USDC (crypto, KYC provider like Circle or Sardine).
  • USD (via Stripe Connect or crypto off-ramp).

Review Workflow

• Manual moderation of all NSFW uploads.
• Flagging system for community reporting.

• Automated scans for CSAM or illegal content using services like:

  • PhotoDNA
  • Hive Moderation
  • Sightengine

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3. Age-Gated Content Handling

Buyer Flow

• Buyers must input birthday upon signup.
• Age stored server-side and encrypted.
• Adult content locked behind age gate.
• Clear UI disclaimers for 18+ sections.

Seller Flow

• Sellers must mark explicit content as NSFW.
• Manual review ensures context (e.g., fantasy, parody, consensual themes).

• Ban list includes:

  • CSAM or anything involving minors (real or simulated).
  • Non-consensual material without strong contextual narrative.
  • Bestiality or illegal content per jurisdiction.

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4. Security & Exploit Prevention

XSS / Injection Mitigation

• Sanitize all user inputs via DOMPurify (frontend) and validator.js (backend).
• Use parameterized queries with Prisma/SQL to avoid SQLi.
• CSP headers via next-secure-headers.
• Validate file uploads (type + size).
• Use signed URLs for storage access (S3, Cloudflare R2).

API Rate Limiting & Abuse Protection

• Implement Upstash rate limiting via Edge Middleware.
• Protect sensitive endpoints with JWT and session validation.
• Bot mitigation with CAPTCHA (Turnstile or hCaptcha).

Payment Gateway Security

• Card data handled by PCI-compliant providers (Stripe, Privy, Magic).
• Never store or log card details directly.
• Webhooks validated with HMAC signatures.

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5. Compliance Notes

• Buyers: Not required to KYC (closed-loop, platform-only credits).
• Sellers: Required to KYC for withdrawals.
• NSFW: Reviewed manually, gated by age, compliant with legal standards.
• AML: Transactions > $1000 flagged internally for review.
• Reporting: Internal tools for auditing suspicious financial behavior.

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6. Summary

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Final Notes

This proposal outlines a scalable, secure, and legally-compliant path forward for building a creator-friendly marketplace that avoids pitfalls faced by Moonpay, Gumroad, and Patreon in the NSFW space while staying within U.S. and international financial laws.

Why a Web3 Proxy Helps

Using a web3 proxy model (abstracted wallet + managed flow) provides:

⚠️ Key Considerations:

• Manual review (as you noted) is essential for risky content.
• Keep clear ToS + disclaimers around user-generated content.
• KYC only for sellers is okay — many platforms (Steam, Roblox) don't KYC buyers, but do verify sellers for payouts.

You may need to implement geo-fencing for certain jurisdictions (e.g., Singapore, UAE).

Gift Card Scams

Project Entropia Dollar Reference

MindArk’s Fraud and Money Laundering Prevention Measures

MindArk, the developer of Entropia Universe, uses the virtual currency Project Entropia Dollars (PED), which has a fixed 10:1 exchange rate with the U.S. dollar and can be exchanged between users and withdrawn as real-world currency. Given the real cash economy (RCE) of Entropia Universe and its potential for fraud and money laundering, MindArk implements several measures to mitigate these risks. Below, I outline how MindArk prevents fraud and money laundering, based on available information, while addressing the specific context of PED transactions and payouts.

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1. Know Your Customer (KYC) and Identity Verification

• Account and Bank Matching: Withdrawals from Entropia Universe must be made to a bank account in the same name as the registered Entropia Universe account holder. If the names do not match, the transfer fails, and funds are returned to MindArk. This ensures that funds are not redirected to unauthorized parties, reducing the risk of fraudulent withdrawals or money laundering through third-party accounts. [1]
• KYC for DeepToken: For their cryptocurrency initiative, DeepToken, MindArk emphasized advanced KYC processes to verify user identities, which expedites transactions and ensures compliance with anti-money laundering (AML) regulations. While DeepToken is separate from PED, this indicates MindArk’s broader commitment to KYC across its financial systems. [2]

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2. Transaction Monitoring and Security Checks

• Manual Verification for Withdrawals: Historically, MindArk manually verified withdrawals to ensure funds were earned legitimately (e.g., not through hacking or exploits). While this process was initially cumbersome, taking months, MindArk introduced an ATM card system in 2006 with a secure system for instant verification and cash authorization, reducing fraud risks. They claim to have systems to detect “abnormal fluctuations” in player transactions, which would flag potential fraud or laundering activities. [3]
• Chargeback Risk Management: MindArk delays withdrawals for approximately 50 business days to account for the risk of chargebacks, as most deposits are made via credit cards, which allow chargebacks up to six months after a transaction. This delay allows time for internal security checks to identify fraudulent deposits or suspicious activity before funds are paid out. [1]
• Transaction History Tracking: Players can monitor withdrawal progress in their Transaction History, with a “Committed” status indicating approval and transfer to the registered bank account. This transparency helps MindArk and users detect discrepancies or unauthorized activities. [1]

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3. Regulatory Compliance and Banking Oversight

• Swedish Banking License: In 2009, MindArk obtained a real-world banking license from the Swedish government, subjecting its financial operations to regulatory oversight. This license provides deposit insurance for PED funds (up to $60,000 per customer) and allows regulators to monitor for money laundering in the virtual economy. [4] [5]
• AML Compliance: MindArk’s operations, particularly for PED withdrawals and DeepToken, align with AML regulations, including filing suspicious activity reports (SARs) as required by the U.S. Financial Crimes Enforcement Network (FinCEN) and similar bodies. Their banking license ensures adherence to Bank Secrecy Act (BSA) requirements, such as maintaining robust AML programs. [6] [2]
• No Intermediary Banks: MindArk prohibits withdrawals to intermediary banks (e.g., credit unions operating via larger banks with different SWIFT codes), reducing the risk of funds being funneled through complex or untraceable channels often used in money laundering. [1]

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4. Secure Transaction Systems

• PED Card System: PED is managed through a “PED Card” system linked to each player’s account, where MindArk administers deposits and withdrawals. This centralized control allows MindArk to monitor and restrict suspicious transactions. [7]
• Blockchain for DeepToken: For their DeepToken cryptocurrency, MindArk uses Ethereum smart contracts to create an immutable record of transactions, enhancing transparency and traceability. While PED itself is not blockchain-based, this indicates MindArk’s adoption of secure, auditable systems for virtual currency transactions. [8]
• Encryption and Technical Safeguards: MindArk employs encryption for transactions (e.g., deposits via Paysafecard or credit cards), ensuring secure data transfer and reducing the risk of interception or fraud. [7]

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5. In-Game Economic Controls

• Fixed Exchange Rate: PED’s fixed 10:1 exchange rate with the U.S. dollar provides stability and predictability, making it harder for bad actors to manipulate currency values for laundering purposes. [9]
• Virtual Item Ownership: All virtual items, including PED, are legally owned by MindArk or its planet partners, not players, per the End User License Agreement (EULA). This allows MindArk to seize or freeze assets if fraudulent activity is detected, limiting the ability to transfer illicit funds through in-game items. [7]
• Withdrawal Limits and Fees: A minimum withdrawal threshold of 1,000 PED ($100) and a 1% withdrawal fee (minimum 100 PED) discourage small, frequent transactions that could be used to obscure laundering activities. [1]

---

6. Collaboration with Authorities

• MindArk works with the Swedish government to ensure compliance with financial regulations and prevent abuses like money laundering. Their CEO, Jan Welter, stated in 2006 that systems were in place to detect and address suspicious activities, with direct communication with regulators. [3]
• Their banking license subjects them to regular audits and oversight, ensuring alignment with international AML/CTF standards set by bodies like the Financial Action Task Force (FATF). [4]

---

Relevance to Your Platform

Your platform, which uses USDC for transactions related to erotic content, can draw lessons from MindArk’s approach:

• KYC and Account Verification: Like MindArk, you should verify user identities and ensure withdrawals go to accounts matching the platform’s registered user to prevent fraud and laundering.
• Transaction Monitoring: Implement delays or automated checks for high-value USDC transactions to detect suspicious patterns, especially given the high-risk nature of adult content.
• Regulatory Compliance: Partner with USDC issuer Circle, which complies with FinCEN and AML regulations, to ensure robust KYC/AML processes. Consider obtaining a Money Services Business (MSB) license if handling significant fiat conversions. [6]
• Decentralized Safeguards: While PED is centralized, your use of USDC (a centralized stablecoin) could be supplemented with decentralized stablecoins (e.g., DAI) or blockchain-based smart contracts to enhance transparency and reduce reliance on single entities. [8]

---

Potential Gaps and Criticisms

• Solvency Concerns: Some sources question MindArk’s solvency, noting that outstanding PED deposits (classified as “contingent debt”) exceed their liquid assets. If many users withdraw PED simultaneously, MindArk might struggle to honor payouts, potentially raising fraud concerns. However, most PED is consumed in-game, reducing this risk. [10]
• Long Withdrawal Times: The 50-business-day withdrawal period has been criticized as excessive, potentially allowing MindArk to delay payouts for suspicious accounts while conducting checks, but it may frustrate legitimate users. [1] [10]
• Limited Transparency: While MindArk claims robust anti-fraud systems, details are sparse, and some critics argue their PR stunts (e.g., high-profile virtual item sales) lack verification, raising skepticism about their financial integrity. [11]

---

Conclusion

MindArk prevents fraud and money laundering in Entropia Universe through strict KYC verification, transaction monitoring, regulatory compliance via a Swedish banking license, secure systems like the PED Card and encryption, and in-game economic controls like fixed exchange rates and asset ownership. Their collaboration with regulators and use of blockchain for DeepToken further strengthen their AML framework. For your platform, adopting similar KYC, monitoring, and compliance measures, tailored to USDC and adult content regulations, will be critical to mitigate fraud and laundering risks. If you need help designing specific anti-fraud measures or a sample DPA for processors handling USDC, let me know!

---

References

1. Entropia Universe Withdrawal FAQ
2. The Fintech Times - DeepToken
3. New York Times - Entropia Universe
4. NBC News - Swedish Banking License
5. Gizmodo - Planet Calypso
6. FBI - Virtual Currency Challenges
7. Entropia Planets Wiki
8. VentureBeat - DeepToken Launch
9. Wikipedia - Entropia Universe
10. MMOS Editorial - Solvency Concerns

Terra Nova Blog - Project Entropia

Jurisdictional Notes

Legal Concerns

Payment Processing

What additional privacy requirements are we subject to with our method of non-custodial payment processing? Are we B2B?

Global Privacy Policy

We at Coinbase (the Coinbase entities listed in Section 11 below, referred to here as “we”, “us” or “our”) respect and protect the privacy of those who explore our Services (“Users”) and Users who sign up for and access our Services (“Customers”) (together referred throughout this policy as “you” and “your”).

This Privacy Policy describes how we collect, use, and share personal information when you explore, sign up for or access our “Services”, which include the services offered on our websites, including coinbase.com, coinbase.com/exchange, coinbase.com/prime, coinbase.com/futures, coinbase.com/cloud (each a “Site” and collectively the "Sites") or when you use the Coinbase mobile app, the Coinbase Card App, Coinbase Exchange, Coinbase Prime, Dapp Wallet, or Coinbase Custody application programming interface (“API”) or third party applications relying on such APIs (together, our “Apps”) and related services. 

### Understanding the Frameworks Used by WeWork and Coinbase

Based on the analysis of WeWork and Coinbase’s privacy policies, their frameworks are rooted in:

1. **Regulatory Compliance**:

- **GDPR (General Data Protection Regulation, EU)**: Requires clear disclosure of data collection, processing purposes, legal bases (e.g., consent, legitimate interest), user rights (e.g., access, deletion), and international data transfers.

- **CCPA/CPRA (California Consumer Privacy Act/Regulations)**: Mandates transparency about personal information collection, categories of data, sharing with third parties, and consumer rights (e.g., opt-out of data sales, deletion requests).

- **Other Laws**: Depending on your operations, you may need to address laws like Canada’s PIPEDA, Brazil’s LGPD, or U.S. state-specific laws (e.g., Virginia’s CDPA).

2. **Standardized Structure**:

- Both companies use a clear, modular structure with sections like:

- **Introduction**: Purpose and scope of the policy.

- **Data Collection**: Types of data collected (e.g., personal, financial, behavioral).

- **Data Use**: Purposes for processing (e.g., service delivery, marketing).

- **Data Sharing**: Details on third-party sharing (e.g., service providers, affiliates).

- **User Rights**: Access, correction, deletion, and opt-out options.

- **Security Measures**: Technical and organizational safeguards (e.g., encryption).

- **Data Transfers**: Handling cross-border data transfers.

- **Contact Information**: How users can reach the data controller.

- **Updates**: How policy changes are communicated.

3. **Industry-Specific Customization**:

- WeWork tailors its policy to workspace services (e.g., CCTV, visitor management), while Coinbase focuses on cryptocurrency and financial compliance (e.g., AML/KYC, blockchain analytics). Your policy should reflect your business’s unique operations.

4. **Use of Legal Templates**:

- Both companies likely use templates or legal consultants to ensure compliance, resulting in standardized language (e.g., “personal information,” “data controller”). These templates are widely available through legal services like OneTrust, Termly, or law firms specializing in privacy.

### Steps to Frame Your Global Privacy Policy

You can create a similar policy by following these steps, using the frameworks observed in WeWork and Coinbase’s policies:

1. **Identify Applicable Regulations**:

- Determine where your business operates or collects data (e.g., EU, U.S., global markets). For example:

- If serving EU users, align with GDPR (e.g., specify lawful bases like consent or contract).

- If serving California residents, include CCPA disclosures (e.g., “Do Not Sell My Personal Information” opt-out).

- Research other jurisdictions (e.g., LGPD for Brazil, PIPEDA for Canada) if applicable.

2. **Define Your Data Practices**:

- **Data Collection**: List what data you collect (e.g., names, emails, payment details, IP addresses). For example, WeWork collects visitor data and CCTV footage, while Coinbase collects blockchain transaction data.

- **Data Use**: Specify purposes (e.g., service delivery, analytics, marketing). Be clear and specific, as required by GDPR and CCPA.

- **Data Sharing**: Identify third parties (e.g., cloud providers, payment processors) and clarify their roles. Both WeWork and Coinbase emphasize that third parties have separate privacy policies.

- **Data Retention**: Define how long you keep data (e.g., Coinbase retains applicant data for 12 months; WeWork retains member data per legal obligations).

3. **Adopt a Modular Structure**:

- Use a clear, section-based format like WeWork and Coinbase. A sample structure:

- **Introduction**: Explain who you are and the policy’s scope (e.g., “This policy applies to Shobbl’s platform for content creators”).

- **Information We Collect**: List data types (e.g., account details, usage data).

- **How We Use Your Information**: Detail purposes (e.g., “To provide subscription services”).

- **Sharing and Disclosure**: Describe third-party sharing (e.g., “We share data with payment processors under contract”).

- **Your Rights**: Outline user rights (e.g., access, deletion, opt-out under GDPR/CCPA).

- **Security**: Mention safeguards (e.g., “We use encryption and access controls”).

- **International Transfers**: Address cross-border data transfers (e.g., “We use EU-approved Standard Contractual Clauses”).

- **Contact Us**: Provide a contact point (e.g., privacy@shobbl.com).

- **Changes to This Policy**: Note how updates are communicated (e.g., via email or website).

4. **Use Standardized Language**:

- Incorporate common legal phrases to ensure compliance, as seen in WeWork and Coinbase’s policies. Examples:

- “We collect personal information to provide and improve our services.”

- “No method of transmission over the Internet is 100% secure.”

- “You may request access, correction, or deletion of your data.”

- Avoid copying their exact wording to prevent potential legal issues, but you can model your language on these standards.

5. **Customize for Your Business**:

- Tailor the policy to Shobbl’s operations (e.g., a marketplace-subscription platform for content creators). For example:

- Mention specific data types (e.g., “content uploads, subscription payment details”).

- Highlight unique features (e.g., “We collect analytics to recommend content to users”).

- Address community interactions (e.g., “We process user comments to moderate our platform”).

- If Shobbl operates globally, include international transfer clauses, as both WeWork and Coinbase do for their global entities.

6. **Leverage Templates or Legal Expertise**:

- Use privacy policy generators like Termly, OneTrust, or FreePrivacyPolicy to create a draft, then customize it. These tools incorporate GDPR/CCPA-compliant language, similar to what WeWork and Coinbase use.

- Alternatively, consult a privacy lawyer to ensure compliance, especially if Shobbl processes sensitive data (e.g., financial or creative assets).

7. **Include Supplemental Notices**:

- Like WeWork (e.g., Guest and Visitor Privacy Notice) and Coinbase (e.g., Applicant Privacy Notice), create additional notices for specific contexts:

- **Applicant Notice**: If Shobbl hires employees, outline recruitment data practices.

- **User Notice**: If Shobbl has distinct user types (e.g., creators vs. subscribers), consider separate notices.

- **State-Specific Notices**: If serving U.S. users, include a CCPA notice or other state-specific disclosures.

8. **Ensure Transparency and Accessibility**:

- Make the policy easy to read, with clear headings and plain language, as seen in both companies’ policies.

- Post it prominently on your website (e.g., in the footer, as WeWork and Coinbase do) and notify users of updates via email or platform announcements.

### Considerations to Avoid Plagiarism

While you can model your policy on WeWork and Coinbase’s frameworks, avoid plagiarism by:

1. **Not Copying Verbatim**:

- Do not reproduce their exact text. Instead, use their structure and adapt the language to Shobbl’s context. For example, instead of copying Coinbase’s “We collect blockchain transaction data,” write “We collect subscription payment data” if that applies to Shobbl.

2. **Customizing to Your Business**:

- Ensure the policy reflects Shobbl’s unique data practices. For instance, highlight how Shobbl handles creator content or community interactions, which differs from WeWork’s workspace focus or Coinbase’s crypto focus.

3. **Using Reputable Sources**:

- Rely on legal templates or consultants rather than copying directly from another company’s policy. Templates from platforms like Termly or Iubenda are designed to be legally sound and customizable.

4. **Attributing Inspiration (if Necessary)**:

- If you draw heavily from a specific framework, consult a lawyer to ensure it’s permissible. However, since privacy policies are functional and driven by law, attribution is rarely needed for standard language.

### Practical Example for Shobbl

Here’s a sample Global Privacy Policy outline for Shobbl, based on WeWork and Coinbase’s frameworks, within 120 characters for a summary (though the full policy would be longer):

**Summary (117 characters)**:

“Shobbl collects creator data to manage subscriptions & communities. We protect your data & respect your rights. #Privacy”

**Full Policy Outline**:

- **Introduction**: “Shobbl is a marketplace-subscription platform for content creators and communities. This policy explains how we handle your data.”

- **Data Collection**: “We collect names, emails, payment details, content uploads, and usage data when you use Shobbl.”

- **Data Use**: “We use your data to provide services, process payments, and improve our platform.”

- **Data Sharing**: “We share data with payment processors and analytics providers under strict contracts.”

- **Your Rights**: “You can access, correct, or delete your data, or opt out of marketing, per GDPR/CCPA.”

- **Security**: “We use encryption and access controls, but no system is 100% secure.”

- **International Transfers**: “Data may be transferred globally using GDPR-compliant safeguards.”

- **Contact**: “Reach us at privacy@shobbl.com.”

- **Updates**: “We’ll notify you of policy changes via email or our website.”

### Additional Tips

- **Review Regularly**: Like WeWork (updated May 2023) and Coinbase (updated March 2024), update your policy to reflect new laws or business changes.

- **Get Legal Advice**: If Shobbl handles sensitive data (e.g., financial or creative assets), consult a privacy lawyer to ensure compliance.

- **Test for Clarity**: Share a draft with a small group to ensure it’s understandable, as LinkedIn audiences value clear communication (per your earlier question).

### Conclusion

You can absolutely frame a Global Privacy Policy for Shobbl using the frameworks employed by WeWork and Coinbase, as they rely on standard legal structures driven by GDPR, CCPA, and industry practices. By identifying applicable regulations, defining your data practices, using a modular structure, and customizing for Shobbl’s context, you can create a compliant and effective policy. Avoid plagiarism by tailoring the language to your business and using legal templates or consultants. If you need a detailed draft or help with specific sections, let me know, and I can assist further!

Introduction

We at Shobbl LLC ("Shobbl," "we," "us," or "our") are embroiled in minding and protecting the privacy
      and personal information of all those who interact with our Services ("Users") and Users who register
an account for and access our Services ("Customers") or further set up a creator page and/or paid product listing ("Creators")
(together referred throughout our policies by the terms “you” and “your”).
      This Privacy Policy details how, what, and why we collect, use, process, share, and protect personal information when you interact with our
      platform, services, and/or community features.

We at Shobbl LLC ("Shobbl," "we," "us," or "our") are embroiled in minding and protecting the privacy
      and personal information of all those who interact with our Services ("Users") and Users who register
an account for and access our Services ("Customers") or further set up a creator page and/or paid product listing ("Creators")
(together referred throughout our policies by the terms “you” and “your”).
      This Privacy Policy details how, what, and why we collect, use, process, share, and protect personal information when you interact with our
      platform, services, and/or community features.

 

Our Privacy Mission

Shobbl is a broad platform delivering a wide range of services internationally. The scope of our data collection must be large, as we must provide compliance and competitive outcomes for our content creators. Our privacy mission is to prioritize the rights of content creators on this platform while advocating for a worldwide internet that is safe for children and adults.

Shobbl Offers Privacy Rights

We Are Privacy Rights Advocates

Privacy rights are for everyone, regardless of the country a user is from. All users are entitled to a copy of their data, account deletion, or clarification on our policies.

Contact Us

Email any requests, questions, concerns, or potential violations of our privacy policy to privacy@shobbl.com

Why Shobbl Collects Data

Our Privacy Mission

Shobbl is a broad platform delivering a wide range of services internationally. The scope of our data collection must be large, as we must provide compliance and competitive outcomes for our content creators. Our privacy mission is to prioritize creators on this platform while balancing an ideology of Parental Rights, Privacy Rights, and Freedom of Speech. This means we're committed to hosting both sides of the argument

Shobbl uses your information to provide its services, such as search processing, regional compliance, or content moderation. We also use this data to further develop and maintain services for our platform, service outage tracking, or for troubleshooting these services.

The information we collect is used to provide an optimal, legally compliant privacy outcome for your age, preferences, and the area you are from.

Your information is used to recommend content Shobbl hosts on our platform, such as products like games, music, podcasts books, comics, and art, as well as creator pages relevant to your interests.

We use the information we collect to customize our services for you, including providing recommendations, personalized content, and customized search results. For example, Security Checkup provides security tips adapted to how you use Google products. And, depending on your available settings, Google Play could use information like apps you’ve already installed and videos you’ve watched on YouTube to suggest new apps you might like.

Depending on your settings, we may also show you personalized ads based on your interests and activity across Google services. For example, if you search for “mountain bikes,” you may see ads for sports equipment on YouTube. You can control what information we use to show you ads by visiting your ad settings in My Ad Center.

How We Use Your Information

Information Shobbl Collects

Shobbl collects the following information in order to facilitate its services and provide the best possible guest, user, or creator experience:

• Terms, tags, products, contests, and creators you search for.
• Videos you watch
• Interactions and views with content, services, and ads.
• Voice and audio information within products on our platform.
• Transaction and purchase activity.
• Individuals whom you share content or communicate with.
• Information about your products and services.
• Information about potential customers from trusted business and advertising partners.
• Information from trusted security partners for protecting against the abuse of our platform.

Public Content You Submit

Information pertaining to usernames, chat messages, posts, comments, files, products, pages, and contests as well as relevant metadata you publicly submit is collected for our services. This also includes any links, text, audio, video, software, or tool.

Access-Restricted Content You Submit

Additionally, Shobbl builds an "access-restricted" information profile for each guest and user based on the compliance region they are visiting us from, their verified or inferred age, content preferences, or relevant metadata. This is used in our compliance-first strategy for the purpose of ensuring all access to the content or services is comported legally for that user, as well as filtering out content an individual user does not wish to see.

Content which a user cannot see but is accessible by others via their own preferences is considered "access-restricted" for that user, but not another who may view that information publicly from another compliance region.

Private Content You Submit

Content that is private refers to the legal content such as publicly inaccessible media, products, pages, and contests hosted on Shobbl by its users or creators for the purpose of private file storage, maintaining a library of products, or staging. We host this content and collect information associated with it for the purpose of presenting it to its owner, forbidding its transfer to access-restricted users, or identifying illegal content.

Children

Parental Rights

Shobbl believes in and advocates for Parental Rights. Anyone under the age of 18 must participate on Shobbl through an account set up by their Parent or Legal Guardian which does not identify who they are beyond a selected age category.

Users under the age of 18 may be restricted from certain 13+ or 16+ content categories depending on the access-restricted information profile we build for making sure they may only access content that is legal and parentally approved for them to do so.

Children's Personal Information

We do not keep any information on persons under the age of 18, other than inferred age for the sole purpose of making sure they do not operate an account or access restricted content. If any user, customer, or creator submits personal information and is suspected as being under the age of 18, we will close his or her account and delete that information off of the account.

Who Shobbl Shares Information With

We Use Non-Custodial Cryptocurrency

Shobbl offers non-custodial USDC "Stablecoin" transactions through the third-party services necessary to do so. These are OnRamper, Privy, and any providers we assess as necessary, secure, regionally compliant, and adequately private for servicing challenging Compliance Regions.

Notifications

Changes to This Privacy Policy

Shobbl is constantly innovating its services. We will post any additions or changes to our Privacy Policy on this page.

United States Privacy Compliance

This section of our Privacy Policy entails information for our guests, users, and creators that is for persons living in the U.S.

Privacy Rights

Residents of certain states may have specific rights with respect to their personal information collected and processed under state privacy laws.

• Right to Know: You have a right to request
• Right to Correct: You have a right to request the correction of inaccurate personal information maintained within our services.
• Right to Delete: You have a right to request that we delete your personal information from our services, exempting certain cases.
• Right to Opt-Out: You have a right to opt out from the sharing or sale of your personal information, including its processing for the process of targeted advertising.
• Right to Non-Discrimination: we will never discriminate against anyone for exercising their rights to privacy.

Global Privacy Policy

Supplemental Privacy Addendum: International Data Transfers & Standard Contractual Clauses (SCCs)

Supplemental Privacy Addendum: International Data Transfers & Standard Contractual Clauses (SCCs)

Effective Date: July 1, 2025

Last Updated: August 6, 2025

This Privacy Addendum (“Addendum”) supplements the Shobbl LLC (“Shobbl”, “we”, “us”, or “our”) Global Privacy Policy. Shobbl LLC transfers personal data internationally, including transfers subject to Standard Contractual Clauses (“SCCs”) or equivalent mechanisms under applicable law.

1. Scope and Purpose

This Addendum applies to all personal data transferred by Shobbl across international borders, including but not limited to the European Economic Area (EEA), United Kingdom, Brazil, Turkey, Kingdom of Saudi Arabia (KSA), LATAM, and Canada, where SCCs or similar legal mechanisms are required.

1.1 Areas of Service

Shobbl provides services exclusively to the following regions: the EU (excluding the UK), the USA, and Canada. We are actively working towards compliance with other jurisdictions. Access to our website from countries outside these specified service areas will be restricted.

2. International Data Transfers

2.1 Transfer Mechanisms

Shobbl implements the following safeguards for international data transfers:

• Standard Contractual Clauses (SCCs): For data transfers from the EEA, UK, and other regions requiring SCCs, Shobbl uses the latest approved SCCs to ensure adequate data protection.
• Adequacy Decisions: Where applicable, Shobbl relies on adequacy decisions by relevant authorities for data transfers.
• Data Processing Agreements (DPAs): All third-party processors and partners are required to sign DPAs aligned with GDPR or other applicable regional laws when importing or exporting our controlled data in reference to residents of the European Union ("EU") or European Economic Area ("EEA").
• Technical and Organizational Safeguards: Measures such as AES-256 encryption, TLS 1.3, access controls, and secure protocols are enforced to protect data during transfer and storage.

2.2 Data Processing Locations

Personal data may be processed in the United States and other jurisdictions as required for service delivery and legal compliance. Data processing locations are selected based on compliance with applicable SCCs and regional requirements.

3. Jurisdiction-Specific SCC Provisions

3.1 European Economic Area (EEA) & United Kingdom

• Transfers are governed by the EU Commission-approved SCCs or UK International Data Transfer Addendum.
• Data subjects have rights under GDPR/UK GDPR, including access, rectification, deletion, restriction, portability, and the right to lodge complaints.

3.2 Brazil

• Data Transfers are governed by the Brazil SCCs under Law No. 13.709/2018 (LGPD).
• Data subjects have rights to access, correct, delete, and object to processing as per LGPD.

3.3 LATAM and Canada

• Data Transfers are governed by LATAM and Canada SCCs, as required by local law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada.
• Data subjects have rights as defined by applicable national data protection laws.

3.4 Turkey

• Data Transfers are governed by Turkey SCCs under Law No. 6698 and related regulations.
• Data subjects have rights to access, correct, and delete personal data.

3.5 Kingdom of Saudi Arabia (KSA)

• Data Transfers are governed by KSA SCCs under the Personal Data Protection Law.
• Data subjects have rights as defined by KSA law.

4. Roles and Responsibilities

Depending on the relationship, Shobbl may act as:

• Data Exporter (Controller or Processor): Shobbl transfers data to a third party (importer) under SCCs.
• Data Importer (Controller or Processor): Shobbl receives data from another entity under SCCs.

The applicable SCC module (Controller-Controller, Controller-Processor, Processor-Processor, Processor-Controller) will be determined by the nature of the relationship.

5. Updates to this Addendum

Shobbl may update this Addendum to reflect changes in laws or our practices. The effective date will be updated accordingly. Continued use of our services constitutes acceptance of the updated Addendum.

Cookies Notice

Effective Date: July 1, 2025

Last Updated: August 5, 2025

The Cookies Notice ("Notice") applies to any cookie or similar technology which you (the "user,") may acquire from us when interacting with Shobbl LLC (“Shobbl”, “we”, “us”, or “our”) services including https://shobbl.com/ and other domains where we serve as the data controller under applicable law.

1. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to enhance platform functionality, analyze usage patterns, and provide personalized experiences.

 

1.1 Types of Cookies We Use

2. HOW TO MANAGE AND/OR DELETE COOKIES

2.1 Cookie Disclaimer

You may interact with our Cookie Disclaimer which allows you to accept all cookies or only non-essential cookies. For users who are logged in to any kind of account on our website, we will once again ask for consent once per year or when we have made significant changes to our cookies in order to keep you informed on our Cookies, Privacy Notices, and Privacy Addendums. Users who are not logged in will only have their choices saved once per session.

2.2 Browser Settings

Your browser settings allow you to manage cookie preferences in various ways. By default, most browsers are set to accept all cookies automatically; however, you may adjust these settings to notify you when cookies are in use or to block them completely. For detailed guidance on managing or disabling cookies, refer to the “Help,” “Tools,” or “Edit” sections within your browser. Additionally, you have the option to remove cookies from your browser by clearing Local Storage at any time through your browsers settings.

2.3 Cookie Settings

You can enable or disable Analytics, Functional, and Targeting cookies at any time by using the 'Cookie Settings' option found in the footer of the Website. Please note that declining these cookies may limit certain features of the Website or restrict access to specific sections.

Terms of Service

ToS Working Document

SHOBBL TERMS OF USE

Last Updated: January 15, 2025

IMPORTANT: THESE TERMS CONTAIN A MANDATORY ARBITRATION AGREEMENT, CLASS ACTION WAIVER, AND JURY TRIAL WAIVER. PLEASE READ SECTIONS 16, 17, AND 18 CAREFULLY.

Table of Contents

• Introduction and Acceptance of Terms
• Definitions
• Account Registration and Eligibility
• License to Content
• Digital Library and Streaming Services
• Shobbl Premium Subscription
• Subscriptions to Content Creators
• Payments, Billing, and Fees
• Taxes
• User Conduct and Prohibited Activities
• Safe Harbor Provisions for Third-Party Content
• Content Moderation and Removal
• Intellectual Property
• Disclaimers of Warranties
• Limitation of Liability
• Arbitration Agreement
• Class Action Waiver
• Jury Trial Waiver
• Governing Law
• Termination
• General Provisions

1. Introduction and Acceptance of Terms

Welcome to Shobbl. These Terms of Use ("Terms") constitute a legal agreement between you ("User," "you," or "your") and Shobbl LLC, a Nevada limited liability company ("Shobbl," "we," "us," or "our"). These Terms govern your use of the Shobbl platform, including our website, mobile applications, APIs, and all related services (collectively, the "Platform").

By creating a Shobbl account, accessing, or using the Platform,

you agree to be bound by:

(a) These Terms of Use

(b) Our Privacy Policy [link]

(c) Our Arbitration Agreement [link] ← IMPORTANT

(d) Our Community Guidelines [link] (if applicable)

(e) All applicable laws and regulations

**The Arbitration Agreement is presented separately and requires

specific acknowledgment. It contains important waivers of legal

rights, including your right to jury trial and class action

participation.**

If you do not agree to all of these terms, you may not access

or use the Platform.

By creating an account, accessing, or using the Platform in any manner, you agree to be bound by these Terms and our Privacy Policy, which is incorporated herein by reference. If you do not agree to these Terms, you may not access or use the Platform.

We may modify these Terms at any time by posting revised Terms on the Platform. Your continued use of the Platform after any such modification constitutes your acceptance of the modified Terms. It is your responsibility to review these Terms periodically.

2. Definitions

For purposes of these Terms:

• "Content" means digital games, videos, music, comics, and other digital materials available on the Platform.
• "Content Creator" or "Creator" means individuals or entities who make Content available through the Platform and offer subscription services.
• "Digital Library" means your personal collection of licensed Content accessible through your Account.
• "License" means the limited, non-exclusive right to access and use Content as specified in these Terms.
• "Subscription" means recurring payment arrangements for ongoing access to Creator content or Platform services.
• "Third-Party Content" means Content provided by parties other than Shobbl.

3. Account Registration and Eligibility

To use the Platform, you must create an Account. You must be at least 18 years of age to register for an Account. By creating an Account, you represent and warrant that you are at least 18 years old and have the legal capacity to enter into these Terms.

You agree to provide accurate, current, and complete information during registration and to maintain and update your Account information. You are responsible for maintaining the confidentiality of your Account credentials and for all activities that occur under your Account.

You may not create an Account if you have been previously suspended or banned from the Platform. Each person may maintain only one Account. Accounts are non-transferable.

4. License to Content

Content is Licensed, Not Sold. All Content on the Platform is licensed to you, not sold. When you purchase or access Content, you receive a limited, non-exclusive, non-transferable, revocable license to access and use that Content according to the license terms specified at the time of purchase. Unless you have purchased a commercial license from a Creator, your license is limited to personal, non-commercial use only.

Your license to Content includes the right to download (where applicable), stream, and view Content through the Platform. You may not copy, distribute, modify, create derivative works of, publicly display, or otherwise exploit Content except as expressly permitted by these Terms or applicable law.

Licenses to Content may be subject to additional terms provided by Content creators or publishers. Your license terminates immediately upon termination of your Account or violation of these Terms.

5. Digital Library and Streaming Services

Your Digital Library provides access to Content you have licensed through the Platform. We provide streaming and download services to deliver Content to your devices. The availability of Content in your Digital Library may change due to licensing agreements, Content removal, or technical issues.

Streaming quality may vary based on your internet connection, device capabilities, and Platform capacity. We do not guarantee uninterrupted access to Content or streaming services.

Downloaded Content may include digital rights management (DRM) technology to prevent unauthorized use. You agree not to circumvent or attempt to circumvent any DRM or other security measures.

6. Shobbl Premium Subscription

6.1 Premium Membership

Shobbl offers a premium subscription service ("Shobbl Premium") that provides enhanced features and benefits to subscribers. Premium benefits may include, but are not limited to: higher quality streaming, offline downloads, early access to new releases, exclusive discounts, ad-free experience, cloud storage for your Digital Library, and other features as specified on the Platform.

6.2 Premium Billing

Shobbl Premium is billed on a recurring basis according to your selected billing cycle (monthly, quarterly, or annually). You authorize us to charge your payment method automatically at the beginning of each billing cycle. Premium subscription fees are non-refundable except as required by applicable law.

6.3 Free Trials

We may offer free trial periods for Shobbl Premium. If you do not cancel before the end of your free trial, your payment method will be charged for the first subscription period. Free trial eligibility may be limited to new subscribers or subject to other restrictions.

6.4 Price Changes

We reserve the right to modify Shobbl Premium pricing with at least thirty (30) days' advance notice. Continued use of Shobbl Premium after a price change constitutes your acceptance of the new price. If you do not agree to a price increase, you may cancel your subscription before the new price takes effect.

6.5 Cancellation

You may cancel your Shobbl Premium subscription at any time through your Account settings. Cancellation will take effect at the end of your current billing period, and you will retain Premium benefits until that time. No refunds will be provided for partial billing periods.

7. Subscriptions to Content Creators

The Platform enables you to subscribe to Content Creators for recurring access to their content and services. Creator subscriptions are separate from Shobbl Premium subscriptions and are subject to the terms set by individual Creators.

Subscription payments are processed automatically according to the billing cycle you select. You may cancel Creator subscriptions at any time through your Account settings, with cancellation taking effect at the end of your current billing period.

Shobbl acts as a payment processor for Creator subscriptions but is not responsible for the quality, availability, or delivery of Creator content or services. Disputes regarding Creator content should be addressed directly with the Creator.

8. Payments, Billing, and Fees

All payments on the Platform are processed in advance and are non-refundable except as required by law or as specified in our refund policy. You authorize us to charge your chosen payment method for all purchases and subscription fees.

Shobbl charges platform fees, payment processing fees, and other applicable fees as disclosed during the purchase process. Fees may change with notice to users.

If your payment method is declined or insufficient, we may suspend your access to paid Content and services until payment is resolved.

9. Taxes

You are responsible for any taxes, duties, or other governmental fees associated with your use of the Platform. Where required by law, we will collect applicable sales tax, VAT, or other taxes on transactions.

Content Creators are responsible for their own tax obligations related to income earned through the Platform. We may issue tax forms as required by law.

10. User Conduct and Prohibited Activities

You agree not to:

• Use the Platform for any illegal purpose or in violation of applicable laws
• Share Account credentials or allow others to access your Account
• Circumvent technical measures that control access to Content
• Upload, distribute, or share Content without proper authorization
• Engage in harassment, abuse, or harmful conduct toward other users
• Interfere with or disrupt the Platform's operation
• Use automated systems to access the Platform without permission
• Attempt to gain unauthorized access to Platform systems or other user accounts

11. Regional Compliance

All parties to any contract or agreement with Shobbl must comply with all applicable federal, state, and international laws and regulations relevant to the regions where services are offered. Contracts must explicitly state this compliance requirement to ensure adherence to legal and regulatory standards.

12. Safe Harbor Provisions for Third-Party Content

Shobbl qualifies for safe harbor protections under Section 230 of the Communications Decency Act and similar laws for Third-Party Content posted by users, Content Creators, and other third parties.

We do not review all Third-Party Content before it appears on the Platform and are not responsible for such content. We may, but are not obligated to, monitor, review, or remove Third-Party Content that violates these Terms or applicable law.

Third-Party Content does not reflect Shobbl's views or opinions. Users access Third-Party Content at their own risk.

13. Content Moderation and Removal

We reserve the right to remove or restrict access to any Content that violates these Terms, infringes intellectual property rights, or is otherwise objectionable in our sole discretion.

Content Creators may report violations through our reporting system. We will investigate reports and take appropriate action, which may include content removal, user warnings, or account suspension.

14. Intellectual Property

The Platform and its original content, features, and functionality are owned by Shobbl and are protected by copyright, trademark, and other intellectual property laws.

You retain ownership of any content you upload to the Platform, but you grant Shobbl a worldwide, royalty-free license to use, reproduce, and distribute such content as necessary to provide Platform services.

We respect intellectual property rights and will respond to valid notices of copyright infringement in accordance with the Digital Millennium Copyright Act (DMCA).

15. Disclaimers of Warranties

THE PLATFORM AND ALL CONTENT ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND. WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

We do not warrant that the Platform will be uninterrupted, error-free, or secure. Your use of the Platform is at your sole risk.

16. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, SHOBBL SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR DATA, ARISING FROM YOUR USE OF THE PLATFORM.

Our total liability to you for all claims related to the Platform shall not exceed the amount you paid to Shobbl in the twelve months preceding the claim.

17. Arbitration Agreement

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS AND GOVERNS HOW DISPUTES BETWEEN YOU AND SHOBBL ARE RESOLVED.

Your use of the Shobbl Platform is subject to a separate

Arbitration Agreement that significantly affects your legal rights,

including your right to file a lawsuit in court and to participate

in class actions.

By accepting these Terms of Use, you acknowledge that you have read,

understood, and agree to be bound by the separate Arbitration Agreement

presented to you during the registration process. The Arbitration Agreement

is incorporated into these Terms of Use by reference and is a binding part

of your agreement with Shobbl.

Key provisions of the Arbitration Agreement include:

- Mandatory binding arbitration for disputes

- Waiver of jury trial rights

- Waiver of class action participation

- 30-day opt-out right

The full Arbitration Agreement is available at [URL] and was presented

to you separately during account creation. If you have questions about

the Arbitration Agreement, please contact legal@shobbl.com before

accepting these Terms.

18. Class Action Waiver

YOU AND SHOBBL AGREE THAT EACH PARTY MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE ACTION.

Neither you nor Shobbl may participate in a class action, class arbitration, or other representative proceeding as a plaintiff, class member, or otherwise, except as specified in applicable law.

19. Jury Trial Waiver

YOU AND SHOBBL HEREBY WAIVE ANY RIGHT TO TRIAL BY JURY IN ANY PROCEEDING ARISING OUT OF OR RELATED TO THESE TERMS OR THE PLATFORM.

This waiver applies to any legal proceeding, whether in arbitration or court, between you and Shobbl.

20. Governing Law

These Terms are governed by the laws of the State of Nevada, without regard to conflict of law principles. Any disputes not subject to arbitration shall be resolved in the courts of Nevada.

21. Termination

You may terminate your Account at any time by contacting us or using Account settings. We may terminate or suspend your Account immediately for violation of these Terms or for any other reason at our discretion.

Upon termination, your right to access the Platform and your Digital Library will cease, though certain provisions of these Terms will survive termination.

22. General Provisions

These Terms constitute the entire agreement between you and Shobbl regarding the Platform. If any provision is found unenforceable, the remaining provisions will remain in effect.

Our failure to enforce any provision does not waive our right to enforce that provision later. You may not assign these Terms without our written consent.

We may provide notices through the Platform, email, or other reasonable means. Electronic delivery of notices is deemed effective when sent.

Contact Information:

Shobbl LLC

Legal Department

Nevada, United States

Email: [email protected]

Arbitration Agreement

Arbitration Agreement

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS AND GOVERNS HOW DISPUTES BETWEEN YOU AND SHOBBL ARE RESOLVED.

Capitalized terms used in this Arbitration Agreement have the meanings assigned to them in the Shobbl Terms of Use, unless otherwise defined below.

1. Agreement to Arbitrate

You and Shobbl agree that any dispute, claim, or controversy arising out of or relating to these Terms, the Platform, or your use of our services (including games, music, books, and video streaming) shall be resolved through binding arbitration on an individual basis rather than in court, except for certain types of disputes specified in Section 8 below.

By accepting these Terms, you agree to waive your right to a jury trial and to participate in class action lawsuits.

2. Specific Acknowledgment of Arbitration Agreement

This arbitration provision is a significant part of these Terms. By clicking "I Agree" or using the Platform, you specifically acknowledge and consent to:

• Resolving disputes through binding arbitration rather than court
• Waiving your right to a jury trial
• Waiving your right to participate in class actions or representative proceedings

Opt-Out Right: You may opt out of this arbitration agreement (see Section 9 below).

3. Mandatory Informal Dispute Resolution

Before filing any arbitration demand or lawsuit, you and Shobbl agree to first attempt to resolve disputes informally for a period of 60 days.

Notice Requirements:

• You must send written notice to: Shobbl Legal Department, [Your Address], with the subject line "Dispute Notice"
• Shobbl will send notice to: The email address associated with your account

• Notice must include:

  • Your name, username, and contact information
  • Detailed description of the dispute and facts supporting your claim
  • Specific relief requested with calculation of damages (if any)

Both parties agree to engage in good faith negotiations during this 60-day period. No arbitration or lawsuit may be filed until this informal process is completed. This requirement applies to each individual claimant and cannot be satisfied on a collective or representative basis.

Tolling: The statute of limitations and any filing fee deadlines will be tolled during the informal resolution period.

4. Arbitration Rules and Provider

If informal resolution is unsuccessful, any arbitration shall be administered by:

• Primary: JAMS (Judicial Arbitration and Mediation Services) under their Streamlined Arbitration Rules & Procedures, or
• Alternative: American Arbitration Association (AAA) under their Consumer Arbitration Rules

If neither JAMS nor AAA is available or willing to arbitrate, the parties will mutually select another arbitration provider. The arbitration shall take place in Clark County, Nevada, or may be conducted remotely via videoconference at the claimant's option.

For disputes involving 25 or more coordinated demands, the provider's Mass Arbitration Supplementary Rules (if any) shall apply.

5. Individual Arbitration Only – Class Action Waiver

YOU AND SHOBBL AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING.

• The arbitrator may not consolidate more than one person's claims
• The arbitrator may not preside over any form of class, consolidated, or representative proceeding
• The arbitrator may award relief (including monetary, injunctive, and declaratory relief) only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party's individual claim

If this class action waiver is found to be unenforceable for any reason, the entire arbitration agreement (except the opt-out provision in Section 9) shall be null and void.

6. Coordinated Filings and Mass Arbitration Protocol

6.1 Definition of Coordinated Filing

"Coordinated Filing" means 25 or more arbitration demands that are filed or submitted by or on behalf of similarly situated individuals against Shobbl and are represented by the same law firm(s), coordinated by the same entities, or involve substantially similar claims arising from the same or similar circumstances.

6.2 Good Faith Meet and Confer

Before filing a Coordinated Filing, the law firm(s) or organization(s) representing the claimants must:

1. Provide written notice to Shobbl of the intent to file coordinated demands
2. Participate in a good faith meet and confer session within 30 days
3. Provide reasonable information about the nature and number of anticipated claims
4. Engage in meaningful discussion about global resolution

6.3 Bellwether Resolution Process (If Coordinated Filing Proceeds)

If informal resolution and the meet and confer process are unsuccessful, and 25 or more coordinated demands are filed, the following process applies:

Stage 1 – Bellwether Cases (Non-Binding Guidance):

• The parties shall work together in good faith to select 10 bellwether cases (5 selected by claimants' counsel, 5 selected by Shobbl)
• These 10 cases will proceed to individual arbitration while other cases are administratively stayed
• Bellwether cases will be arbitrated individually with full procedures including discovery rights
• Bellwether results serve as non-binding guidance only and do not establish binding precedent
• All other claimants remain free to pursue their individual claims with their own facts and arguments
• Bellwether arbitrations shall be completed within 180 days of the last case being filed, unless extended by mutual agreement

Stage 2 – Global Mediation:

• Within 60 days of the completion of all bellwether arbitrations, the parties agree to participate in a full-day global mediation session
• Mediation shall be conducted by a mutually agreed mediator or mediator selected by JAMS/AAA
• Shobbl will pay the mediator's fees
• Each side shall bear its own costs of mediation and attorney's fees

Stage 3 – Individual Arbitration:

• If global mediation does not result in resolution of all claims, the remaining individual cases may proceed to arbitration
• Cases will be processed in the order filed, subject to arbitrator availability
• Each claimant retains the right to individual arbitration with full procedural rights

Stage 4 – Bellwether Refresh:

• After every 50 cases are resolved (whether by arbitration, settlement, or withdrawal), either party may request selection of 3 new bellwether cases to account for changed circumstances
• The process returns to Stage 1 with these new bellwethers

6.4 Procedural Protections in Coordinated Filings

In any Coordinated Filing:

• No claimant is bound by the outcome of another claimant's case
• Each claimant has the right to individual arbitration on their own merits
• Discovery may be coordinated for efficiency but each claimant retains the right to case-specific discovery
• No claimant waives any individual defenses or claims
• Claimants may be removed from the coordinated process at any time upon request

7. Arbitration Fees

7.1 Individual Claims (Fewer than 25 Coordinated Demands)

• For claims seeking less than $10,000: Shobbl will pay all arbitration filing fees, administrative fees, and arbitrator compensation. You are responsible for your own attorney's fees unless you prevail and applicable law allows fee recovery.
• For claims seeking $10,000 or more: Filing fees and arbitrator compensation will be allocated according to the arbitration provider's rules. Shobbl will advance your share of fees if needed, and the arbitrator will determine ultimate fee responsibility in the award.

7.2 Coordinated Filings (25 or More Demands)

• Initial bellwether cases (10 cases): Shobbl will pay all arbitration filing fees, administrative fees, and arbitrator compensation for these cases
• Process administrator fees: If the arbitration provider assesses process administrator fees for managing coordinated filings, Shobbl will pay these fees for the first 100 demands. For demands beyond 100, these fees will be allocated according to the provider's rules.
• Subsequent individual arbitrations: Fees will be allocated as specified in Section 7.1 above

7.3 Fee Recovery

The arbitrator may award reasonable attorney's fees and costs to the prevailing party if authorized by applicable law or if the arbitrator finds that a claim or defense was frivolous or brought for an improper purpose.

8. Exceptions to Arbitration

This arbitration agreement does not apply to:

• Disputes relating to the ownership, validity, enforceability, or infringement of Shobbl's or your intellectual property rights (including patents, copyrights, trademarks, trade secrets, and moral rights)
• Claims seeking temporary restraining orders or preliminary injunctions related to intellectual property or confidential information
• Claims that may be brought in small claims court, provided the claim remains in small claims court and proceeds only on an individual basis
• Claims that by applicable law cannot be subject to binding arbitration

Either party may bring these excepted claims in court.

9. Opt-Out Right

You have the right to opt out of this arbitration agreement. To opt out, you must send written notice within 30 days of first accepting these Terms.

Opt-out notice must:

• Be sent by email to [legal@shobbl.com] AND by mail to [Shobbl Legal Department, Your Address]
• Include your full name, username, email address, and mailing address
• State clearly: "I opt out of the arbitration agreement"
• Be sent from the email address associated with your account

If you validly opt out:

• This arbitration agreement will not apply to you
• You and Shobbl may bring claims in court
• The class action waiver in Section 5 will still apply (you may only bring individual claims, not class actions)

Opting out of this arbitration agreement does not affect any other terms of these Terms of Service.

10. Arbitration Procedures

10.1 Initiating Arbitration

To initiate arbitration, you must file a demand with JAMS or AAA according to their rules and send a copy to Shobbl at [legal address].

10.2 Arbitrator Authority

The arbitrator shall have exclusive authority to resolve all disputes relating to the interpretation, applicability, enforceability, or formation of this arbitration agreement, including any claim that all or part of it is void or voidable, except:

• The court (not the arbitrator) shall decide disputes about the validity of the class action waiver in Section 5
• The court (not the arbitrator) shall decide whether claims fall within the exceptions in Section 8

10.3 Arbitration Hearing and Award

• The arbitrator will conduct a hearing if either party requests one, or if the arbitrator determines a hearing is necessary
• Hearings may be conducted in person in Clark County, Nevada, or via videoconference
• The arbitrator shall issue a written decision with findings of fact and conclusions of law
• The arbitrator may award any relief that would be available in court under applicable law
• The arbitrator's award is final and binding, subject only to limited judicial review under the Federal Arbitration Act

10.4 Confidentiality

Unless otherwise required by law, all arbitration proceedings, documents, and awards shall remain confidential, except:

• As necessary to enforce or challenge an award in court
• If both parties agree to disclosure
• For financial institutions' regulatory reporting requirements
• Where disclosure is required by law or court order

11. Governing Law

This arbitration agreement and any arbitration proceeding shall be governed by the Federal Arbitration Act (9 U.S.C. §§ 1 et seq.) and federal arbitration law. The arbitrator shall apply Nevada substantive law to the merits of any dispute, without reference to Nevada's conflict of laws principles.

12. Severability

If any portion of this arbitration agreement is found to be unenforceable or unlawful for any reason:

1. If the class action waiver (Section 5) is found unenforceable, the entirety of this arbitration agreement (except Section 9 opt-out rights) shall be null and void, and any dispute must be brought in court.
2. If the Coordinated Filings/Mass Arbitration Protocol (Section 6) is found unenforceable, that section shall be severed and disputes shall proceed to individual arbitration under the standard rules of the chosen arbitration provider. The remainder of this arbitration agreement shall remain in full force and effect.
3. For all other provisions found unenforceable, the unenforceable provision shall be severed and the remainder of this arbitration agreement shall remain valid and enforceable.

If this entire arbitration agreement is found unenforceable (except for opt-out rights), you and Shobbl agree that any dispute must be brought in the state or federal courts located in Clark County, Nevada, and both parties consent to the personal jurisdiction and venue of those courts.

13. Changes to This Arbitration Agreement

Notwithstanding any other provision in these Terms, you agree that if Shobbl makes any material change to this arbitration agreement in the future (other than changes to contact addresses or provider names):

1. Shobbl will provide 60 days' advance notice of the change
2. The change will apply only to disputes arising from transactions or events occurring after the effective date of the amendment
3. Any dispute arising from transactions or events occurring before the effective date will be governed by the arbitration agreement in effect at the time of the transaction or event
4. You will have a new 30-day opt-out right from the date the amended arbitration agreement takes effect

14. Survival

This arbitration agreement shall survive the termination of your account and these Terms of Service.

Community Guidelines

Acceptable Use Policy

Content Moderation Policy

Accessibility Policy

Private Policies

• Anti-Money Laundering (AML) Policy
• Know Your Customer (KYC) Policy
• Data Retention and Deletion Policy
• Information Security Policy
• Employee Data Protection Policy
• Vendor Management Policy
• Parental Consent and Verification Policy (COPPA-specific)
• Incident Response and Data Breach Policy

Compliance Policy

Anti-Money Laundering (AML) Policy

Know Your Customer (KYC) Policy

Data Retention and Deletion Policy

Information Security Policy

Employee Data Protection Policy

Vendor Management Policy

Parental Consent and Verification Policy (COPPA-specific)

Incident Response and Data Breach Policy