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Final Web/App Version – Premium Consolidated Edition [17.06.2026]
0. EXECUTIVE SUMMARY
Elebaa is a private, invitation-only digital community composed exclusively of real people who have completed Elebaa's access verification process. It is not an open social network or an application designed for volume. It is a curated space where intimate freedom is experienced through consent, safety and discretion. This Master Document establishes the legal and operational architecture that makes that promise possible.
0.1 Purpose
The purpose of this document is to:
This is not merely about complying with the law. It is about structuring freedom within clear and enforceable boundaries.
0.2 Guiding principles
Elebaa is built on three inseparable pillars:
These principles are not merely declarative. They are applicable and enforceable.
0.3 Differentiated model
In contrast to a market dominated by volume, implicit rules or limited governance, Elebaa integrates:
The difference lies not in the narrative, but in how the system is built.
0.4 Shared responsibility
Elebaa provides the structure. The community sustains the space. Adult freedom requires responsibility. Every member contributes to protecting the environment that protects them.
1. CODE OF CONDUCT
1.1 Nature of the space
Elebaa is a private, invitation-only digital environment composed exclusively of real people who have completed Elebaa's access verification process. It is not an open social network. It is not a space for public exhibition. It is not a contact marketplace. It is a curated community where intimate freedom is exercised consciously, consensually and discreetly. Membership of Elebaa is not an automatic right. It is a responsibility towards the community.
1.2 Principles
Adult freedom
Exploration is a conscious decision between responsible adults. Nothing is presumed. Everything is agreed. Everything may be withdrawn.
Absolute consent
Every interaction must be based on consent that is:
Silence does not constitute consent. Persistence after a clear boundary has been expressed constitutes a serious breach.
Safety as a condition
Without physical, emotional and digital safety, there can be no community.
Discretion
Information shared within Elebaa belongs to the Platform's private environment. Its external disclosure without consent violates the essence of the space and may have legal consequences.
A community built on judgement and respect
Elebaa prioritises human quality, intention and respect over accumulation, pressure or external validation.
1.3 Prohibited conduct
The following, among other conduct, shall constitute a breach:
The non-consensual redistribution of intimate content shall result in immediate termination and may be reported to the competent authorities.
1.4 Enforcement and disciplinary measures
Elebaa may apply proportionate measures, including:
Where a measure entails a material restriction of an account or content, the member shall receive:
In accordance with Regulation (EU) 2022/2065 (DSA). Decisions shall be adopted on the basis of proportionality, consistency and non-discrimination and shall be recorded internally for traceability purposes.
1.5 Communities
Communities are thematic spaces created to facilitate interaction among Elebaa members with shared interests. All communities must be approved in advance by Elebaa before they are published or activated. Communities may be configured as public or private within the Platform, in accordance with the functionalities available at any given time and the criteria established by Elebaa. The persons responsible for each community must promote a respectful environment consistent with the principles of consent, safety and discretion set out in this Code of Conduct.
Individual members may not use communities for advertising, promotional or commercial purposes without Elebaa's prior authorisation. Communities must maintain a minimum of 20 members and a reasonable level of activity. Elebaa may suspend, archive or delete communities that remain inactive for more than 30 days or fail to meet the minimum participation requirements.
Invitations sent to third parties must be used responsibly. Members who invite other persons must exercise reasonable diligence in relation to those admitted through their invitations. Abusive use of the invitation system, the repeated admission of users who breach the Platform rules, or any attempt to circumvent access mechanisms may result in limitations, suspension or withdrawal of invitation privileges and, where appropriate, the member's own account.
Communities, their administrators and their members must comply with the Platform rules at all times. The existence of a community does not confer autonomy from Elebaa's general rules.
2. TERMS AND CONDITIONS
2.1 Identification
Random Lifestyle Group, S.L.
B26719740
legal@elebaa.com
support@elebaa.com
DSA point of contact: dsa@elebaa.com
2.2 Nature of the service
Elebaa is a private digital platform that hosts content generated by its members. Elebaa:
Elebaa acts as a hosting service provider in accordance with European legislation.
2.3 Eligibility and mandatory verification
Access is restricted to persons aged 18 or over. Biometric verification is mandatory before a user may:
Access to the Platform requires completion of the verification process and an active subscription or another valid access entitlement in accordance with the applicable conditions. Access to the Platform will not be activated unless the verification process has been successfully completed. Elebaa reserves the right to approve or refuse access in accordance with internal criteria designed to preserve safety and consistency, without unlawful discrimination.
2.4 Paid services
Access to Elebaa is provided through a subscription or through other valid access entitlements granted by Elebaa under promotional campaigns, special invitations or specific applicable conditions. Elebaa may offer different access plans, premium functionalities, additional services or temporary promotions. The characteristics, duration, price, applicable taxes and conditions of each plan shall be communicated to the user before purchase. The specific conditions applicable to each paid service shall be provided before it is purchased.
Elebaa may modify prices applicable to future purchases or renewals. No modification shall affect periods that have already been paid for. Users shall be informed within a reasonable period before new prices applicable to future renewals take effect.
2.5 Invitations, codes and promotions
Access to Elebaa may be obtained through an invitation, an access code or a request approved by the Platform. Possession of an invitation or access code does not necessarily imply free access or exemption from payment. Certain promotional codes may include specific conditions, including free access periods or temporary benefits. All promotions shall be subject to their own conditions, duration, availability and limitations.
Codes are personal, limited, non-transferable and may not be redeemed for cash. Elebaa may cancel any code obtained or used fraudulently. Promotions and launch prices are temporary and do not create any right to their indefinite continuation unless expressly stated otherwise.
2.6 Immediate commencement and right of withdrawal
Certain Platform functionalities may constitute digital services whose performance begins immediately after purchase. When purchasing a paid functionality, the user:
The service shall be deemed to have commenced when the functionality becomes available to the user. Elebaa shall retain a technical record of:
Elebaa shall retain electronic evidence of these records for the purpose of demonstrating consent and performance of the service in accordance with applicable consumer legislation.
2.7 Member-generated content
Members retain ownership of the content they publish on the Platform. By sharing content on Elebaa, the member grants Elebaa a non-exclusive licence limited to what is necessary for its use within the Platform, including hosting, display, operation, moderation and legal compliance.
Explicit content is not permitted on public profiles. Intimate content may only be shared through a private album, and access shall require the specific consent of the member who shared the content. Elebaa may remove content, restrict its visibility or retain limited copies where necessary for incident management, community safety or legal defence.
Elebaa does not review all content in advance but shall act diligently once it obtains actual knowledge of a possible infringement. The unauthorised redistribution or disclosure of intimate content is strictly prohibited and may have legal consequences. In particular, non-consensual disclosure may constitute a criminal offence under Article 197.7 of the Spanish Criminal Code.
2.8 Protection of intimate content
Elebaa implements reasonable technical measures intended to reduce unauthorised screenshots or captures. No system can guarantee absolute protection. Non-consensual redistribution constitutes a serious breach and may result in:
2.9 Moderation, Notice and Action, and the DSA
Elebaa provides:
Where content or an account is restricted (suspended and/or removed), Elebaa shall communicate:
The user may lodge an internal complaint within 15 days. Where possible, the review shall be conducted by a person other than the person who made the initial decision. Elebaa shall respond within a reasonable period. This is without prejudice to any out-of-court or judicial remedies available under the DSA.
2.10 Limitation of liability
Elebaa shall not be liable for:
This limitation applies without prejudice to mandatory consumer rights.
2.11 Payments and refunds
Unless otherwise required by applicable law, digital functionalities purchased within the Platform shall not be refundable once activated. Subscription services may renew automatically for equivalent periods unless cancelled in advance by the user.
Before purchasing any paid service, the user shall at all times have access to clear information regarding:
In the event of non-payment, chargeback, fraud or a payment incident, Elebaa may temporarily suspend access until the outstanding payment or payment issue has been resolved. Elebaa may use third-party payment service providers to process transactions. Full payment method details shall be managed by those providers in accordance with their own privacy and security policies.
3. PRIVACY POLICY (GDPR)
3.1 Data controller
Random Lifestyle Group, S.L.
privacy@elebaa.com
3.2 Data processed
3.3 Special categories of personal data
Information concerning a person's sex life or sexual orientation constitutes a special category of personal data under Article 9 GDPR. Its processing:
3.4 Purposes of processing
3.5 Legal bases
3.6 Retention
Data shall be retained while the account remains active. Following termination:
3.7 International transfers
Where a provider is located outside the EEA, Elebaa shall implement:
3.8 Rights
Requests may be submitted through the designated channel. A complaint may be lodged with the Spanish Data Protection Agency (AEPD).
3.9 Automated decision-making
No decisions based solely on automated processing that produce legal effects shall be made without human review.
3.10 Security
3.11 Use of data and personalisation
Elebaa may use data derived from the use of the Platform, including:
for the purpose of:
Such processing may include automated processes that do not produce significant legal effects for the user. Elebaa shall not disclose identifiable personal data to third parties for commercial purposes without the user's express consent. However, Elebaa may use aggregated, anonymised or otherwise non-identifiable information for analytical, statistical or service-improvement purposes.
4. COOKIE POLICY
Elebaa uses:
The banner shall display: Accept · Reject · Configure, with equal prominence.
No non-essential cookies shall be installed without prior consent. Users may change their preferences at any time through the settings panel. The policy shall detail:
In accordance with the LSSI and the 2024 AEPD Cookie Guidance. No deceptive design patterns shall be used to influence the user's choice.
5. VERIFICATION POLICY
Verification is mandatory before any interaction on the Platform. The process is carried out through a specialised biometric verification and liveness detection provider, such as Didit, acting as a processor. Only the data strictly necessary to verify the user's authenticity through biometric mechanisms and liveness checks shall be processed.
Verification does not constitute documentary identity validation or an official age check. Elebaa does not store identity documents or biometric data and retains only the verification result and the technical records necessary for security and compliance purposes. The verification provider shall process the data in accordance with its own privacy policy and only for the period strictly necessary to provide the service and comply with its legal obligations.
Manipulation of the verification process shall result in permanent termination. Elebaa shall apply the principles of data minimisation and purpose limitation throughout the verification process.
6. SAFETY CENTRE
Elebaa provides:
Meeting in person is solely the members' decision. Elebaa recommends:
Safety begins within the community and is sustained through individual responsibility. Elebaa does not supervise or validate in-person meetings and accepts no liability for decisions made outside the Platform.
7. REGULATORY FRAMEWORK AND ACRONYMS
Elebaa operates within the framework of Spanish and European Union legislation applicable to digital services, data protection and electronic commerce. This Master Document incorporates the requirements arising from the following legislation and standards:
7.1 GDPR — General Data Protection Regulation (Regulation (EU) 2016/679)
The GDPR regulates the processing of personal data within the European Union. For Elebaa, this entails:
Privacy is a fundamental condition of the service.
7.2 LOPDGDD — Spanish Organic Law on Data Protection and Guarantee of Digital Rights (Organic Law 3/2018, Spain)
This law supplements the GDPR within the Spanish legal system and regulates additional matters such as digital rights and the sanctions regime.
7.3 LSSI — Spanish Information Society Services Act (Law 34/2002, Spain)
The LSSI regulates:
Elebaa complies with the applicable identification, transparency and consent obligations concerning tracking technologies.
7.4 DSA — Digital Services Act (Regulation (EU) 2022/2065)
The DSA governs the obligations of platforms that host user-generated content (UGC). For Elebaa, this entails:
Elebaa does not qualify as a VLOP (Very Large Online Platform) at its current stage.
7.5 UGC — User-Generated Content
Content generated by the Platform's own members. Elebaa acts as a hosting service provider in relation to UGC, without systematic prior review, but shall act diligently once it obtains actual knowledge of an infringement.
7.6 CMP — Consent Management Platform
A technical system that enables Elebaa to:
Technical implementation of a CMP is essential for compliance with the LSSI and the 2024 AEPD Cookie Guidance.
7.7 SLA — Service Level Agreement (internal)
Internal response and resolution time standards applicable to:
These standards form part of Elebaa's internal Operational Playbook and ensure consistency and traceability.
7.8 DPO — Data Protection Officer
A role appointed where required or strategically advisable under the GDPR. The DPO acts as the point of contact for data protection matters.
7.9 AEPD — Spanish Data Protection Agency
The competent supervisory authority in Spain for personal data protection matters. Members may lodge a complaint with the AEPD if they believe their rights have been infringed.
7.10 EEA — European Economic Area
Where personal data is transferred internationally outside the EEA, Elebaa shall implement the appropriate safeguards required by the GDPR, including Standard Contractual Clauses where applicable.
Regulatory conclusion
The regulatory framework is not a formal add-on. It is the architecture that allows freedom to exist within clear boundaries. Elebaa integrates privacy, safety and transparency as essential elements of its design (safety-by-design and privacy-by-design).