Privacy Policy

I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)

EntertainTech Solutions LLC ("we," "us" or "our") takes your privacy seriously. This Privacy policy ("Privacy policy") explains our data protection policy and describes the types of information we may process when you install and/or use our "AI Hairstyle Try On" software application for mobile devices (the "App", "our App"; bundle identifier tech.blowy.hairstyle). The App lets you preview new hairstyles and hair colors on a selfie you provide. The App's title may vary in countries and is subject to change without specific notice.

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy policy applies to all users, and others who access the App ("Users").

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:

• the categories of personal information that is processed;
• the categories of sources from which personal information is obtained;
• the purpose for processing of user personal data;
• the categories of third parties with whom we may share your personal information;
• the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

What this Privacy Policy Covers:

PERSONAL INFORMATION

All about the categories of information, its sources and purposes of processing.

Please mind that according to CCPA personal information does not include de-identified or aggregated consumer information.

SHARING

How your information can be shared.

Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

OPT-OUT OPTIONS

If you don't want us to process your personal information anymore please contact us through the support@blowy.tech. In most cases there is no way to maintain the App's further operating without functional data therefore you will be advised to remove the App from your device.

If you don't want us to share device identifiers with service providers please check your device settings to opt out.

REQUESTS

To submit a verifiable consumer request for access, portability or deletion of personal data please contact us through the support@blowy.tech. Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California".

When submitting a verifiable request, you should be ready to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor's identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

EQUAL RIGHTS

Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.

SALE OF DATA

We do not sell any of your personal data to third parties. We do not sell your photos, and we do not use your photos for advertising.

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Information That Is Processed Automatically

On the basis of your permission, we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (Identifier For Advertisers for iOS devices). Some integrated advertising or analytics tools (check Section IV to see the list of them) launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically once you allow our App to track your activity. You can withdraw your permission at any time - please check opt-out options in Section VIII below.

We may process some information about your device and your user behavior on the ground of our legitimate interest. This information falls within categories of data described above in Subsection "Information That Is Processed Automatically", it is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We use this information for improving our App and giving our users the best experience.

• Device Details. When you use a mobile device (tablet / phone) to access our App, some details about your device are reported, including "device identifiers". Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.

What data can be processed:

➜ Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.

➜ Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser.

➜ Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone.

➜ Other device identifiers: e.g. user identifiers (if they are set up by the App's developer).

• Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analysis.
• Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
• Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App. This includes diagnostic and crash information that helps us detect and fix technical problems.
• Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was "clicked" or if it was shown as a "conversion" event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad. This data supports attribution — understanding which marketing campaign led you to install the App.
• In-app events. When you use our App, analytics tools automatically record your activity information (taps, scrolls, screens you visited in the App, onboarding steps, the gender you select for the style gallery, the styles you choose, generations you start, payments, in-app purchases, custom events).
• Subscription details: information about all your subscriptions in the App (subscription start date, its duration, payment receipts); information about the accounts that you create when you get registered (if any); the number of currently connected devices; information about promo codes that you used for accessing the paid version of the App.

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook / Google / Apple account, Facebook / Google / Apple may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).

Payment Information

Our e-commerce provider (Apple) is responsible for billing, processing and charging for the in-app purchases and subscriptions, handles your personal information and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information. You may access the applicable "in-app" purchase rules and policies directly from the App Store.

Selfies, Camera and Photos

The core function of the App is to show you how a different hairstyle or hair color would look on you. To do this, you provide a selfie — either captured with your device's camera or chosen from your photo library. You won't be able to take a selfie unless you grant our App access to your camera, and you won't be able to upload an existing image unless you grant access to your photo library. We request these permissions only for this purpose, and you can change them at any time in your device settings. We process the photo you provide solely to generate the hairstyle preview you request.

On-Device Face Detection

Before a photo is sent for generation, the App uses Apple's on-device Vision framework to check whether a human face is present in the image. This is a simple quality gate that prevents a generation from being started on a photo that has no visible face. This check runs entirely on your device, produces only a "face present / not present" signal, and is not stored or transmitted to us or to any third party. It is not facial recognition: it does not identify you, does not match you against any database, and does not create a face template.

No Facial Recognition or Biometric Identification

We do not use your photos to recognize, identify, verify, or authenticate you. We do not create, store, or share a faceprint, face geometry template, or any other biometric identifier for the purpose of uniquely identifying you, and we do not build a profile of you from your facial features. Facial imagery is processed only to render the hairstyle you asked to preview, and for no other purpose. We do not use your photos to train artificial-intelligence models, and we require the processing providers that render your result to use your images solely to deliver that result and not for their own purposes.

AI Generation and Processing

Generating a realistic hairstyle preview is computationally intensive and is performed on servers rather than on your device. When you start a generation, your selfie and the style you selected are transmitted over an encrypted connection to our processing backend and to a third-party artificial-intelligence image-generation provider acting as our service provider. The provider transforms the image to apply the selected hairstyle while preserving your appearance, and returns the result to the App. These providers process your image on the basis of an agreement and only to perform this service for us.

Generated Content

We may also process the content you generate within the App, namely the "after" images produced from your selfie with the selected hairstyle, and the before/after comparisons you create. You can save these results to your device and share them at your own discretion.

Push Notifications

If you allow notifications, we may send you push notifications (for example, to tell you a generation is ready, or about features and offers). We use a device push token to deliver them. You can turn notifications off at any time in your device settings.

Email communications

If you Sign In or create an account within the App, or otherwise provide us your email address, we may use that email address to send you communications (newsletters) regarding special subscription offers, new features and functionalities and other news related to the App on the grounds of our legitimate interest. Sending you newsletters will allow you to stay up to date and receive the latest news about our App, including about the best price offers. The information about your email address that we've received may be transferred to an email marketing tool for the purposes of optimization and automation of the email delivery process (please check Section IV to learn more about the tools' privacy policies and practices). You may unsubscribe, opt-out of receiving communications to your email address at any time by using the resignation link provided in each email you receive from us. Your unsubscribe request shall be honored within a reasonable period of time.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available. We use functional information — including the selfie you provide and the style you select — to generate and deliver the hairstyle previews you request and to provide you with all other requested services.

(b) To improve, test and monitor the effectiveness of our App. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

(c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use the information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing. We do not use your photos for advertising.

(d) To communicate with you. We use the information we have to communicate with you through push notifications and newsletters, i.e. to send you service and marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e) To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy. We adhere to the U.S. Digital Advertising Alliance's Self-Regulatory Principles for the Mobile Environment.

Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like log files, and device identifiers, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties' tracking technologies or how they may be used.

The service providers we rely on, and their roles, are:

• Apple Inc. — App Store distribution, billing and subscription processing, and delivery of push notifications. See apple.com/legal/privacy.
• Apphud — subscription management and purchase analytics. See apphud.com/privacy.
• Adjust GmbH — install attribution and marketing analytics. See adjust.com/terms/privacy-policy.
• Meta Platforms, Inc. (Facebook) — attribution, in-app analytics events and advertising through the Facebook SDK and Audience Network. See facebook.com/privacy/policy.
• Google / Firebase — analytics, crash reporting and push message delivery (Firebase Analytics, Crashlytics, Cloud Messaging). See firebase.google.com/support/privacy and policies.google.com/privacy.
• AI image-generation provider(s) — a third-party provider that renders your hairstyle preview from your selfie, acting as our service provider and processing your image only to deliver that result.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

• as required by law;
• when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

Photos. We retain the selfie you upload only for as long as necessary to generate and deliver your hairstyle preview, and we delete it from our active processing systems once your result has been delivered, subject to routine, time-limited backups. Generated results that you save remain on your own device under your control until you delete them.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct, change, update or rectify your data.
• Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on the context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us through support@blowy.tech. Please bear in mind that we ensure the above-mentioned rights only with respect to the information that we physically access and store.

When your personal information is processed automatically, you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes.

VIII. HOW TO OPT OUT

Opt-out of tracking

When you first use the App, iOS asks for your permission to track your activity across apps and websites (App Tracking Transparency). If you decline, or later change your choice, we and our partners will not use your device's advertising identifier (IDFA) for cross-app tracking. You can change this at any time in Settings › Privacy & Security › Tracking.

Opt-out of marketing tracking

If you don't want third-party service providers to use the personalized ads on the basis of your interests please follow the instructions below:

• Choose option "Limit Ad Tracking" on your iOS device in Settings/ Privacy/ Advertising, please find additional information here: https://support.apple.com/en-us/HT202074;
• Turn off notifications for the App at any time in Settings/ Notifications.

You can also visit https://youradchoices.com for the same purpose.

Please mind when you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

IX. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information. The selfies you submit for generation are transmitted over encrypted connections.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through the email displayed below.

X. CHILDREN'S PRIVACY

Our App is not directed to children under the age of 13 (or the minimum age required in your jurisdiction), and we do not knowingly collect personal information from children. If you believe that a child has provided us with personal information, please contact us at support@blowy.tech and we will take steps to delete such information.

XI. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

XII. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us via support@blowy.tech.