Annex C — Restricted territories and sanctions screening

(Unchanged from v2.0.)

Territory block — sale and payment: Cuba, Iran, North Korea, Syria, Crimea, Donetsk, Luhansk. Determined by billing country, card country, IP and residence time zone — any positive signal blocks.

Screening of designated persons against OFAC SDN/CAPTA and the consolidated lists of the EU, the UN and the United Kingdom (OFSI), at account creation, before the first charge, and monthly across the active paying base.

Two corrections of premise, retained: Georgia is not subject to comprehensive sanctions; neither is Iraq — the restriction there is by designated-person list. Blocking entire countries without a legal basis creates exposure of its own.

Every blocking decision is recorded with its reason, signal, date and operator, and is reviewable by a human (LGPD Art. 20). Channel to contest it: privacidade@soulloop.com, answered within 15 days.

Access to free content is not blocked by territory, except where the law requires it — the restriction applies to the transaction.