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Privacy Policy / GDPR / Cookie Policy / Medical Disclaimer

PoPLuxon Ltd.

Last Updated: 20 January 2026

 

Welcome to the PoP Program. This Privacy Policy explains how PoPLuxon Ltd. (“we,” “us,” “our,” or the “Company”) collects, uses, stores, and protects your personal data when you visit our website at https://mypopprogram.com/ (the “Website”) or use our services.

We are committed to protecting your privacy and handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Given the sensitive nature of our services in the sexual health and self-improvement sector, we take extra care to ensure your information remains confidential and secure.

 

The data controller responsible for your personal data is:

PoPLuxon Ltd. Company Registration Number: 16114928   Registered Office: 85, Great Portland Street, First Floor, London, W1W 7LT, UK   Registered in England and Wales

Contact Email: info@mypopprogram.com   Website: https://mypopprogram.com/

For any questions regarding this Privacy Policy or your personal data, please contact us at the email address above.

 

We may collect and process the following categories of personal data:

3.1 Information You Provide Directly

  • Identity Data: Name, surname, username, or similar identifier.
  • Contact Data: Email address, telephone number, billing address, and Skype/WhatsApp ID.
  • Special Category Data (Health-Related Data): Information regarding your sexual health or performance issues, which you provide voluntarily when filling out our questionnaires or during consultations, including details about erectile dysfunction, premature ejaculation, porn-induced erectile dysfunction, or related issues. This data is classified as “special category data” under UK GDPR and is processed only with your explicit consent.
  • Financial Data: Billing address and payment details (processed securely via Stripe; we do not store your full card numbers).
  • Profile Data: Your responses to questionnaires (including the Potency Questionnaire), program preferences, and feedback.
  • Communication Data: Records of correspondence with us, including emails, chat messages, and consultation notes.
  • Forum Data: Posts, comments, and interactions within the VIP Club Forum.

3.2 Information Collected Automatically

  • Technical Data: IP address, browser type and version, device type, operating system, time zone setting, and location data.
  • Usage Data: Information about how you use our Website, including pages visited, time spent on pages, click patterns, and navigation paths.
  • Cookie Data: Information collected through cookies and similar tracking technologies (see Section 10 below).

3.3 Information from Third Parties

We may receive personal data from third-party services such as:

  • Payment processors (e.g., Stripe, PayPal)
  • Analytics providers (e.g., Google Analytics)
  • Marketing platforms (e.g., email service providers)

 

We use your personal data for the following purposes:

4.1 Special Category Data (Health-Related Information)

We process health-related information you provide (such as details about sexual health concerns) solely to deliver our coaching and educational services. This processing is based on your explicit consent, which you provide when you:

  • Complete the Potency Questionnaire
  • Enrol in our programs
  • Participate in consultations

You may withdraw this consent at any time by contacting us (see Section 12).

 

We do not sell, rent, or trade your personal data to third parties. We may share your information only with trusted service providers essential for our operations, such as:

5.1 Service Providers

We work with trusted third-party service providers who assist us in operating our business:

  • Stripe: For secure payment processing.
  • MailerLite: For sending our newsletters.
  • Hosting Providers: To keep our website running.
  • Analytics Providers: To understand Website usage (e.g., Google Analytics).
  • Customer Support Tools: To manage enquiries and support requests.

These providers are contractually obligated to protect your data and may only use it for the purposes we specify.

5.2 Legal Requirements

We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., courts, regulatory agencies).

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity.

 

Your personal data may be transferred to and processed in countries outside the United Kingdom. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

  • Transfers to countries with an adequacy decision from the UK Government.
  • Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner’s Office (ICO).
  • Other lawful transfer mechanisms under UK GDPR.

 

We keep your data only as long as necessary.

After the retention period expires, we securely delete or anonymise your data.

 

You have the following rights regarding your personal data:

  • Right of Access: Request a copy of the personal data we hold about you.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data in certain circumstances.
  • Right to Restrict Processing: Request that we limit the processing of your data.
  • Right to Data Portability: Request a copy of your data in a structured, machine-readable format.
  • Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
  • Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
  • Rights Related to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing that significantly affect you.

How to Exercise Your Rights

To exercise any of these rights, please contact us at info@mypopprogram.com. We will respond to your request within one month of receipt. If your request is complex, we may extend this period by a further two months, and we will notify you accordingly.

There is no fee for exercising your rights, although we may charge a reasonable fee for manifestly unfounded or excessive requests.

Right to Complain

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner’s Office (ICO) Website: https://ico.org.uk/ Telephone: 0303 123 1113

 

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

  • Secure socket layer (SSL) encryption for data transmitted via our Website.
  • Secure storage of data on protected servers.
  • Access controls limiting data access to authorised personnel only.
  • Regular security assessments and updates.

While we take all reasonable precautions, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

 

Our Website uses cookies and similar technologies to enhance your experience and analyse Website traffic.

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help us recognise your device and remember your preferences.

10.2 Types of Cookies We Use

10.3 Managing Cookies

When you first visit our Website, you will be presented with a cookie consent banner allowing you to accept or decline non-essential cookies.

You can also manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Website.

For more information, please see our Cookie Policy [Insert link].

 

Our Website may contain links to third-party websites, plugins, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party sites you visit.

 

Our services are intended for individuals aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected data from a minor, we will take steps to delete it promptly.

 

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will:

  • Update the “Last Updated” date at the top of this page.
  • Notify you via email or a prominent notice on our Website (where appropriate).

We encourage you to review this Privacy Policy periodically.

 

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

PoPLuxon Ltd.   Registered Office: 85, Great Portland Street, First Floor, London, W1W 7LT, UK   Company Number: 16114928   Email: info@mypopprogram.com   Website: https://mypopprogram.com/

By using our Website and services, you acknowledge that you have read and understood this Privacy Policy.

 

On the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, GDPR)

The name of the data controller is: PoPLuxon Ltd., PoPLuxon Ltd., (hereinafter referred to as the “Contractor”)

Represented by: PoPLuxon Ltd.

Registered office: Popluxon Ltd. CH: 16114928 

85, Great Portland Street, First Floor, London, W1W 7LT, UK

E-mail: info@mypopprogram.com 

WEB page: (not accessible for the blind and partially sighted) mypopprogram.com

The Contractor does not employ a data protection officer. Profiling: the Contractor does not use profiling.

The Contractor uses cookies on its website:

During visits to the Website, one or more cookies – small files containing a series of characters – are sent to the visitor’s computer, which will allow the visitor’s browser(s) to be uniquely identified. These cookies are provided by Google and are used through the Google Adwords system. These cookies are only sent to the visitor’s computer when visiting certain sub-pages, i.e. they only store the fact and time of the visit to the sub-page in question, and no other information.

The use of the cookies sent in this way is as follows: third-party service providers, including Google, use these cookies to store if the user has previously visited the advertiser’s website and, on this basis, to display advertisements to the user on the websites of partners of third-party service providers, including Google. Users can opt out of Google cookies by going to the Google ads opt-out page. (You can also indicate to users that you can opt out of cookies from third-party service providers by going to the Network Advertising Initiative opt-out page.)

Cookies used:

– Analytics, tracking cookie

– Tracking via website

– Login, user identification session cookie

The “Help” function in the menu bar of most browsers provides information on how to use the browser to

how to disable cookies,

how to accept new cookies, or

how to instruct your browser to set a new cookie, or

how to turn off other cookies.

The website of PoPLuxon Ltd. Contractor uses cookies to facilitate the operation and use of the website, to track website activity and to provide relevant offers.

The cookie notice consists of 4 sections: cookie notice, strictly necessary, functional, analytics

Cookie information

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Data controller PoPLuxon Ltd.’s privacy policy on “cookies”.

What is a “cookie”?

An http cookie is a small packet of information that is sent by the data controller Somorjai Martina or an external service server operated by a third party affiliated with it to the internet browser used by the user/visitor. The browser usually sends it back to the online service each time it requests data from the service’s server. The cookies are created by the service itself, or by a third-party solution created by the related third party and integrated into the service operated by the data controller Somorjai Martina, through the browser on the user’s desktop or portable computer or mobile device capable of browsing the internet, where they are stored in a separate location in the back-up memory of the device.

Depending on the category of “cookies” used on the website, they may be strictly necessary in legal terms, automatically used on the site in practice, or they may require the prior explicit consent of the user. Depending on their category, these may be functional or performance or marketing cookies.

Today, almost all websites use “cookies”, which are basically designed to recognise repeated visits by the user and thus improve the user experience. This may include remembering settings that the user has already made, such as cookie settings, so that they do not need to be remembered on the next visit.

Cookies used:

  • not collect information that personally identifies you
  • collect more general information, such as how users access and use the website, or even the location of users
  • will not be used to provide information to third party marketing companies or media advertisers.

GROUPING OF HTTP COOKIES BY EXPIRY DATE.

In principle, cookies can have 2 types of validity period. One type of cookie lasts only until the browser is closed or until the task is completed, i.e. until the end of the session. Its sole purpose is to prevent data loss. This type of cookie works, for example, for various forms, which are deleted when the cookie is sent. The other type of cookie is “persistent”, i.e. it is stored on the user’s computer beyond the session so that the information it contains can be retrieved by the online service in question. The retention period of the data in the cookie in this case can vary from a few days to years, but can of course be deleted by the visitor at any time. User preferences, such as the display language of the website, are usually stored in this type of cookie.

GENERALLY ALLOW/DENY THE USE OF COOKIES.

Most browser settings give you the option to generally allow or disallow the use of “cookies” when viewing websites. Modern browsers generally provide controls for the use of cookies through the browser settings. You can find out about the cookie settings of the most popular browsers by following the links below:

It is important to note that disabling the use of “cookies” in general through your browser settings may also result in some or all of the interactive features of the website not being available. Therefore, it is always best to use the “cookie” settings provided by the website to control the use of “cookies” associated with that website.

When visiting this website for the first time, the user can consent to the use of cookies by clicking on the “Accept cookies” button at the bottom of the browser window. Before giving consent, the “Advanced settings” link allows you to control which category of cookies you wish to allow. Once cookies have been enabled, the settings will be remembered in the browser for 1 calendar year, but can be changed at any time in the “Cookie settings” menu in the footer of the page.

Note: it may happen that a third-party cookie has been stored on the browser device before the user rejects it (e.g. by previous authorization, etc.). For technical reasons, in such a case, only cookies that are not from a third party will be deleted during the process of “cookie” acceptance using the settings provided by the website. In the case of third-party cookies already placed on the browser device, their deletion will be possible through the browser’s privacy settings.

————

  1. menu item

Strictly required (with the button turned on)

Strictly necessary

“Cookies” strictly necessary for the basic functioning of the website, for which your consent is not required

Legislation allows the use of “cookies” without user consent, without which it would not be technically possible to use the website properly and fully. Examples of such functions include session identification “cookies” for the connection during data communication between the website and the server or the recording of user preferences made in relation to the authorisation of the cookies themselves.

Legal basis for processing: legitimate interest of the controller (Article 6(1)(f) GDPR)

Cookies

Type

Access

Description

cookieyes-functional

https

1 year

This cookie is set by CookieYes and is used to remember users’ consent to the use of cookies in the “Functional” category.

cookieyesID

https

1 year

It stores a unique identifier, which CookieYes uses to record the status of the visitor’s consent to cookies.

cky-consent

https

1 year

The cookie is set by CookieYes to remember the user’s consent to the use of cookies on the website.

cookieyes-necessary

https

1 year

This cookie is set by CookieYes and is used to remember users’ consent to the use of cookies in the “Required” category.

cookieyes-analytics

https

1 year

This cookie is set by CookieYes and is used to remember users’ consent to the use of cookies in the “Analytics” category.

cky-action

https

1 year

This cookie is set by CookieYes and is used to remember what the user has done.

JSESSIONID

https

session

JSP-based websites use. General-purpose platform session cookies, which are used to maintain users’ state between page loads.

  1. menu item

 

Functional (the knob is adjustable)

Category requiring prior user consent:

In the case of cookies that are not legally necessary for the functioning of the website, it is essential that the user gives his or her explicit consent to their use.

If the user does not consent to the use of these “cookies” on the site in their entirety, they also accept that without their consent the website will not function in all respects as intended by the creator/creator. However, the user may subsequently change his/her previous decision to accept cookies requiring consent at any time and without any further conditions by using the settings provided on the website.

The functional cookies allow some of the information provided by the user on the website to be saved so that the site can offer better, more personalised features (e.g. the display language selected on the site, etc.). In addition, this type of “cookie” helps to keep track of various states during navigation on the site, such as the volume setting of the video player, the current playback position, etc.

Legal basis for processing: voluntary consent of the data subject (website visitor) (Article 6(1)(a) GDPR)

Cookies

Type

Access

Description

sync_active

https

Never

It contains information about the visitor’s video content preferences – This allows the website to remember parameters such as the desired volume or video quality. The service is provided by Vimeo.com.

player

https

1 year

Vimeo uses this cookie to save user preferences when playing Vimeo embedded videos.

  1. menu item

 

Analytics (the knob is adjustable)

Category requiring prior user consent:

In the case of cookies that are not legally necessary for the functioning of the website, it is essential that the user gives his or her explicit consent to their use.

If the user does not consent to the use of these “cookies” on the site in their entirety, they also accept that without their consent the website will not function in all respects as intended by the creator/creator. However, the user may subsequently change his/her previous decision to accept cookies requiring consent at any time and without any further conditions by using the settings provided on the website.

Analytical cookies are used to understand how visitors interact with the website. These cookies provide information about the number of visitors, bounce rate, traffic source, etc.

Legal basis for processing: voluntary consent of the data subject (website visitor) (Article 6(1)(a) GDPR)

Cookies

Type

Access

Description

_ga_B3TK3HR2VE

https

2 years

Google Analytics cookie. The cookie is used to track visitors, session and site usage to report site performance. Cookies store information anonymously and assign a randomly generated number to distinguish individual visitors.

_ga

https

2 years

Google Analytics cookie. The cookie is used to track visitors, session and site usage to report site performance. The cookie stores information anonymously and assigns a randomly generated number to distinguish individual visitors.

vuid

https

2 years

Vimeo creates this cookie to collect tracking information by setting a unique identifier to embed videos on the website.

  1. Legal basis for processing

A személyes adatok kezelése során a Vállalkozó a GDPR rendelet 5. cikkében foglaltak szerint jár el. Ezek szerint a személyes adatok kezelése kizárólag akkor és annyiban jogszerű, amennyiben a következők feltételek közül, legalább egy teljesül az adatkezelés során:

1) the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes;

2) the processing is necessary for the performance of a contract to which the data subject is a party or for taking steps at the request of the data subject prior to entering into the contract;

3) the processing is necessary for compliance with a legal obligation to which the controller is subject. If the processing is carried out in the performance of a legal obligation to which the controller is subject, the processing must have a legal basis in Hungarian or Union law or the law of a Member State

4) processing is necessary for the protection of the vital interests of the data subject or of another natural person;

5) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

6) the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child.

In the case of a contract, processing is required by law for the performance of the contract or the issuing of an invoice. Processing shall be lawful if it is necessary in the context of a contract concluded with the Contractor or in the context of an intention to conclude a contract with the Contractor.

In other cases, the provision of data is voluntary, the data subject is not obliged to give his consent to the processing of data, but he acknowledges that without the provision of data the Contractor cannot start or continue the business relationship with him. If the provision of the data was voluntary, the withdrawal of consent to the processing shall not affect the lawfulness of the previous processing.

The Contractor’s detailed data processing purposes, legal grounds and duration are set out in the table below.

  1. Scope of data subjects, legal basis, purpose and duration of data processing

The processing includes all partner / buyer / client / customer data (data subjects).

Principles and methods of data processing

  1. The Contractor shall act in accordance with the requirements of good faith, fairness and transparency, in cooperation with the data subjects in the processing. The Contractor shall process only the data specified by law or provided by the data subjects for the purposes set out below. The scope of the personal data processed shall be proportionate to the purposes of the processing and shall not go beyond those purposes.
  2. In any case where the Contractor intends to use the personal data for a purpose other than that for which they were originally collected, the data subject shall be informed and shall be given the opportunity to obtain his or her prior explicit consent or to oppose such use.
  3. The Contractor does not verify the personal data provided to him. The person providing the personal data is solely responsible for the correctness of the personal data provided.
  4. The personal data of a person under the age of 16 may be processed only with the consent of the person who has parental authority over him/her. The Contractor is not in a position to verify the eligibility of the person giving consent or the content of his/her declaration, so the person concerned or the person having parental authority over him/her warrants that the consent is in accordance with the law. In the absence of a declaration of consent, the Contractor shall process the data of natural persons under the age of 16 only on the basis of a legal provision and only if the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Contractor and if the Contractor has a legitimate interest in doing so.
  5. The Contractor shall not transfer the personal data it processes to third parties other than the data processors specified in this Policy and, in certain cases referred to in this Policy, to external service providers.

An exception to this provision is the use of data in aggregate statistical form, which shall not include any other form of data that can be used to identify the data subject, and shall therefore not constitute processing or transfer of data.

In certain cases – due to an official court or police request, legal proceedings, copyright, property or other infringement or reasonable suspicion thereof, without prejudice to the interests of the Contractor, endangering the provision of the service, etc. – the Contractor may make the personal data of the data subject available to third parties.

The Contractor shall notify the data subject and all those to whom the personal data was previously transmitted for processing purposes of the rectification, restriction or deletion of the personal data processed by it. The notification may be omitted if, having regard to the purposes of the processing, this does not harm the legitimate interests of the data subject.

The Contractor shall process personal data only for specific purposes, for the exercise of rights and the performance of obligations. At all stages of the processing, the purpose of the processing is fulfilled. The data are collected and processed fairly and lawfully. The Contractor shall endeavour to process only personal data that is necessary for the purposes for which it is processed and is adequate for the purposes for which it is processed. Personal data shall only be processed to the extent and for the duration necessary to achieve the purpose.

The Contractor shall not be liable for the lawfulness of the data processing of a contractual partner who is not performing a data processing task and who is in a legal relationship with the Contractor.

The Contractor processes the following data:

 

Type of data

Legal basis, purpose and grounds for processing

Duration of processing

the name, email address, /phone number/skype address (including facial image if not masked) of the private respondent, any sexually sensitive information that may be shared voluntarily

request information electronically via the website on the basis of voluntary consent)

20 years from the date of the incoming notification email

details of the individual on the invoice/receipt voucher for the invoice (name, address)

by law, to pay for the service used and to issue the invoice

8 years after the date of issue of the invoice (Accounting retention)

sensitive personal data relating to the sexual life and/or sexual orientation of the individual who is the subject of the request

provide the requested therapeutic treatment on the basis of the explicit written and voluntary consent of the data subject

20 years after treatment

name, email address, telephone number of the individual interested in the event

contact based on voluntary consent

3 months from the start of the event after the event has taken place

the name, email address, telephone number of the individual representing the co-entrepreneur

the creation of the contract, contacts

in the case of a framework contract, 3 months after the termination of the framework contract, the termination of the representation or, in the case of an ad hoc mandate, the performance of the mandate

name, address, tax number, bank account number, email address, telephone number of the sole trader

the creation of the contract, contacts

8 years after the termination of a framework contract or, in the case of ad hoc assignments, after its completion (Accounting retention)

details of the sole trader on the invoice/receipt voucher for the invoice (name, address, tax number, bank account number)

by law, to pay for the service used and to issue the invoice

8 years after the date of issue of the invoice (Accounting retention)

the name, email address and date of subscription of those subscribed to the newsletter

voluntary consent, provision of information, contact

from subscription to unsubscription or, if an email sent for data accuracy purposes remains without an active reply, for 3 months from the date of sending the data accuracy email

newsletter maintenance calls database (name, phone number)

on a voluntary basis, developing services, providing information, maintaining contacts

from subscription to withdrawal

the name voluntarily registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram/TikTok etc. social networking sites, or the user’s public profile picture

to all data subjects who have voluntarily registered on Facebook/Google+/Twitter/Pinterest/Youtube/Instagram etc. and have “liked” or commented on the Contractor’s website, to provide information, to maintain contact

the data subject can find out about the source of the data, how it is processed, and the method and legal basis of the transfer on the relevant Community site. The processing of data takes place on the social networking sites, so the duration of the processing, the way in which the data are processed and the possibilities for deleting and modifying the data are governed by the rules of the social networking site concerned.

blog/forum post on the contractor’s website: name, email address

publishing a personal diary opinion (without an email address) based on voluntary consent, which can be viewed by anyone via the Contractor’s web interface, and allowing the subscriber to post comments

the processing of the data will continue until the Data Subject withdraws his or her consent in writing

forum/blog post notification: email address

when posting a comment, by ticking the appropriate box, the subscriber has the option, with their voluntary consent, to be notified when a new comment is added to the blog post

the processing of the data will continue until the Data Subject withdraws his or her consent in writing

the name, email address, billing address, delivery address, telephone number of the voluntary users of the web shop, the data of the computer of the logged-in person, which are generated during the use of the service and which are recorded by the system of the data controller as an automatic result of technical processes, the unique browser of the computer by cookies

on the basis of voluntary consent, sales, provision of information, contact

from subscription to withdrawal

the email address, telephone number and sexually sensitive data of the individual completing the questionnaire on the website

requesting information, consultation or assistance on the basis of voluntary consent

20 years from the date of the incoming email

name, address, identification and number of the person lodging the liability claim/complaint

adjudication of the claim / complaint under the law

5 years from the date of sending the reply

personal data of proxies: name, address, name and number of identification cards of a person acting for and on behalf of the data subject in relation to the entrepreneur

managing the proxy holder’s affairs on the basis of voluntary consent

5 years from the date of the case

 

The provision of the data required for the conclusion of the contract is a condition of the provision of the Contractor’s contractual service, and in the absence of such data the service cannot be used, or, in the event of a subsequent request for their deletion, the service can no longer be used. The provision of the other data is voluntary and the withdrawal of consent to data processing does not affect the lawfulness of the previous data processing.

III. Scope of data controllers

 

Person authorised to process datais PoPLuxon Ltd., self-employed.

  1. Data transmission, data processing

The Contractor sends its newsletters via the MailerLite software. MailerLIte Ltd. Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593, Ireland, if the customer’s billing address is in the EEA, the United Kingdom or Switzerland. MailerLite’s sub-processors are also located in the EU: 1. Google Ireland Limited – Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Írország. 2. Vercom S.A. – Roosevelta 22, 60-829 Poznań, Poland (https://www.mailerlite.com/)

The website is hosted by: Elin.hu (ELIN.hu Information Technology Service Provider and Consultant Limited Liability Company 9024 Győr, Déry T utca 11. 2. em. 4.)

The Contractor uses a data processor – the Contractor uses an accountant to perform accounting tasks. The name and address of the data processor is available from the Contractor.

Orders placed on the website can be purchased and paid for with a credit card through the WordPress plugin, Woocommerce software. Credit card payments are provided by Stripe. This guarantees that credit card payments, subscriber data, and data storage are secure.

Orders placed on the website are invoiced manually.

The option to opt for a receipt is a key element in protecting the privacy rights of data subjects.

  1. Data subjects’ rights in relation to data processing

Right to information: at the data subject’s request, the controller must provide information in an appropriate size, language, plain language and easy to find on the essential aspects of the processing (who, what, for what, how, from when, for how long).

Right of access: individuals may request information on whether data relating to them are being processed and, if so, which data are being processed.

Request rectification of data: the data subject can indicate that the data processed are inaccurate and request that they be replaced by what they should be – the controller is responsible for the accuracy of the data, so it is advisable to check their accuracy from time to time.

Right to erasure: the data subject may request the erasure of his or her data at any time. Where the controller has given third parties access to the data requested to be deleted, it must inform all those to whom it has disclosed the data concerned to delete all references to and personal data held by them. Except where the data subject has made any complaint or request for a refund. In this case, the status of the data subject will be replaced by that of a complainant, and the data will be processed in accordance with the general legal provisions on complaints handling.

The right to restriction of processing: in certain cases, the data subject may request the restriction of the processing of his or her personal data – for example, in an unclear, contentious situation or if the processing is no longer necessary but the data subject still wishes to have it restricted.

Right to data portability: the data subject may request to receive data processed concerning him or her in a structured, commonly used, machine-readable format (e.g. .doc, .pdf, etc.) and has the right to have these data transferred to another controller without hindrance from the original controller. In other words, it makes it easier for the data subject to transfer his or her personal data from one controller to another.

Right to object: the data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of his or her personal data for a specified reason. This typically occurs where the data subject has not given consent to the processing of his or her personal data.

Right to withdraw consent: the data subject has the right to withdraw his or her consent at any time. Withdrawal of consent does not affect the lawfulness of the processing based on consent prior to its withdrawal.

The data subject may exercise his or her rights in relation to his or her data by making a request to the controller orally, in writing, by postal address, e-mail address, website – preferably in the forum through which the data were lawfully received by the controller. In the case of an oral request, a record shall be kept and a copy shall be given to the data subject.

If the data subject has a complaint about the processing, we recommend that he or she first complain to the controller (i.e. the Company). The controller has 30 days to investigate and respond to the complaint. If you still have a complaint, you can take it to court (the competent court in your place of residence) or to the National Authority for Data Protection and Freedom of Information.

The court is acting out of turn in the case. The Controller shall prove that the processing complies with the law. In the event that the Controller infringes the data subject’s right to privacy by unlawfully processing his or her data or by breaching data security requirements, the data subject may claim damages from the Controller.

  1. Security measures for data management

The Contractor shall take advanced technical and organisational security measures of a standard appropriate to the size and activity of the business, which shall ensure the security of the processing and handling of personal data as required.

The Data Controller shall ensure the security of the data. To this end, it shall take the technical and organisational measures and establish the procedural rules necessary to enforce the applicable laws, data protection and confidentiality rules.

The Data Controller shall take appropriate measures to protect the data against unauthorised access, alteration, disclosure, disclosure, deletion or destruction, accidental destruction or damage and against inaccessibility resulting from changes in the technology used.

When determining and applying measures to ensure the security of data, the controller shall take into account the state of the art and shall choose among several possible processing solutions the one which ensures a higher level of protection of personal data, unless this would involve a disproportionate effort.

The purpose of this Privacy Notice is to provide data subjects with concise information about certain processing activities of the Data Controller and the relevant rules.

The Data Controller draws your attention to the fact that this Notice is based on the specific data management activities of the Data Controller.

This Information may be amended by the Contractor, the current version of which is available on the Contractor’s website.

Client Communication and Confidentiality

The Service Provider may respond to client inquiries not only through Martina personally but also through authorized staff members, assistants, or professional partners involved in client support.

All authorized personnel receive access only to the information necessary to address the Client’s inquiry and are bound by the same confidentiality, data security, and data protection obligations as the Service Provider.

The Service Provider ensures that all personal data and communication received from the Client are treated confidentially, are not shared with any third parties, and are used exclusively for the purpose of delivering the contracted services.

Medical Disclaimer

Medical Disclaimer

PoP Program – PoP Potency Program

Website: https://mypopprogram.com/

Effective Date: 20 January 2026

  1. Not Medical Advice The information provided in the PoP Potency Program, including but not limited to text, graphics, videos, workbooks, and consultations, is for educational and self-help purposes only. It is not intended to be a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition.
  2. No Doctor-Patient Relationship Participation in the PoP Potency Program or communication with Martina Somorjai (Award-Winning Potencyologist®) does not establish a doctor-patient relationship. Martina Somorjai is a Sexologist and Potencyologist®; these titles represent professional coaching and therapeutic expertise in sexual health and are not medical doctor qualifications.
  3. Physical and Mental Health The program includes psychological, mental, and neurological exercises. Before starting any new program, especially one involving physical techniques or lifestyle changes, consult your doctor. If you experience any pain or discomfort, stop immediately and seek medical attention.
  4. No Guarantees of Results While the PoP Potency Program is designed to address the root causes of sexual performance issues, individual results may vary. Success depends on various factors, including your commitment, health history, and individual circumstances.
  5. Emergency Situations Never disregard professional medical advice or delay in seeking it because of something you have read or heard in this program. If you think you may have a medical emergency, call your doctor or emergency services immediately.
  6. Limitation of Liability PoPLuxon Ltd. and its staff are not responsible for any adverse effects or consequences resulting from the use of the suggestions or exercises provided in this program.

 

The information, content, and services provided by PoP Program through the PoP Potency Program, PoP VIP Program, consultations, books, and all associated materials (collectively referred to as “the Program”) are intended for educational and informational purposes only.

The Program is a self-help and personal development coaching service. It is not a medical service, medical treatment, or therapy, and it should not be construed as such.

 

Nothing contained in the Program, including but not limited to video content, written materials, workbooks, forum discussions, consultations, exercises, or any other resources, constitutes:

  • Medical advice
  • Psychological or psychiatric advice
  • Diagnosis of any medical or mental health condition
  • A prescription or recommendation of any medication or medical treatment
  • A substitute for professional medical care, diagnosis, or treatment

The terms used within the Program, including but not limited to “brain regeneration,” “trauma processing,” “cure,” “fix,” or “treatment,” are used in a colloquial, educational, and coaching context and do not imply medical treatment or clinical intervention.

 

Sexual performance issues, including but not limited to Erectile Dysfunction (ED), Premature Ejaculation (PE), and Porn-Induced Erectile Dysfunction (PIED), may be symptoms of underlying medical conditions that require professional medical evaluation and treatment.

Before commencing the Program, you are strongly advised to:

  • Consult with a qualified physician, urologist, or other appropriate healthcare provider regarding any sexual health concerns.
  • Undergo appropriate medical examinations to rule out underlying physiological causes.
  • Discuss any lifestyle changes, exercises, or techniques presented in the Program with your healthcare provider before implementation.
  • Continue any prescribed medical treatments unless otherwise directed by your physician.

Do not disregard, discontinue, or delay seeking professional medical advice because of any information or content provided in the Program.

 

Participation in the Program, including any consultations or coaching sessions, does not create a doctor-patient, therapist-client, or any other professional healthcare relationship between you and PoP Program, its founder Martina Somorjai, or any of its representatives, coaches, or affiliates.

Martina Somorjai is a certified Potencyologist® and coach. She is not a licensed medical doctor, psychologist, psychiatrist, or licensed mental health professional.

 

The Program is based on holistic coaching methodologies focusing on psychological, mental, and lifestyle factors. Results are not guaranteed and may vary significantly from individual to individual based on numerous factors, including but not limited to:

  • The nature and severity of the individual’s condition
  • Underlying medical or psychological conditions
  • Individual commitment and adherence to the Program
  • Personal circumstances and lifestyle factors

Testimonials, case studies, and success stories presented in connection with the Program represent individual experiences and outcomes. They are not indicative of typical results and should not be relied upon as a guarantee of similar outcomes.

 

By accessing or using the Program, you acknowledge and agree that:

  • You are voluntarily participating in the Program at your own risk.
  • You have been advised to consult a healthcare professional before beginning the Program.
  • You take full responsibility for any decisions you make based on the information provided.
  • PoP Program shall not be held liable for any adverse effects, outcomes, or consequences resulting from your use of or reliance on the Program.

 

The Program is not designed to address medical emergencies. If you experience chest pain, severe pain, difficulty breathing, thoughts of self-harm, or any other medical emergency, discontinue use of the Program immediately and seek emergency medical assistance.

 

To the fullest extent permitted by applicable law, PoP Program, its owner, founder, employees, contractors, affiliates, and representatives shall not be liable for any direct, indirect, incidental, consequential, or punitive damages arising out of or in connection with:

  • Your use of or inability to use the Program
  • Any decisions made or actions taken based on the information provided in the Program
  • Any adverse physical, psychological, or emotional effects experienced during or after participation in the Program

 

This Medical Disclaimer shall be governed by and construed in accordance with the laws of England and Wales.

 

By purchasing, accessing, or using any part of the Program, you acknowledge that you have read, understood, and agree to be bound by this Medical Disclaimer.

PoP Program

The 30-Day Potency Program

Last Updated: 20 January 2026

2025.11.24

Cookie Policy

Cookie Policy

PoPLuxon Ltd. (operating as PoP Program)

Effective Date: 20 January 2026

Last Updated: January 20, 2026

 

This Cookie Policy explains how PoPLuxon Ltd. (“we,” “us,” “our,” or “the Company”), operating as PoP Program, uses cookies and similar tracking technologies on our website located at https://mypopprogram.com/ (the “Website”).

By continuing to browse or use our Website, you acknowledge that you have read, understood, and agree to the use of cookies as described in this Policy. This Cookie Policy should be read in conjunction with our Privacy Policy.

 

Cookies are small text files that are placed on your device (computer, tablet, or mobile phone) when you visit a website. They are widely used to make websites work more efficiently, provide a better user experience, and supply information to website owners.

Cookies may be set by the website you are visiting (“first-party cookies”) or by third parties, such as those who provide content, advertising, or analytics services on the website (“third-party cookies”).

 

We use cookies and similar technologies on our Website for the following categories of purposes:

3.1 Strictly Necessary Cookies (Essential)

These cookies are strictly necessary for the operation of our Website. They enable core functionality such as security, network management, account access, and remembering your cookie preferences. Without these cookies, the Website cannot function properly.

3.2 Analytical/Performance Cookies

These cookies allow us to recognise and count the number of visitors to our Website and see how visitors navigate when using it. This helps us understand traffic and usage patterns and improve how our Website works (for example, by ensuring that users can find what they are looking for easily).

3.3 Functionality Cookies

These cookies enable the Website to provide enhanced functionality and personalisation, such as remembering settings and preferences you choose. They may be set by us or by third-party providers whose services we have added to our pages.

3.4 Targeting/Advertising Cookies

These cookies may be set through our Website by us or our advertising and social media partners. They are used to help deliver marketing, measure the effectiveness of advertising, build audiences, and show you more relevant ads across websites and platforms. They may also be used for social media pixels.

 

Some cookies on our Website are placed by third parties. We do not control the operation of these cookies. The third-party services we use that may set cookies include:

  • Google Analytics – For website analytics and performance monitoring
  • Facebook/Meta – For social media integration and advertising
  • YouTube – For embedded video content
  • Payment Processors – For secure transaction processing

We recommend that you review the privacy and cookie policies of these third parties to understand how they use your information.

 

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences in the following ways:

5.1 Cookie Consent Banner

When you first visit our Website, you will be presented with a cookie consent banner that allows you to accept or reject non-essential cookies.

5.2 Browser Settings

Most web browsers allow you to control cookies through their settings. You can typically find these settings in the “Options,” “Preferences,” or “Settings” menu of your browser. The following links provide information on how to manage cookies in common browsers:

  • Google Chrome
  • Mozilla Firefox
  • Safari
  • Microsoft Edge

5.3 Opt-Out Links

You may opt out of certain third-party cookies by visiting:

  • Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout
  • Digital Advertising Alliance: https://optout.aboutads.info/
  • Network Advertising Initiative: https://optout.networkadvertising.org/

Please Note: If you choose to disable cookies, some features of our Website may not function properly, and your user experience may be affected.

 

In addition to cookies, we may use similar technologies such as:

  • Web Beacons (Pixel Tags): Small graphic images embedded in web pages or emails that track whether you have viewed specific content.
  • Local Storage: Technology that allows websites to store data locally on your device.
  • Session Storage: Similar to local storage but limited to a single browser session.

These technologies work in conjunction with cookies and are subject to the same controls outlined in this Policy.

 

Some browsers have a “Do Not Track” feature that signals to websites that you do not want your online activity tracked. Our Website does not currently respond to “Do Not Track” signals, as there is no industry-standard approach to such signals.

 

We may update this Cookie Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the “Last Updated” date at the top of this Policy.

We encourage you to review this Cookie Policy periodically to stay informed about how we use cookies.

 

If you have any questions, concerns, or requests regarding this Cookie Policy or our use of cookies, please contact us at:

PoPLuxon Ltd.

Registered Office: 85 Great Portland Street, London, England, W1W 7LT

Company Number: 16114928

Registered in England and Wales

Email: support@mypopprogram.com

Website: https://mypopprogram.com/

 

Under the UK General Data Protection Regulation (UK GDPR) and the Privacy and Electronic Communications Regulations (PECR), we rely on the following legal bases for using cookies:

  • Strictly Necessary Cookies: These are exempt from consent requirements as they are essential for the Website to function.
  • All Other Cookies: We rely on your consent, which you may give or withdraw at any time using the methods described in Section 5 of this Policy.

© 2026 PoPLuxon Ltd. All rights reserved.