Surf Privacy Notice — Nutty Gear Studio

Nutty Gear Studio Surf Privacy Notice Edition dated 22 September 2026 Surf is a Nutty Gear Studio service. Nutty Gear Studio is the studio name used by the Operator identified below, not a separate legal entity. Full details appear in “Operator details” in this document. The data shared for external AI processing is clarified. Handles, names, “about” details, avatars and comments are not reviewed before publication: such material is published immediately and moderation follows reports and Operator decisions. 1. Who processes data The person identified in “Operator details” is the controller for Surf users habitually resident in the Russian Federation. Contact: support@nuttygearstudio.com. Interface language does not determine the controller. This notice describes data processing in Surf. Required consents are obtained separately. 2. Data we receive You provide your handle, profile name, biography, avatar, login information, birth date, country of residence, language and content access settings. Password login uses a protected password hash rather than a plain-text password. Your birth date and selected country are not published in your profile. We receive uploaded video and audio, author notes, comments, reactions, support requests, complaints and supporting evidence. Material may contain images, voices and other information about you or third parties. Do not send documents or sensitive information unnecessary for a particular request. Service operation generates information about queries and stream sessions, impressions, viewing, skips and reactions, and derived interests for content selection. Technical account and session identifiers, action times, client information, security and error records are also processed. Network components receive an IP address to establish the connection; session handling uses a shortened address prefix. Document acceptance records include the edition, language, fingerprint of the displayed text, time and account association. Rightsholder cases contain contacts, descriptions of rights and material, signatures, declarations and review history. Names and contacts needed to document a separate consent are stored privately with its receipt and are not added to the public profile. 3. Purposes and legal bases Accounts, authentication, storage of material you choose to provide, publication and delivery of the requested stream support performance of the contract to the extent necessary. Service protection, abuse prevention, error investigation and defence of rights rely on legitimate interests where available under applicable law, following an assessment of necessity and proportionality. Mandatory legal requirements provide a separate basis for the relevant operations. Age information supports eligibility and content access controls; country information determines the operator and applicable requirements. For consent-based operations, the purpose and withdrawal procedure are specified. Consent to dissemination of personal data is obtained separately. 4. Who can see data Videos, comments and public profile elements you publish are accessible to other users under service rules. Consider that third parties may copy published material. Internal account data, birth dates and private complaints are not intended for public display. Authorised administrators, technical providers supporting infrastructure and analysis, and recipients to whom disclosure is required or permitted by law may receive necessary access. In a dispute, necessary information may be disclosed to participants on a lawful basis. Sharing between Surf operators requires its own legal basis. 5. Storage and processing outside your country Surf's primary servers and storage are in Russia. External AI processing uses the DeepSeek API, recipient Hangzhou DeepSeek Artificial Intelligence Co., Ltd. (China). Following separate permission, necessary publication text, author notes and video presentation, recognised speech and text, and machine-generated descriptions of frames and covers are shared for publication presentation review, analysis, translation, description, search features and age-rating recommendations. These calls do not attach passwords, sign-in tokens, Apple/Google email, birth date, full viewing history or original media files; personal information may occur in the material itself. Ordinary viewer stream queries are handled by search within Surf's infrastructure and are not sent to DeepSeek. Viewing is available without external AI permission. Withdrawal stops new calls on this basis and application of results from unfinished calls; corresponding tasks wait for permission. A request already sent cannot be recalled from the recipient. Withdrawal alone does not delete the account or published content. The recipient is outside Russia and Georgia. Mandatory international transfer requirements apply independently of the user's separate choice. Contact support about the recipient, processing of previously shared data and applicable safeguards. Surf does not guarantee no retention by the external recipient or immediate deletion of all previously shared copies. 6. Automated selection and restrictions Surf uses the requested topic, video features and interaction history to generate a personalised stream. Account age limits, a voluntarily selected lower rating and moderation decisions also apply. Automated analysis can be wrong; disputed assessments or restrictions may be submitted for review through support or an available complaint form. 7. Retention Account information and service-related material are processed for the time necessary for the stated purposes, taking account of deletion, discontinued use, disputes and legal duties. Operational stream item records have a 90-day cleanup threshold; last-view records, 180 days; technical event batches and completed jobs, 7 days; API accounting records, 90 days. These are scheduled job thresholds, not a promise of immediate erasure of all related information. Events older than 60 days move from the operational database into a restricted archive; this is not erasure. Event archives are erased after 180 days from the event date. Interest profiles are cleared after 60 days without relevant signals. Application logs are kept for 14 days. Consent history and closed age-correction cases are kept for 90 days; the current consent receipt remains until withdrawal or account deletion. Closed rightsholder cases are cleared after 30 days, and unresolved cases after 365 days unless a documented dispute basis requires a limited extension with a specific deadline and reason. Erasure receipts without names or contact details are kept for 90 days. Moderation decision history has a 90-day cleanup threshold; unused avatar versions have a seven-day threshold. These thresholds do not delete a version still used in the public profile. Account or publication erasure also covers private moderation content. 8. Cookies and device storage The web service uses session cookies for login; the app uses a session token. Settings and interface caches may be stored on your device. These mechanisms support service operation. Clearing browser data or signing out may require another login. Optional advertising tracking is not a purpose of these mechanisms. 9. Your requests Contact support@nuttygearstudio.com to request processing information, access, correction, erasure, restriction or portability, or to object where provided by applicable law. Consent-based processing can be withdrawn; this does not invalidate prior lawful processing or remove independent legal grounds for continued retention. We may request proportionate identity verification to avoid disclosing data to another person. Restrictions or refusal must have an applicable lawful basis. You may contact a competent supervisory authority or court. Deletion is available in Data and consents, including before account setup is complete. Account deletion requires renewed sign-in confirmation; withdrawing publication consent does not require deleting the account. Confirmed account deletion closes access immediately and runs cleanup in the background. Legacy caches without video ownership links expire within seven days. Erasure from the operational system does not mean immediate erasure of restricted backup copies. Such copies are not intended for ongoing use; restoration must not resume processing of erased data without a lawful basis. Minimal administrative erasure records containing identifiers but no name or contact details are kept for 30 days. Necessary information for an ongoing dispute may be retained separately on a lawful basis without public access. Requests are handled within applicable statutory periods. 10. Age, security and updates Registration is intended for users aged 16 and over, subject to mandatory regional requirements. Users must provide an accurate date of birth. If inaccurate information is identified, Surf may restrict access and request proportionate age verification. If a child’s account uses an incorrect birth date or a representative’s involvement is required, contact support for review and necessary action. Access restrictions, protected connections and account and infrastructure security measures are used to protect data. Absolute security is not guaranteed. Material processing changes are communicated before application; separate consent is requested where legally necessary. Operator details Individual Entrepreneur Aleksandr Ilichev, Russian taxpayer number 361604949294, state registration number 320366800065326. The Operator operates under the studio name Nutty Gear Studio. This is the data controller under this document. Contact: support@nuttygearstudio.com.