Marketing Policy

SGSuperFans Inc. (“SGSuperFans,” “we,” “us,” or “our”) publishes this Marketing Policy (“Policy”) to establish clear, legally compliant, and ethically sound standards for all marketing and promotional activities conducted on or in connection with the SGSuperFans platform. This Policy reflects our commitment to honest, transparent, and respectful marketing across all channels, and our responsibility to protect Creators, Fans, and the general public from misleading, deceptive, or unwanted commercial communications.

What This Policy Covers

This Policy applies to the full spectrum of marketing and promotional activities associated with SGSuperFans, including without limitation:

• Email marketing, transactional messaging, and commercial electronic messages distributed by or on behalf of SGSuperFans or any Creator using platform messaging tools.
• SMS, push notification, and in-app marketing communications.
• Creator promotional activities including self-promotion, cross-promotion with other Creators, and promotion of subscription tiers, pay-per-view content, live events, virtual gifts, merchandise, and tips.
• Affiliate programs, referral programs, commission-based marketing arrangements, and any paid promotional partnerships.
• Sponsored posts, branded content, endorsements, testimonials, and influencer marketing campaigns.
• Advertising placed by SGSuperFans or by Creators on third-party platforms including Google, Meta, X (formerly Twitter), TikTok, Snapchat, Reddit, and programmatic display networks.
• Contests, sweepstakes, giveaways, promotions, and any offer with a prize or reward element.
• Data-driven personalization, behavioral targeting, retargeting, and audience segmentation used in connection with marketing activities.
• AI-generated, algorithmically produced, or automated marketing content created in whole or in part using artificial intelligence tools.
• Marketing automation workflows, lead generation campaigns, and CRM-driven promotional sequences.
• SGSuperFans’s own brand marketing, corporate communications with commercial intent, investor relations communications carrying a promotional element, and platform-wide promotional campaigns.

Relationship to Other Policies

This Policy supplements and must be read together with the Terms of Service and the Content Creator Agreement. In the event of any conflict, the Terms of Service shall prevail. For marketing activities that involve the collection or use of personal data, the Privacy Policy and Cookie Policy contain additional binding requirements that apply concurrently with this Policy.

The effective date of this Policy is January 1, 2026. All marketing activities conducted on or after this date must comply with this version. Prior iterations of our marketing guidelines are superseded in their entirety.

This Policy is binding on all of the following persons and entities:

SGSuperFans and Its Authorized Agents

All marketing activity undertaken by SGSuperFans Inc. directly, through its employees, contractors, marketing agencies, advertising partners, or technology vendors acting on our behalf must comply with this Policy. We are accountable for the compliance of our authorized agents to the same extent as our own compliance.

Creators

Every registered Creator account holder is bound by this Policy in respect of all marketing and promotional activities conducted:

• Through SGSuperFans’s platform tools including broadcast messages, fan messaging, promotional banners, welcome messages, automated DMs, and subscription discount campaigns.
• On external platforms (social media, personal websites, email lists, podcasts, YouTube channels) where the primary purpose of the communication is to drive traffic to a Creator’s SGSuperFans profile or to promote SGSuperFans-based content or services.
• Through the SGSuperFans affiliate or referral program.
• In any paid advertising campaign that references SGSuperFans, a Creator’s SGSuperFans profile, or any product or service sold through SGSuperFans.

Fans

Fan account holders are bound by this Policy when they:

• Participate in the SGSuperFans referral program and generate promotional communications to recruit new users.
• Publicly promote or endorse Creators, content, or services available on SGSuperFans in exchange for any material benefit, whether monetary or otherwise.
• Organize or participate in affiliate marketing arrangements that direct third parties to the platform.

Managers and Agencies

Any Manager account holder, talent management agency, marketing agency, or third-party service provider that manages marketing activities on behalf of Creators through the platform or externally is directly bound by this Policy. Managers are responsible for ensuring that all marketing conducted on behalf of their managed Creator accounts complies fully with this Policy. A breach by a Manager may result in enforcement action against both the Manager account and the underlying Creator accounts they manage.

Business Partners

Any business entity that is party to a formal partnership, co-marketing, co-branding, or integration agreement with SGSuperFans is bound by the marketing standards in this Policy as well as any additional marketing standards specified in their agreement. If a partner’s agreement contains more stringent marketing requirements, those more stringent requirements apply.

The following categories of marketing and promotional activity are expressly permitted on the SGSuperFans platform, subject to compliance with all other sections of this Policy and all applicable laws.

Creator Self-Promotion

Creators may promote their own profiles, content, subscription tiers, and platform services using the following channels and methods:

• Free Preview Content: Publishing unlocked preview posts, clips, or teasers designed to attract new subscribers, provided such previews comply with the platform’s content guidelines.
• Subscription Discounts & Promotions: Offering limited-time discounted subscriptions using the platform’s built-in promotional tools, provided all discount terms are accurately disclosed.
• Bundle Offers: Bundling subscription access with live event tickets, shoutouts, merchandise, or other paid services at a combined promotional price.
• Fan Loyalty Programs: Rewarding long-term or high-spending fans with exclusive content, early access, or personalized interactions, provided loyalty benefits are described accurately.
• Cross-Promotion: Collaborating with and cross-promoting other Creators on the platform, provided the promotional content is accurate and does not mislead fans about the nature of the collaboration.
• External Social Media Promotion: Promoting a Creator’s SGSuperFans profile on external social media platforms, personal websites, YouTube, podcasts, and similar channels, subject to those platforms’ own terms and this Policy’s disclosure requirements.
• Live Event Promotion: Promoting scheduled live streams, virtual events, ticketed shows, and similar experiences available on the platform, provided event details are accurate and all pricing is clearly disclosed.

SGSuperFans Platform-Wide Promotions

SGSuperFans may from time to time run platform-wide promotional campaigns including seasonal discounts, new user offers, referral bonuses, highlighted Creator features, and promotional events. The terms and conditions of each such promotion will be published at the time of the promotion and will supersede any general provisions in this Policy to the extent of any inconsistency.

General Standards for All Permitted Marketing

All permitted marketing activities must at all times:

• Be truthful, accurate, and not misleading in any material respect.
• Include all material disclosures required by applicable law and this Policy.
• Not target or be designed to reach persons under the age of 18.
• Respect recipients’ privacy rights and comply with applicable consent requirements before sending commercial electronic messages.
• Be clearly identifiable as commercial or promotional in nature and not disguised as organic, editorial, or independent content unless properly disclosed.

Email marketing conducted by SGSuperFans or by Creators using platform tools is subject to some of the strictest anti-spam laws in the world. Canada’s Anti-Spam Legislation (“CASL” S.C. 2010, c. 23) is our primary compliance framework, supplemented by the U.S. CAN-SPAM Act where applicable.

CASL Consent Requirements

Before sending any Commercial Electronic Message (“CEM”) to any electronic address, the sender must have obtained one of the following forms of consent:

Mandatory Message Contents (CASL s.6)

Every CEM sent by or through the platform must contain:

1. 1Clear identification of the sender, including the legal name and, for Creators, their SGSuperFans display name.
2. 2A mailing address that enables the recipient to contact the sender. This may be a physical postal address, PO box, or a valid electronic address combined with a web form.
3. 3A functioning and clearly labeled unsubscribe mechanism that enables the recipient to unsubscribe from all future CEMs from that sender at no cost.
4. 4Unsubscribe requests must be honored within 10 business days of receipt. Sending any further CEMs after an unsubscribe request has been received (but before the 10-business-day deadline has passed) is prohibited unless the recipient re-opts in.

CAN-SPAM Compliance (U.S. Recipients)

When sending emails to recipients in the United States, additional CAN-SPAM requirements apply alongside CASL, including:

• The “From,” “To,” “Reply-to,” and routing information must accurately identify the sender.
• Subject lines must not be deceptive and must accurately reflect the content of the message.
• The message must be clearly and conspicuously identified as an advertisement unless express consent was obtained.
• A valid physical postal address of the sender must be included.
• Opt-out requests must be honored within 10 business days. No opt-out fee may be charged and no unnecessary personal information may be required to process an opt-out.

Prohibited Email Practices

• Purchased or harvested email lists: Using any email list that was purchased, rented, scraped, or otherwise obtained without the direct express consent of each recipient for your specific class of messages is prohibited.
• Deceptive headers or subject lines: Using misleading subject lines, false sender identities, or headers designed to obscure the commercial nature of the message.
• Pre-checked opt-in boxes: Obtaining consent through a pre-ticked checkbox or any other method that does not require an affirmative action by the recipient.
• Bundled consent: Bundling consent to receive marketing emails as a condition of receiving a service, accessing content, or completing a transaction, where the person has no practical ability to decline the marketing.
• Identity obfuscation: Sending marketing emails through third-party relay services, compromised accounts, or any method designed to hide the true sender.

Transactional vs. Commercial Messages

Transactional messages (purchase receipts, booking confirmations, password resets, account security alerts, and similar service messages) are not subject to CASL’s consent requirements. However, any commercial or promotional content embedded within a transactional message must be clearly separated and secondary to the transactional content. A transactional message that is primarily commercial in nature loses its transactional classification and becomes a CEM subject to full CASL compliance.

SMS (text message) marketing and mobile push notifications are highly personal and intrusive communication channels. SGSuperFans applies strict standards to their use that exceed the minimum requirements of applicable law.

SMS Marketing Requirements

CASL’s consent, identification, and unsubscribe requirements apply in full to SMS messages with commercial content. In addition, the following standards apply:

• Prior Express Written Consent: SMS marketing requires express written consent obtained through a separate opt-in mechanism specifically identifying that the person will receive text messages. Consent to receive email marketing does not constitute consent to receive SMS marketing.
• Clear Identification: Every SMS must identify the sender by name at the start of the message. The platform name or Creator name must be clearly stated.
• Opt-Out Instructions: Every SMS must include a simple keyword-based opt-out instruction (for example, “Reply STOP to unsubscribe”). Upon receipt of STOP or any reasonable opt-out request, no further SMS messages may be sent to that number except a single confirmation of the opt-out.
• Message Frequency: The frequency of promotional SMS messages must be disclosed at the point of consent. If a Creator commits to sending “up to 4 messages per month,” that commitment is binding.
• Carrier Compliance: All SMS campaigns must comply with wireless carrier guidelines and CTIA (Cellular Telecommunications Industry Association) standards, including restrictions on times of sending and message content.
• SMS Time Restrictions: No marketing SMS may be sent before 8:00 a.m. or after 9:00 p.m. local time of the recipient. Respecting time zones is the sender’s responsibility.

Push Notification Marketing

Mobile push notifications sent through the SGSuperFans app are subject to the following requirements:

• Users must have explicitly granted push notification permissions in their device operating system settings. We do not manipulate operating system permission prompts to extract consent through misleading UI patterns.
• Push notifications containing promotional content (new content alerts, subscription discount offers, live event reminders) must be clearly distinguishable from transactional or service notifications in their content and framing.
• Users who revoke push notification permissions at the operating system level must have those preferences honored immediately. Attempting to re-prompt for permissions in an intrusive or coercive manner is prohibited.
• Marketing push notifications may not be sent more frequently than is reasonably necessary to deliver the promotional communication. Flooding a user’s notification tray constitutes a violation of this Policy.

Social media platforms are the primary external marketing channel used by Creators on SGSuperFans. Marketing conducted on social media remains subject to this Policy when its purpose is to promote a Creator’s presence, content, or services on SGSuperFans.

Platform-Specific Terms

Creators are responsible for complying with the terms of service of each social media platform they use for marketing. Where a social media platform’s terms impose restrictions on adult content promotion, Creators must respect those restrictions. SGSuperFans is not liable for the consequences of a Creator’s violation of third-party platform terms when promoting their SGSuperFans content.

Adult Content Promotion on Social Media

Many mainstream social media platforms prohibit the promotion of explicit adult content in advertising or require it to be age-gated. The following standards apply:

• Creators must not post, share, or advertise explicit sexual content on social media platforms that prohibit it, regardless of whether the content is behind a paywall on SGSuperFans.
• Thumbnails, preview images, and teaser clips used in social media promotion must comply with both the applicable platform’s content guidelines and applicable law regarding the advertising of adult content.
• Creators must use platform-provided age-restriction tools (such as YouTube’s age-restriction feature, Facebook’s sensitive content settings, or X’s sensitive media settings) where such tools are available and appropriate.
• Misleading or bait-and-switch social media previews that imply freely available content when that content is actually behind a paywall are prohibited as deceptive advertising under Canada’s Competition Act and this Policy.

Authentic Engagement Standards

• Creators may not purchase, rent, or use any service that delivers fake followers, inflated view counts, artificial likes, or manufactured engagement on any social media platform used to promote their SGSuperFans presence.
• Evidence that a Creator’s social media metrics were obtained through artificial inflation may result in removal from promotional programs and account review.
• Creators must not operate fake, duplicate, or impersonation social media accounts for promotional purposes.

Hashtag and SEO Marketing

Using relevant hashtags, SEO-friendly descriptions, and organic discovery methods to promote a Creator’s SGSuperFans profile is permitted. The following are prohibited:

• Using hashtags that are irrelevant to the content in order to artificially expand reach (hashtag stuffing).
• Misappropriating trending hashtags related to breaking news, tragedy, or political events for promotional purposes.
• Using SGSuperFans’s own trademarked hashtags in external promotional content without our prior written approval.

All advertising, whether placed by SGSuperFans or by Creators on third-party advertising platforms, must meet the highest standards of truthfulness and accuracy required by Canadian and international advertising law. This Section is informed primarily by Canada’s Competition Act (ss. 74.01-74.06 on deceptive marketing practices), Advertising Standards Canada’s Canadian Code of Advertising Standards, and Ontario’s Consumer Protection Act.

The Truthfulness Obligation

All advertising claims must be:

• Accurate: Claims must reflect verifiable truth. Performance claims, income claims, subscriber count claims, and audience size claims must be supportable by data.
• Not misleading by omission: Advertising must not omit material information that, if known to a reasonable consumer, would likely affect their decision to transact. Presenting a “best-case scenario” Creator earnings without any disclosure of typical or average outcomes is misleading by omission.
• Substantiated before publication: Before making any performance claim, earnings claim, subscriber growth claim, or comparative claim in advertising, the person making the claim must hold adequate and proper substantiation for that claim.

Earnings and Income Claims

This subcategory carries significant legal risk and is addressed separately:

Specifically, the following are prohibited:

• Advertising or prominently promoting exceptional Creator earnings (e.g., “Creator X earns $50,000/month on SGSuperFans”) without a clear disclaimer that this represents exceptional results and is not typical.
• Making any guarantee of income, subscriber growth, or engagement outcomes for Creators who join the platform.
• Using forward-looking financial projections in advertising that are not grounded in current, verifiable data.
• Implying that anyone who joins SGSuperFans as a Creator can achieve a specific level of financial success through effort alone, without disclosing the many factors outside a Creator’s control that influence earnings.

Comparative Advertising

Advertisements that compare SGSuperFans to competing platforms must:

• Be based on accurate, current, independently verifiable comparisons.
• Not disparage a competitor through false statements. Fair, factually accurate comparative claims are permitted under Canadian law.
• Not imply an endorsement or affiliation with a competitor that does not exist.
• Be reviewed by SGSuperFans’s legal team before publication when placed by SGSuperFans directly.

Price Advertising

• Advertised prices must include all mandatory fees and charges, or must clearly disclose that additional fees apply.
• “Sale” and “discount” pricing claims must reflect a genuine reduction from a regular, established price. Canada’s Competition Act (s.74.01(3)) prohibits fictitious ordinary pricing used to inflate the apparent magnitude of a discount.
• Subscription price changes must be disclosed to existing subscribers in advance with adequate notice, consistent with the Terms of Service.

When a Creator, Fan, or any other person promotes SGSuperFans or a Creator’s content in exchange for any material benefit (financial compensation, free subscriptions, gifts, early access, or any other benefit), this constitutes an endorsement that must be disclosed. Endorsement disclosure requirements are among the most actively enforced areas of advertising law globally.

FTC Endorsement Guides (United States)

The U.S. Federal Trade Commission’s Guides Concerning Endorsements and Testimonials (16 C.F.R. Part 255, as updated in 2023) apply when content promoting SGSuperFans is directed at U.S. audiences. Key requirements under the updated 2023 Guides include:

• Clear and Conspicuous Disclosure: Any material connection between an endorser and the brand (including payment, free product/services, employment, organizational affiliation, or family/personal relationships) must be disclosed clearly and conspicuously in every endorsement.
• Placement of Disclosure: Disclosures must appear before any affiliate link or the bulk of the promotional content. They must not be buried in the middle of a long caption, hidden below “more” folds, or placed only in metadata. On video content, disclosures must appear verbally and in text overlay, not only in the video description.
• Social Media-Specific Rules: On social media, disclosures must appear in the first line of the caption or at the very beginning of a post, using plain language such as “Ad,” “Paid partnership,” “Sponsored,” or “Gifted.” Hashtags such as “#ad” and “#sponsored” remain acceptable if placed prominently.
• Truthfulness of the Endorsement: Endorsers must genuinely hold the views they publicly express about a product or service. Endorsing content you do not use or believe in is deceptive under FTC Guides regardless of whether the endorsement was paid.
• Liability for Endorsers: The 2023 updated Guides allow the FTC to seek civil penalties directly from endorsers (influencers) who violate disclosure requirements, not only from the brand. Creators are personally exposed to FTC enforcement risk.

Canadian Advertising Standards Requirements

Advertising Standards Canada’s Code requires that advertising be identifiable as advertising. In Canada, any social media post, review, testimonial, or recommendation that is paid for, gifted, or otherwise incentivized must be clearly identified as such. The Competition Act’s provisions on deceptive marketing practices (s.74.01) independently prohibit paid endorsements that masquerade as organic opinions.

Testimonials and User Reviews

• Any testimonial or review used in SGSuperFans’s or a Creator’s marketing materials must reflect the genuine experience of a real user who held the views expressed at the time the testimonial was obtained.
• Fabricated reviews, composite testimonials, or reviews posted by employees or contractors without disclosure are prohibited.
• Incentivized reviews (reviews offered in exchange for a discount, gift, or other benefit) must be disclosed as such regardless of whether the review is positive.
• SGSuperFans prohibits the use of fake, constructed, or manipulated user reviews in any marketing content published on or referencing the platform.

SGSuperFans operates an affiliate and referral program that allows Creators and Fans to earn commissions by recruiting new users or promoting the platform. All participants in the affiliate and referral program are bound by the requirements in this Section in addition to the separrate Affiliate Program Terms.

Mandatory Affiliate Disclosure

Every affiliate and referral link must be accompanied by a clear and prominent disclosure. The disclosure must:

• Appear before any affiliate link or before the promotional content that contains the link, not after it.
• Use plain, unambiguous language that a non-specialist reader would understand to mean that the poster earns money if someone clicks the link and signs up or makes a purchase.
• Not be formatted in a way that makes it inconspicuous, for example: tiny font, low-contrast text, collapsed menus, or placement on a different page from the link.

Acceptable qualifying disclosure language includes:

Prohibited Affiliate Practices

• Presenting affiliate links as unpaid personal recommendations when compensation or an incentive is involved.
• Self-referrals: using your own referral code to sign up for a new account to collect referral bonuses, or encouraging family members or associates to do so on a coordinated basis.
• Cookie stuffing, typosquatting, URL hijacking, or any other technique designed to fraudulently attribute affiliate commissions.
• Making false or exaggerated claims about SGSuperFans’s services, pricing, Creator earnings potential, or features in affiliate marketing content.
• Placing affiliate links in spam email, SMS spam, or any communication sent without appropriate consent.
• Using fake or fictional testimonials in affiliate marketing content.
• Creating websites, social media profiles, or content that impersonates SGSuperFans or mimics our official communications to drive affiliate sign-ups.

Affiliate Commission Integrity

SGSuperFans reserves the right to withhold, reverse, or claw back affiliate commissions where the underlying referral was obtained through deceptive, fraudulent, or policy-violating means. Commission reversals may also occur where referred users initiate chargebacks, are identified as fraudulent accounts, or where the referral arrangement violated any applicable law or this Policy.

Paid partnerships, brand integrations, sponsored posts, branded content, and product placement that appear on a Creator’s SGSuperFans profile or in marketing content that drives traffic to SGSuperFans must comply with this Section.

What Constitutes Sponsored Content

A piece of content is “sponsored” or constitutes a “paid partnership” when:

• A Creator receives monetary payment from a brand to feature that brand’s product, service, or messaging in their content.
• A Creator receives free products, complimentary services, discounts, trips, or any other benefit in exchange for creating or publishing promotional content.
• A Creator is an employee, officer, or material shareholder of the brand being promoted.
• The Creator has any other material connection to the brand that a reasonable person would consider relevant to evaluating the authenticity of the endorsement.

Platform-Level Sponsored Content Rules

• Creators who upload sponsored content to their SGSuperFans profile must use the platform’s “Paid Partnership” tagging feature, where available, to flag the content as sponsored.
• Sponsored content must be disclosed in the title, description, or audio/visual content itself, not only in metadata or tags.
• Sponsored content must not promote products or services that are illegal, regulated without proper disclosure (such as prescription medications, unlicensed financial products, or cannabis products in jurisdictions where promotion is restricted), or that violate SGSuperFans’s content policies.
• Creators are responsible for ensuring their sponsorship agreements do not require them to make false or misleading claims about the sponsored product. If a sponsorship contract conflict with this Policy’s truthfulness requirements, this Policy prevails for content posted on the platform.

Native Advertising

Native advertising, which is advertising designed to blend into surrounding editorial or organic content, is subject to particularly strict disclosure requirements because of its high deception risk. Native advertising must be clearly and unmistakably labeled as advertising before a user engages with it. Labels such as “Sponsored,” “Advertisement,” or “Promoted Content” are acceptable. Labels such as “Featured,” “Special Report,” or “From Our Partners” are acceptable only if they are immediately followed by a parenthetical clarification such as “(Advertisement)” in the same or larger font.

SGSuperFans is an 18+ platform that distributes adult content. Marketing and advertising activities that promote an 18+ platform, adult content, or services associated with adult content carry heightened legal obligations in virtually all jurisdictions. This Section establishes the binding minimum standards for all such marketing.

Required Age-Gating in Advertising

• Third-Party Ad Platforms: When buying advertising on platforms such as Google Ads, Meta Ads, TikTok Ads, or any programmatic network, the Creator or SGSuperFans acting as advertiser must enable all available age-targeting restrictions to restrict ad delivery to adults aged 18 and over. Campaigns must not be configured to optimize for audience expansion that may include minors.
• Content of Advertisements: Advertising creative (images, video, copy) promoting adult content must not contain any sexually explicit material. Suggestive, non-explicit creative used to promote an adult platform must include a clear statement that the destination is an 18+ adults-only platform. This disclosure must be readable on the advertisement itself, not only on the landing page.
• Social Media Advertising: When promoting on social media platforms, all applicable sensitive category settings, age restrictions, and adult content advertising policies of those platforms must be selected and complied with in full.
• No Child-Directed Advertising: SGSuperFans and all Creators are absolutely prohibited from advertising through any channel that is primarily directed at children, including YouTube Kids, children’s game apps, family-oriented websites, and educational platforms.

Thumbnail and Preview Standards

Preview images, teaser clips, and thumbnails used in any external marketing context, including social media posts, ads, and email campaigns, must not contain sexually explicit content regardless of whether the full content behind the paywall is legally adult content. Thumbnails that comply with the guidelines of the external platform on which they appear, and that clearly indicate the 18+ nature of the destination, are permitted.

Influencer Marketing of Adult Content

Influencers and Creators who promote other Creators’ adult content profiles on external platforms as part of a paid or incentivized arrangement must ensure that:

• Their own external platform audience is predominantly adult (18+). If their primary social media audience is known to include a significant proportion of minors, they must not conduct paid promotion of adult content regardless of disclosure compliance.
• The disclosure requirements in Section 8 of this Policy are met in full for any paid engagement.
• All promotional content explicitly states that the promoted destination contains adult content available to 18+ users only.

Contests, sweepstakes, giveaways, and similar promotions are subject to comprehensive regulation under Canadian federal and provincial law, including the Competition Act and the Criminal Code (lottery provisions). Running a non-compliant contest or sweepstakes in Canada exposes the organizer to criminal liability. This Section applies to all such promotions run by SGSuperFans and by Creators through or in connection with the platform.

Key Distinction: Contest vs. Lottery vs. Game of Chance

Mandatory Elements of All Promotions

Every promotional contest or sweepstakes run on or by the platform must include:

1. 1A complete set of official rules that are publicly accessible before the promotion begins.
2. 2Official rules must specify: the start and end date of the promotion, eligibility requirements including age restrictions and geographic limitations, how to enter including the free alternative method of entry, detailed description of available prizes and their approximate retail value, odds of winning (for sweepstakes), judging criteria (for skill contests), the expected prize fulfillment date, and the name of the organization running the promotion.
3. 3A free, no-purchase-necessary alternative method of entry that provides the same probability of winning as any purchase-entry method.
4. 4A clear geographic eligibility statement. Promotions must exclude residents of Quebec unless they comply with Quebec’s specific contest regulations (administered by the Regie des alcools, des courses et des jeux) and have fulfilled applicable registration, bonding, and permit requirements.
5. 5Winners must be determined and notified in accordance with the published rules. Winners may be required to sign a release of liability as a condition of claiming their prize, but the release form must be provided in advance or at the time of signing and must not impose undisclosed conditions.

Quebec-Specific Requirements

Quebec’s Consumer Protection Act and the Act respecting lotteries, publicity contests and amusement machines impose registration, bonding, and advertising disclosure requirements on publicity contests that are significantly more onerous than those in other provinces. Any promotion that is open to Quebec residents requires advance legal review by SGSuperFans’s legal team before launch. Creators should contact legal@sgsuperfans.com at least 30 days before launching any promotion to determine whether Quebec compliance requirements apply.

Virtual Currency Promotions

Any promotion that awards SGSuperFans virtual currency, credits, “coins,” or platform-specific tokens as prizes must clearly disclose the applicable redemption restrictions, expiry dates, and the monetary value (if any) of such virtual currency. Virtual currency that cannot be converted to real money or withdrawn must be disclosed as such, and must not be presented as having a monetary value equivalent to real currency in promotional materials.

SGSuperFans collects and processes personal data in connection with its marketing activities. The use of personal data for marketing purposes is governed primarily by Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (“Law 25”), and the EU General Data Protection Regulation (“GDPR”) where applicable. This Section supplements the Privacy Policy, which contains the full details of our data practices.

Legal Bases for Marketing Data Processing

Behavioral Targeting and Profiling

SGSuperFans may use behavioral data, subscription history, content engagement data, and platform activity data to serve personalized marketing content within the platform and to build advertising audiences on third-party platforms. The following standards govern this activity:

• Users are informed of behavioral profiling practices in the Privacy Policy and through our Cookie Policy’s consent management interface.
• Users who have opted out of non-essential cookies and tracking will not have their behavioral data used for marketing personalization. This opt-out is technically enforced, not merely contractual.
• We do not build, purchase, or use advertising audiences based on sensitive personal data categories including health data, financial vulnerability data, religious or political beliefs, or sexual orientation in a manner that could facilitate discrimination or exploitation.
• Lookalike audience features on third-party advertising platforms are used only with appropriately consented seed data sets. We do not create lookalike audiences from data obtained in violation of any applicable privacy law.

Retargeting

We use retargeting technologies (including pixel tracking and browser cookies) to serve targeted advertising to persons who have previously visited the SGSuperFans website. This retargeting:

• Is disclosed in our Cookie Policy and subject to user consent through our cookie consent management platform.
• Does not serve ads that reveal, imply, or suggest the nature of the content a user viewed on the platform. Retargeted ads must be generic platform promotion only, not specific content promotion that could expose a user’s private browsing history.
• Respects Global Privacy Control (“GPC”) signals for users in jurisdictions where GPC must be honored (including California under CPRA).

Cross-Platform Data Sharing for Marketing

We do not sell personal data to data brokers for marketing purposes. We share personal data with marketing technology vendors (email service providers, advertising platforms, analytics tools) only under Data Processing Agreements that bind those vendors to use the data solely for the purposes we specify and in compliance with applicable privacy law. A list of our marketing technology vendors is available in our Privacy Policy.

Artificial intelligence tools, including large language models, generative image tools, synthetic voice technology, and deepfake-adjacent video tools, are increasingly used in the creation of marketing content. SGSuperFans recognizes both the opportunities and significant risks these technologies create. This Section establishes binding rules for AI-generated marketing content on and in connection with the platform.

Disclosure Requirements for AI-Generated Content

The following AI-generated marketing content requires clear disclosure:

• AI-Generated Reviews and Testimonials: Any review, testimonial, or user story produced in whole or in part using AI is prohibited for use in marketing, as it cannot represent a genuine human experience. This applies regardless of whether the AI-generated content is factually plausible or of high quality.
• AI-Generated Images of Real People: Using AI or deepfake technology to create or modify images, video, or audio of real individuals (including Creators, public figures, SGSuperFans staff, or any other identifiable person) for marketing purposes without that person’s informed written consent is prohibited.
• AI Voice Cloning: Using AI voice cloning technology to produce marketing audio content that sounds like a real person without their consent is prohibited. This applies to voiceovers, podcast ads, and any audio marketing material.
• AI-Generated Performance Claims: AI-generated data visualizations, charts, statistics, or projected performance figures that are not grounded in verifiable real data are prohibited in all marketing materials.

Permitted Uses of AI in Marketing

• AI tools may be used to draft, refine, translate, or optimize marketing copy, provided a human reviews the final content for accuracy, legal compliance, and truthfulness before publication.
• AI image generation tools may be used to create abstract or illustrative images for marketing that do not depict real individuals and that do not constitute misleading representations.
• AI-powered marketing optimization (A/B testing, audience segmentation, bid optimization) is permitted within the boundaries of the data protection and targeting standards in Section 13.
• AI generated translations of marketing content are permitted provided the original content was compliant and the translation accurately reflects the original’s meaning without introducing new claims.

Future-Proofing Clause

AI technology is evolving rapidly. Where new AI capabilities create marketing risks not specifically addressed in this Section, the general truthfulness, transparency, and non-deception principles in this Policy shall be applied by analogy. SGSuperFans reserves the right to issue supplementary AI marketing guidelines at any time and those guidelines will form part of this Policy upon publication.

The following marketing practices are strictly and absolutely prohibited by all users, Creators, Managers, partners, and agencies operating on or in connection with SGSuperFans. Engaging in any of these practices constitutes a material breach of this Policy and the Terms of Service.

Deception and Manipulation

• False Scarcity and False Urgency: Creating artificially manufactured “limited time,” “only a few spots left,” or “selling out fast” claims in marketing where no genuine scarcity or time pressure exists. This includes countdown timers, availability counters, and waitlist tools used deceptively to manufacture urgency.
• Dark Patterns in Marketing: Using manipulative user interface or user experience design in marketing funnels to trick users into subscribing, purchasing, or signing up for things they did not intend to commit to. This includes misleading subscription pre-selections, confusing opt-out language, and subscription-to-subscription upsell traps.
• Bait and Switch: Advertising one product, service, pricing, or content type to attract a user and then substituting a different, often inferior, product, service, or pricing once the user has entered the marketing funnel.
• Shill Marketing: Compensating individuals to pose as genuine fans or independent reviewers while concealing their paid relationship with the Creator or with SGSuperFans.
• Fake Social Proof: Fabricating, purchasing, or inflating metrics such as subscriber counts, view counts, testimonials, social media followers, or engagement numbers that are presented as evidence of genuine popularity or quality.

Spam and Unsolicited Communications

• Sending any commercial electronic message without the required CASL or CAN-SPAM consent.
• Mass messaging SGSuperFans users through any platform messaging feature for commercial promotional purposes without using the designated broadcast messaging tool and within the bounds of its permitted use.
• Comment spam: posting promotional comments, affiliate links, or solicitations in other Creators’ post comment sections or in community areas of the platform.
• Operating mass automated account creation or messaging campaigns designed to promote affiliate links or referral codes through the platform’s messaging systems.

Identity and Brand Misuse

• Impersonating SGSuperFans or creating marketing materials designed to look like official SGSuperFans communications when they are not.
• Using SGSuperFans’s name, logo, or brand assets in marketing without authorization as described in the Website Policies Trademark Use Policy.
• Creating phishing pages, fake login pages, or other deceptive infrastructure that impersonates SGSuperFans for any purpose including lead generation.
• Registering domain names, email addresses, or social media handles that impersonate or are confusingly similar to SGSuperFans or its brand for use in marketing.

Multi-Level and Pyramid Scheme Marketing

• The SGSuperFans referral program is a standard single-tier referral program that pays a commission on directly referred users only. Operating or promoting any multi-level commission structure that promises commissions on the referrals of your referrals constitutes promotion of a pyramid scheme and is prohibited under Canada’s Competition Act.
• Any scheme that requires payment of a fee to access marketing materials, referral links, or commission eligibility is a prohibited pyramid scheme regardless of how it is structured.

Targeted Harassment and Competitor Sabotage

• Negative review bombing, coordinated comment campaigns, or organized reporting attacks against competing Creators as a marketing tactic to redirect their fans.
• Defaming, making false statements of fact about, or tortuously interfering with competing Creators’ business relationships through marketing communications.

SGSuperFans serves users globally. Marketing activities directed at users in different countries must comply with the laws of the countries in which those users reside, in addition to Canadian law. This Section provides a high-level overview of jurisdiction-specific marketing requirements that are most relevant to our user base.

European Union (GDPR and ePrivacy)

Marketing directed at EU residents is subject to:

• GDPR (Regulation 2016/679): Requires a clear legal basis (typically freely given, specific, informed, and unambiguous consent) for processing personal data for direct marketing purposes. The right to object to direct marketing processing under GDPR Article 21 must be honored promptly and without requiring any justification from the individual.
• ePrivacy Directive (2002/58/EC): Requires opt-in consent for the sending of electronic marketing communications (email, SMS) to individuals. The “soft opt-in” exception (sending marketing about similar products to existing customers) applies in some EU member states but must be implemented with great care.
• Digital Services Act (DSA): Prohibits profiling-based targeted advertising directed at minors and advertising based on sensitive personal data categories. The DSA’s Chapter III transparency requirements for digital advertising apply to SGSuperFans where we qualify as a relevant intermediary service.

United Kingdom

• UK GDPR (the UK post-Brexit equivalent of the EU GDPR) applies to marketing directed at UK residents.
• The Privacy and Electronic Communications Regulations 2003 (“PECR”) govern email and SMS marketing to UK residents, requiring opt-in consent for marketing to individuals.
• The UK Advertising Standards Authority (“ASA”) and Committee of Advertising Practice Code apply to UK-directed advertising.

United States

• Federal: CAN-SPAM (email), TCPA (telephone and SMS marketing), FTC Act Section 5 (deceptive practices), and FTC Endorsement Guides apply.
• California: CCPA/CPRA provides California residents with opt-out rights from the “sale” and “sharing” of personal data for cross-context behavioral advertising. These rights must be honored through clear “Do Not Sell or Share My Personal Information” mechanisms.
• COPPA: The Children’s Online Privacy Protection Act prohibits collecting marketing data from users under 13. Our 18+ age gate and verification processes are designed to prevent any COPPA exposure entirely.

Australia

• Australia’s Spam Act 2003 governs commercial electronic messages sent to Australian users and requires consent, identification, and unsubscribe mechanisms substantially similar to CASL.
• Australia’s Consumer Law (ACL) within the Competition and Consumer Act 2010 prohibits misleading or deceptive conduct in marketing.

Creator Responsibility for Local Law

While SGSuperFans provides this high-level overview, Creators who market to international audiences are responsible for independently ensuring compliance with the marketing laws of the jurisdictions in which their audience resides. Creators with significant audiences in the EU, U.S., UK, or Australia are strongly encouraged to obtain local legal advice regarding the specific marketing laws that apply to their activities.

SGSuperFans takes marketing compliance seriously and operates an active enforcement program. The consequences described in this Section may be applied individually or in combination depending on the severity, frequency, and nature of the violation.

Detection Mechanisms

We employ the following methods to detect marketing policy violations:

• Automated scanning of promotional content posted through platform tools for prohibited claims, spam patterns, and deceptive elements.
• User and Fan reports submitted through the in-platform reporting system.
• Proactive monitoring of external social media for Creator marketing content that violates this Policy.
• Regulatory referrals and notices received from CASL enforcement (CRTC), the Canadian Competition Bureau, the FTC, national data protection authorities, and equivalent regulators in other jurisdictions.
• Internal audits of affiliate and referral program data for fraud indicators.

Enforcement Actions by Severity

Appeals

Users who believe that an enforcement action was taken in error may submit a written appeal to legal@sgsuperfans.com within 14 days of receiving notice of the enforcement action. The appeal must include the user’s account username, a description of the enforcement action, and the grounds for the appeal. SGSuperFans will acknowledge appeals within 5 business days and respond substantively within 30 business days. During an appeal, the enforcement action remains in effect unless SGSuperFans, in its discretion, agrees to temporarily suspend it pending outcome.

SGSuperFans welcomes reports of marketing policy violations from users, Fans, Creators, competitors, regulators, and members of the public. We are committed to investigating all credible complaints promptly and transparently.

How to Report a Marketing Violation

Reports of marketing policy violations may be submitted through any of the following channels:

• In-Platform Reporting: Use the “Report” feature on any Creator profile, post, or promotion that you believe violates this Policy. In-platform reports are reviewed by our Trust & Safety team within 5 business days for standard cases and within 24 hours for reports flagged as urgent.
• Email: Send a detailed written complaint to marketing-compliance@sgsuperfans.com. Include the username or profile URL of the account involved, a description of the alleged violation, and any supporting evidence such as screenshots, links, or copies of emails received.
• CASL Spam Reports: If you have received an unsolicited commercial electronic message in violation of CASL from a SGSuperFans user, you may also report it directly to the Canada Spam Reporting Centre at fightspam.gc.ca. We cooperate fully with all CRTC investigations under CASL.

Privacy of Complainants

We treat all complaint submissions confidentially. The identity of a complainant will not be disclosed to the subject of the complaint except where disclosure is required by law or with the complainant’s prior written consent. Complainants will receive an acknowledgment of receipt and a notification of the outcome of their complaint to the extent permissible without compromising the confidentiality of our investigation.

Contact Information

Regulatory Contacts for Consumers

This Marketing Policy was last updated in March 2026 and is effective as of January 1, 2026. SGSuperFans reserves the right to amend this Policy at any time. Material amendments will be communicated through in-platform notifications and email. Continued use of the platform following the effective date of any amendment constitutes acceptance of the revised Policy.