Arranged Sugar – Privacy Policy

Version 2.0 – 2026

© 2026 Arcadian Labs Ltd – All Rights Reserved

1. Introduction

This Privacy Policy describes how Arcadian Labs Ltd, a company incorporated under the laws of Cyprus (the “Company”, “we”, “us”, or “our”), collects, processes, stores, and protects personal data in connection with your use of the website located at www.arrangedsugar.com and any associated services (the “Platform”).

By accessing or using the Platform, you acknowledge that your personal data will be processed in accordance with this Privacy Policy.

2. Categories of Personal Data

The Company may collect and process the following categories of personal data:

Personal identification information, including but not limited to name, email address, date of birth, gender, and profile preferences provided during registration or profile creation.

Identity verification data, including photographs, selfies, and government-issued identification documents submitted for the purpose of confirming age and authenticity.

Payment-related information, including billing details and transaction records processed through third-party payment providers, including Verotel. The Company does not store full payment card details.

User-generated content, including profile information, images, messages, interactions, and communications exchanged through the Platform.

Technical and usage data, including IP address, device identifiers, browser type, approximate location data, cookies, session logs, and interaction with the Platform.

Safety, compliance, and moderation data, including reports, complaints, investigation records, enforcement actions, and any communications relating to user conduct.

Certain categories of data processed by the Platform may be considered sensitive under applicable data protection laws. Such data is processed only where necessary for the operation of the Platform, user safety, and compliance obligations.

3. Purposes of Processing

Personal data is processed for the following purposes:

To create, manage, and maintain user accounts and profiles.

To verify identity and prevent fraud, abuse, or under-age access. The Company implements identity and age verification measures to ensure that all users are at least 18 years of age.

To process payments, subscriptions, and digital transactions.

To provide, personalise, and improve Platform functionality and user experience.

To monitor, detect, and prevent fraudulent activity, chargeback abuse, or violations of platform policies.

To moderate content and enforce community standards.

To comply with legal obligations, including regulatory, law enforcement, and compliance requirements.

To communicate with users regarding service updates, security notifications, or administrative matters.

4. Legal Basis for Processing

Where applicable under UK GDPR and EU GDPR, personal data is processed on the following legal bases:

Processing is necessary for the performance of a contract with the user.

Processing is necessary to comply with legal obligations.

Processing is based on the Company’s legitimate interests in maintaining platform security, preventing fraud, and improving services.

Processing is based on user consent where required, including for optional features or communications.

5. Data Sharing and Disclosure

The Company may share personal data with third parties where necessary for the operation of the Platform, including:

Payment processors and billing providers, including Verotel for transaction handling, subscription management, fraud prevention, payment dispute resolution, chargeback management, and compliance with payment network requirements.

Identity verification and fraud prevention service providers.

Hosting, infrastructure, and analytics providers.

Professional advisors, auditors, or regulatory authorities where required.

Law enforcement agencies or governmental bodies where disclosure is required by law or necessary to protect users or the Platform.

The Company does not sell personal data to third parties.

6. Monitoring, Safety, and Fraud Prevention

The Company actively monitors user activity, communications and transactions using automated systems and manual review processes for the purposes of detecting fraud, preventing abuse, enforcing platform rules, and maintaining the safety and integrity of the Platform.

Such monitoring may include the analysis of messages, content, behavioural patterns, and transaction activity.

7. Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected, including compliance with legal, regulatory, and operational requirements.

Account data is generally retained for the duration of the user relationship and for a reasonable period thereafter.

Payment records may be retained for up to seven (7) years in accordance with financial and regulatory requirements.

Data relating to suspended or banned accounts may be retained for extended periods for fraud prevention and enforcement purposes.

Identity verification data is retained only for the period necessary to complete verification and is subsequently deleted within a limited timeframe unless required for compliance purposes.

8. Security Measures

The Company implements appropriate technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. Such measures include encryption, access controls, and secure infrastructure.

Notwithstanding the foregoing, no method of transmission or storage is completely secure, and the Company cannot guarantee absolute security.

9. International Data Transfers

Personal data may be transferred to and processed in jurisdictions outside the user’s country of residence, including jurisdictions that may not provide the same level of data protection.

Where such transfers occur, the Company implements appropriate safeguards, including Standard Contractual Clauses or equivalent mechanisms, to ensure that personal data remains protected in accordance with applicable laws.

10. User Rights

Subject to applicable law, users may have the right to access, correct, update, or request deletion of their personal data, as well as the right to restrict or object to certain processing activities.

Requests may be submitted to the contact details provided below.

11. Children’s Data

The Platform is not intended for individuals under the age of 18. The Company actively enforces age verification measures and does not knowingly collect or process personal data relating to minors. Any such data identified will be deleted.

12. Cookies and Tracking Technologies

The Platform uses cookies and similar technologies to maintain secure sessions, improve functionality, analyse usage, and support performance.

Users may control cookie preferences through browser settings or consent mechanisms presented on the Platform.

13. Changes to this Policy

The Company reserves the right to update this Privacy Policy at any time. Continued use of the Platform constitutes acceptance of any revised version.

14. Contact

Arcadian Labs Ltd

1 Kalymnou, 4th Floor

Agios Nikolaos, Kamares

Larnaca, Cyprus

support@arrangedsugar.com

admin@arrangedsugar.com

compliance@arrangedsugar.com