1. Provider identification and purpose

These Terms and Conditions of Use (the “Terms”) govern access to and use of the audiovisual content platform known as Siroko TV, accessible through the website https://www.siroko.com/tv and through the mobile applications available for the iOS and Android operating systems (together, the “Platform”).

The Platform is owned and operated by SIROKO SOLUTIONS, S.L. (“Siroko”), a company incorporated under Spanish law, with registered office at Plaza 6 de Agosto nº 6, 2º, 33203 Gijón (Asturias), Spain, holder of Tax Identification Number (N.I.F.) B33950338, and registered with the Official Mercantile Registry of Asturias under Volume 3646, Book 1, Page 83, Section 8, Sheet AS-37176. Contact details: phone number: +34 984 49 37 44 and email address: gdpr@siroko.com.

The Platform allows users to access audiovisual content produced by Siroko, content licensed from third parties, and user-generated content submitted through the Siroko Creator program, as well as to interact with such content through the functionalities made available from time to time.

Use of the Platform, whether as a visitor or registered user, implies full and unconditional acceptance of these Terms, as well as the Legal Notice and Privacy Policy published on the Platform. Users who do not accept these Terms must refrain from accessing the Platform or using any of its features.

2. Acceptance and eligibility

Acceptance of these Terms is deemed to occur through any of the following actions: (i) accessing the Platform as a visitor; (ii) creating a user account through the registration form; or (iii) ticking the box confirming acceptance of these Terms during the registration process.

Ticking the acceptance box will create an electronic record of the version accepted, together with the date and time of acceptance, in accordance with Article 23 et seq. of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (“LSSI-CE”) and Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market (“eIDAS Regulation”).

Users represent that they have the legal capacity required to enter into and be bound by these Terms. Use of the Platform is restricted to individuals aged 18 or over. Individuals under the age of 18 may only access the Platform under the supervision and with the prior consent of their parents or legal guardians. Siroko does not knowingly collect personal data from children under the age of 14 and, if it becomes aware that a registered user is below that age, it will immediately terminate the relevant account in accordance with Article 8 of Regulation (EU) 2016/679 (“GDPR”) and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (“LOPDGDD”).

3. Free access and beta version of the Service

Access to and use of the Platform is currently free of charge for all users, whether registered or not. Siroko reserves the right to introduce premium features or content subject to payment in the future, in which case users will be informed in advance and their express acceptance will be required before accessing or using such paid services.

The Platform is currently provided as a beta version, meaning that it is still under development and testing prior to its official release. Accordingly, users expressly acknowledge and accept that: (i) the Platform may contain technical errors, temporary interruptions, or functional limitations; (ii) certain features may not be fully available and may be modified or removed without prior notice; (iii) Siroko may update, modify, suspend, or discontinue the service for maintenance, improvement, or development purposes; and (iv) the Platform is provided on an “as is” basis, without any guarantee of continuity, availability, or error-free operation, to the fullest extent permitted by applicable law.

The beta phase will remain in effect for an indefinite period and will end once Siroko expressly announces the release of the production version of the service. Use of the Platform during the beta phase does not grant users any right to specific service levels, technical stability, or continued availability of any features or functionalities.

4. User registration and account security

Users may create an account by providing the information requested in the registration form, which must in all cases be truthful, accurate, up to date, and belong to the user registering the account. Siroko reserves the right to verify the accuracy of the information provided and may suspend or terminate the account in the event of false information, inaccuracies, or identity impersonation.

Users are solely responsible for safeguarding their login credentials and for all activity carried out through their account. Users must promptly notify Siroko of any unauthorised use of their account or any security incident of which they become aware.

Users may close their account at any time through the functionality available in their account settings or, alternatively, by contacting the email address indicated in Clause 1.

5. User-generated content and the Siroko Creator program

The Platform allows certain users, through the Siroko Creator program, to publish their own audiovisual content (the “User-Generated Content” or “UGC”), as well as to interact with such content through comments, ratings, and any other features that may be made available from time to time.

Zero-tolerance policy. Siroko maintains a zero-tolerance policy towards objectionable content and users engaging in abusive, discriminatory, or unlawful conduct. The publication, distribution, or attempted publication or distribution of any content prohibited under these Terms will result in the immediate removal of such content and the permanent suspension or termination of the offending user’s account, without prejudice to any legal actions that may apply.

For illustrative purposes, and without limitation, objectionable or prohibited content includes any content that:

• Constitutes a criminal offence or administrative infringement under applicable Spanish or international law, including child sexual abuse material, advocacy of terrorism, incitement to hatred, discrimination or violence, trafficking of substances or weapons, or any other unlawful activity.
• Promotes hatred, discrimination, or violence against individuals or groups based on race, ethnicity, nationality, religion, gender, sexual orientation, gender identity, disability, age, or any other legally protected characteristic or social condition.
• Degrades, dehumanises, sexualises, or promotes discriminatory or violent attitudes towards women, including content promoting gender-based violence.
• Promotes, depicts, or incites animal abuse, cruelty, exploitation, or mistreatment.
• Infringes the rights to honour, privacy, or personal image of third parties, or discloses personal data or confidential information without consent.
• Constitutes fraud, deception, identity impersonation, phishing, or any unfair commercial practice.
• Depicts or promotes explicit violence, torture, mutilation, or self-harm.
• Contains pornographic, sexually exploitative, or sexually explicit material.
• Contains malware, viruses, spyware, or any code designed to interfere with computer systems or compromise user security.
• Constitutes spam, unsolicited bulk communications, repetitive advertising, or any other misuse of the system.
• Infringes third-party intellectual property rights, industrial property rights, or image rights, or is distributed without the legally required authorisations.

This non-exhaustive list shall be interpreted in conjunction with all applicable laws and regulations, including Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market for Digital Services (the “DSA Regulation”).

6. User licence for User-Generated Content

Users represent and warrant that they own all rights to the User-Generated Content uploaded to the Platform or that they have obtained all necessary authorisations and licences from the relevant rights holders for its distribution through the Platform, including, where applicable, intellectual property rights, image rights, and any other third-party rights that may be affected.

In particular, users warrant that the User-Generated Content: (i) is not subject to the management of any collective rights management organisation restricting its use or exploitation; (ii) does not infringe any third-party rights; and (iii) is free from any encumbrances, liens, or third-party claims.

By publishing content on the Platform, users grant Siroko a non-exclusive, royalty-free, transferable, sublicensable, worldwide licence over the intellectual property rights relating to such content, including the rights of reproduction, distribution, public communication — in any form, including interactive on-demand making available — and transformation, solely for the purpose of hosting, distributing, promoting, and exploiting the content through the Platform, the mobile application, the Siroko TV linear programming channel, Siroko’s social media profiles, and any other official Siroko channels.

This licence shall remain in force for the maximum period permitted under applicable law in relation to content that has been publicly communicated during the lifetime of the account and shall continue for as long as the content remains available on the Platform or until the user removes the content or deletes the account, without prejudice to any backup copies Siroko may retain for technical or legal reasons.

Users shall retain full ownership of their User-Generated Content at all times, and the licence granted herein shall not constitute a transfer of authorship or a waiver of any non-waivable moral rights recognised under Royal Legislative Decree 1/1996 of 12 April approving the consolidated text of the Intellectual Property Law (“LPI”).

Where uploaded content includes the image of identifiable individuals, users warrant that they have obtained the express consent of the persons depicted for the purposes provided under Organic Law 1/1982 of 5 May on the civil protection of the right to honour, personal and family privacy, and personal image rights. In the case of minors, users warrant that they have obtained the express consent of the individuals holding parental authority or legal guardianship.

7. Content moderation and protection mechanisms

In accordance with the DSA Regulation and applicable sector-specific legislation, Siroko implements a range of content moderation measures on the Platform, including automated systems, human review procedures, and reporting channels available to users and affected third parties.

7.1. Proactive filtering. Siroko implements systems for the filtering and detection of prohibited content, which may include automated analysis of metadata, keywords, images, and video, as well as subsequent human review. The implementation of such systems does not exempt users from liability for the content they upload and does not constitute a general monitoring obligation on the part of Siroko within the meaning of Article 8 of the DSA Regulation.

7.2. Notice-and-action mechanism (flagging system). Any user or third party may notify Siroko of the existence of allegedly unlawful or objectionable content through any of the following channels: (i) the “Report” button available on each item of content and each comment published on the Platform; (ii) the email address: dmca@siroko.com for notifications relating to intellectual property infringements; and (iii) the email address: gdpr@siroko.com or the whistleblowing channel available at https://fdigital.es/siroko-ced/ for all other notifications. In accordance with Article 16 of the DSA Regulation, the notice must include a sufficiently substantiated explanation of the reasons why the content is considered unlawful, the location of the content (URL), and the contact details of the notifying party, except in the case of notifications relating to offences against sexual freedom or offences involving minors.

7.3. User blocking mechanism. Any registered user may block any other user or creator through the functionality available on the profile of the user to be blocked and on each of their publications. Blocking will take effect immediately and will result in the instant removal from the blocking user’s feed of all content published by the blocked user, as well as an automatic notification to Siroko for internal review purposes.

7.4. 24-hour response commitment. Siroko will act on notifications relating to objectionable content within a maximum period of twenty-four (24) hours from receipt of the notice and may, as appropriate and with a reasoned decision: (i) remove the content; (ii) restrict its visibility; (iii) suspend or terminate the infringing user’s account; or (iv) reject the notice with justification. This timeframe is without prejudice to any shorter deadlines that may apply in cases involving manifestly unlawful content, particularly in the circumstances contemplated under Article 18 of the DSA Regulation.

7.5. Statement of reasons for decisions. In accordance with Article 17 of the DSA Regulation, Siroko will notify users affected by a moderation decision by providing a statement of reasons including, at a minimum, the nature and scope of the restriction imposed, the facts and circumstances underlying the decision, the legal or contractual basis applied, and information regarding the available complaint and redress mechanisms.

7.6. Single point of contact. For the purposes of Articles 11 and 12 of the DSA Regulation, Siroko designates the email address: gdpr@siroko.com as its single point of contact for both authorities and recipients of the service. Communications may be submitted in Spanish or English.

8. User obligations and prohibited conduct

Users agree to use the Platform in a diligent, reasonable, and lawful manner and, in particular, undertake not to:

• Publish offensive, defamatory, slanderous, racist, discriminatory, violent, or otherwise harmful content affecting the rights of third parties, as described in Clause 5.
• Publish personal data, private images, or any confidential information relating to third parties without their consent.
• Create accounts using false profiles, impersonate third parties, or use fictitious identities for fraudulent purposes.
• Use the Platform to send unauthorised commercial communications, collect data from other users, or engage in unauthorised automated scraping activities.
• Upload content subject to third-party intellectual property or industrial property rights without obtaining the legally required authorisations.
• Circumvent, disable, or interfere with the technical security, filtering, or moderation measures implemented by Siroko.
• Use the Platform in any manner that may damage, overload, impair, or compromise the operation or security of the Platform.

Any breach of the obligations set out in these Terms shall entitle Siroko to adopt the measures provided for in Clause 7.4, without prejudice to any civil, criminal, or other legal actions that may apply.

9. Uso de sistemas de inteligencia artificial y etiquetado de contenidos

In accordance with Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (the “AI Regulation”), and with the European Commission guidelines on the labelling of synthetic content, Siroko informs users that certain content available on the Platform may have been generated, modified, or manipulated using artificial intelligence systems.

9.1. Labelling requirements. Content generated wholly or partially through artificial intelligence systems, as well as content that has been substantially altered using such systems in a manner that may mislead users as to its authenticity, will be identified by a visible label stating: “Content generated or modified using artificial intelligence (AI)”.

9.2. User obligations. Users who use artificial intelligence tools to generate or modify User-Generated Content must: (i) clearly and visibly disclose the artificial nature of the content where it may mislead users as to its authenticity; (ii) ensure that such content does not infringe any third-party rights, including image rights, intellectual property rights, or data protection rights; (iii) refrain from generating synthetic content that simulates the identity of real individuals without their express consent; and (iv) refrain from creating or distributing manipulated content that may constitute disinformation, fraud, identity impersonation, or a misleading commercial practice.

9.3. Automated recommendation systems. Where the Platform uses automated systems for the classification, recommendation, or prioritisation of content, users will be provided with accessible information regarding the operation of such systems, in accordance with Article 27 of the DSA Regulation.

10. Siroko intellectual and industrial property rights

The Platform software, graphic design, text, trademarks, logos, trade names, databases, interfaces, and any other materials or elements protected by intellectual or industrial property laws are owned by Siroko or by third parties that have authorised their inclusion on the Platform, and are protected under the Intellectual Property Law (LPI), Law 17/2001 of 7 December on Trademarks, and all other applicable legislation.

Any reproduction, distribution, public communication, modification, making available, or commercial exploitation of such content, whether in whole or in part, is strictly prohibited without Siroko’s prior express written consent.

The use of framing techniques, deep linking, automated scraping tools, or any other methods enabling the unauthorised extraction, appropriation, or exploitation of content available on the Platform is also prohibited.

11. Advertising

Users acknowledge and expressly accept that the Platform may now or in the future display advertising belonging to Siroko or to third parties. Any advertising content will be clearly identified and distinguishable from other content, in accordance with the LSSI-CE and Spanish Law 34/1988 of 11 November on General Advertising.

12. Disclaimer and limitation of liability

Siroko acts as a hosting service provider within the meaning of Article 3(g)(iii) of the DSA Regulation and Article 16 of the LSSI-CE. Accordingly, Siroko is under no general obligation to monitor the User-Generated Content hosted on the Platform and shall not be liable for such content where it does not have actual knowledge of its unlawful nature or, upon obtaining such knowledge, acts diligently to remove the content or disable access to it.

To the fullest extent permitted by applicable law, Siroko shall not be liable for any damages arising from: (i) interruptions, errors, or technical failures affecting the Platform, particularly during the beta phase; (ii) temporary unavailability of the service due to technical reasons, maintenance, or force majeure events; (iii) misuse of the Platform by users; (iv) content published by third parties; or (v) content, services, or information accessible through links to external websites or services not operated by Siroko.

Nothing in these Terms shall exclude or limit Siroko’s liability towards consumers where such exclusion or limitation is prohibited under mandatory consumer protection laws, in particular Royal Legislative Decree 1/2007 of 16 November approving the consolidated text of the General Law for the Protection of Consumers and Users (“TRLGDCU”).

13. Personal data protection

The processing of users’ personal data is governed by Siroko’s Privacy Policy, available on the Platform and incorporated into these Terms by reference. In accordance with Articles 13 and 14 GDPR, the Privacy Policy informs users about the identity of the data controller, the purposes of processing, the legal basis for processing, the recipients of the data, retention periods, the rights of data subjects, and the procedures available for exercising those rights.

Siroko’s appointed Data Protection Officer is Martín López Escartiín, attorney-at-law and member no. 103516 of the Madrid Bar Association (ICAM), who may be contacted at gdpr@siroko.com.

14. Modification of the Terms

Siroko may amend these Terms at any time for technical, operational, legal, or strategic reasons. Any changes will be communicated to registered users by email or through a prominent notice displayed on the Platform within a reasonable period prior to their entry into force.

Continued use of the Platform after the effective date of the changes shall constitute acceptance of the updated version of the Terms. If users do not agree with the modifications, they may terminate their account in accordance with Clause 4.

15. Duration and termination

These Terms shall remain in force for as long as the user maintains an active account or continues using the Platform. Siroko may, at any time and without prior notice where justified grounds exist, suspend, restrict, or terminate a user account in the event of a breach of these Terms, applicable law, or reasonable indications of fraud or abuse.

Termination of the contractual relationship shall not affect any obligations which, by their nature, are intended to survive termination, including those relating to intellectual property, confidentiality, liability, and dispute resolution.

16. Governing law and jurisdiction

These Terms shall be governed by and construed in accordance with the laws of Spain. In the event of any dispute arising out of the interpretation or performance of these Terms:

16.1. Users acting as consumers. Where the user qualifies as a consumer within the meaning of Article 3 of the TRLGDCU, jurisdiction shall lie with the courts and tribunals of the consumer’s place of residence, in accordance with Articles 17 to 19 of Regulation (EU) No 1215/2012 of the European Parliament and of the Council of 12 December 2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (“Brussels I (recast) Regulation”), and Article 90.2 of the TRLGDCU. Consumer users residing in the European Union may also access the European Commission’s Online Dispute Resolution platform, available at https://ec.europa.eu/consumers/odr/, established under Regulation (EU) No 524/2013.

16.2. Non-consumer users. For users who do not qualify as consumers, the parties expressly waive any other jurisdiction that may otherwise apply and submit to the exclusive jurisdiction of the courts and tribunals of Gijón, Spain.

17. Language

These Terms have been drafted in Spanish, and the Spanish-language version shall constitute the original and binding version for all purposes. Translations into other languages are provided for convenience only. In the event of any discrepancy, inconsistency, or conflict between the Spanish version and any translated version, the Spanish-language version shall prevail.

18. Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable, in whole or in part, by a competent court or administrative authority, such invalidity, illegality, or unenforceability shall not affect the validity or enforceability of the remaining provisions, which shall remain in full force and effect. The affected provision shall be deemed replaced by a valid and enforceable provision that most closely reflects the original intent of the parties.

19. Incident reporting and feedback

During the beta phase of the Platform, users may report bugs, technical issues, suggestions for improvement, or other observations relating to the operation of the Platform through the contact channels made available for that purpose.

Such communications are provided on a voluntary and informational basis only and shall not create any obligation on Siroko’s part to implement, respond to, or adopt any suggestions received, nor shall they grant users any rights in relation to any improvements, developments, or enhancements that may result from them. Siroko may freely use the information provided for the purposes of analysis, improvement, development, and evolution of the service, without giving rise to any intellectual property rights, financial compensation, or attribution of authorship in favour of the user.

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Siroko Solutions, S.L. · Tax ID No. B33950338 · Plaza 6 de Agosto nº 6, 2º · 33203 Gijón (Asturias), Spain · gdpr@siroko.com

Notice on the Use of Artificial Intelligence and Content Labeling

SIROKOTV informs its users that, in accordance with Regulation (EU) 2024/1689 of the European Parliament and of the Council of June 13, 2024, laying down harmonized rules on artificial intelligence and amending Regulations (EC) No. 300/2008, (EU) No. 167/2013, (EU) No. 168/2013, (EU) 2018/858, (EU) 2018/1139, and (EU) 2019/2144, and Directives 2014/90/EU, (EU) 2016/797, and (EU) 2020/1828 (Artificial Intelligence Act), some content available on the platform may have been generated, modified, or manipulated using artificial intelligence (AI) systems.

The objective of this policy is to ensure responsible, transparent and safe use of AI in the digital audiovisual environment.

1. Detecting AI-created or AI-edited content

SIROKOTV applies a visual and textual labeling system to identify content that:

• Has been created in whole or in part by AI systems.
• Has been digitally altered or manipulated in a way that could mislead regarding its authenticity.

Visible label: "Content generated or modified with artificial intelligence (AI)"

2. Limitations and liability

SIROKOTV cannot guarantee the authenticity of all content uploaded by users. Despite automated tools and human reviews, there may be unlabeled materials that include elements created by AI or digital alterations.

Therefore, users are advised to:

• Critically analyze the videos viewed.
• Do not assume that images, voices or statements represent actual events.
• Report any content that may be considered manipulated or potentially misleading.

3. Principles of transparency and traceability

In line with the AI Act and the European Commission's guidelines on synthetic content labeling, SIROKOTV is committed to:

• Apply metadata and digital watermark systems to label synthetic content.
• Implement manual and automated review procedures.
• Collaborate with competent authorities in detecting deepfakes or misuse of AI.

4. Sensitive or high-risk content

SIROKOTV will apply enhanced monitoring and blocking measures when AI-generated content is detected that:

• May be misleading in political, health or public safety matters.
• Involves impersonation of real people or infringes image copyrights.

5. User rights

Users may request the review or removal of content when they believe it violates this AI transparency policy. Requests must be submitted through the contact form available on the platform or to the legal email provided in the general notice.

Service provided in beta version

The SIROKO TV Platform is currently in a beta phase, meaning it is a version under development and testing prior to its final release.

Consequently, the User acknowledges and expressly accepts that:

1. The Platform may be subject to technical errors, temporary service interruptions, functional limitations, or changes to its features without prior notice.
2. Certain features, content, or services may not be fully available, and may be modified or removed during the beta period.
3. SIROKO may update, modify, suspend, or partially or fully restrict access to the Platform in order to perform maintenance, improvements, corrections, or service enhancements.
4. Access to and use of the Platform during the beta phase are provided on an "as is" basis, and SIROKO makes no guarantees regarding continuity, availability, or the absence of errors, to the extent permitted by law.
5. The use of the Platform in its beta phase shall not confer any right to demand specific service levels, technical stability, or continued availability of features.

The beta phase shall have an indefinite duration and will conclude when SIROKO expressly announces the transition to the final or production version of the service.

Reporting of incidents and suggestions

During the beta phase of the Platform, the User may report to SIROKO any detected errors, technical incidents, suggestions for improvement, or remarks regarding the Platform’s operation, using the contact channels provided for this purpose on the website.

All such communications shall be considered purely voluntary and informational, and their submission shall not obligate SIROKO to respond to, implement, correct, or adopt the suggestions, incidents, or observations received, nor confer any rights upon the User in relation to any resulting improvements, developments, or modifications.

SIROKO may freely use the information received for purposes of analysis, improvement, development, and evolution of the service, without this implying any recognition of intellectual property rights, financial compensation, or attribution of authorship in favor of the User.