🛡️ DMCA & COPYRIGHT POLICY

Whale Group LTD (operating under the trading name Pumio, hereinafter referred to as the "Company") respects the intellectual property rights of others and expects its users to do the same. In accordance with the Digital Millennium Copyright Act ("DMCA"), the UK Copyright, Designs and Patents Act 1988, and other applicable global intellectual property laws, we will respond expeditiously to legitimate claims of copyright infringement committed using our Services.

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1. Designated Copyright Agent

If you are a copyright owner or authorized to act on behalf of one, please report alleged copyright infringements taking place on or through the Services by sending a formal Notice of Alleged Infringement to our designated agent:

• Entity: Whale Group LTD (operating under the trading name Pumio)
• Email: support@pumio.io
• Postal Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

2. Information Required in the Infringement Notice (Checklist)

To be legally effective, your notice must be a written communication that includes substantially all of the following six components:

1. Signature Authority: A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed. 2. Copyright Identification: Clear identification of the copyrighted work claimed to have been infringed (e.g., a link to the original work or a detailed description). 3. Infringing Material Location: Precise identification of the material claimed to be infringing and requiring removal or access disabling, including the exact URL or location within the mobile application. 4. Contact Information: Contact details reasonably sufficient to permit the Company to contact you (address, telephone number, and an email address). 5. Good Faith Statement: A statement that you have a good faith belief that the use of the material complained of is not authorized by the copyright owner or its agent. 6. Accuracy Statement: A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the exclusive right owner.

3. Platform Action and Takedown Procedure

Upon receipt of a valid and complete Infringement Notice, the Company will take the following steps:

• Takedown: Expeditiously remove or disable access to the allegedly infringing material hosted on our third-party Content Delivery Networks (CDNs) in compliance with "notice and takedown" frameworks.
• User Notification: Forward the notice to the user who uploaded the material, including instructions on how to file a Counter-Notification if they believe the removal was an error.
• Infringer Termination: Terminate accounts of users determined to be repeat infringers in appropriate circumstances.

4. Limitation of Liability for User-Generated Content (UGC)

As a platform provider, Whale Group LTD acts strictly as a passive conduit and host for user-generated content distributed via third-party CDN networks, in accordance with the UK Electronic Commerce (EC Directive) Regulations 2002 and global safe harbor principles.

> Crucial Disclaimer: The Company assumes no direct liability for intellectual property violations committed by its users. By utilizing the Services, copyright owners acknowledge that the Company’s sole legal obligation is to act in good faith upon receiving a valid DMCA or UK copyright notice to remove infringing content within a reasonable technical timeframe.

5. Counter-Notification Procedure

If your content was removed by mistake or misidentification, you may submit a Counter-Notification to our Designated Agent. This submission must include:

• Your complete contact information.
• Identification of the material that was removed.
• A statement under penalty of perjury that the material was removed by mistake.
• Consent to the jurisdiction of the courts of England and Wales (or your local federal court if outside the UK).