PRIVACY POLICY

Future Copilot (HK) Limited, including our subsidiaries and affiliated companies (collectively, “Future Copilot”, “we”, “our” or “us”), puts great efforts in making sure that the personal data we process is stored securely and used properly, and that our data processing practices are accurately communicated to our users and prospective users.

Future Copilot is a pioneer in innovative technology that bridges the gap between imagination and creation. Our photo generating tools offer endless possibilities and inspiration. Future Copilot is a global company, offering these services, apps and technology worldwide.

This privacy policy (“Policy” or "Privacy Policy") describes how we collect, store, use and disclose information while using any of our services, technologies and apps detailed herein. We tried to detail these processes in a simple and friendly manner, and we encourage you to read carefully and reach out to us if you have any further questions.

This Policy is applicable to (collectively and separately, referred to as "you" or “your”): (i) prospects and visitors browsing our websites, landing pages, engaging with ads and campaigns promoting our services, blogs or other web-forms and digital assets (“Prospect” and “Visitor”, respectively); (ii) users accessing, installing or otherwise using our Apps (“Users”); (iii) any individuals using our Services.

You are not obligated, at any time, to provide us with Personal Data or Personal Information (as defined below).

POLICY TOPICS:

UPDATES AND AMENDMENTS
CONTACT INFORMATION AND ROLES
TYPE OF DATA SETS PROCESSED
PURPOSE, LAWFUL BASIS, AND PROCESSING OPERATIONS

TABLE A: APPS, AI AND EDITING TECHNOLOGIES AND TOOLS

TABLE B: AI MACHINE LEARNING AND INTERNAL DEVELOPMENT

TABLE C: PROSPECTS, VISITORS AND INDIVIDUALS INTERACTION WITH OUR WEBSITE, ADS OR DIGITAL ASSETS

HOW WE COLLECT YOUR INFORMATION
COOKIES AND SIMILAR TECHNOLOGIES
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
USER RIGHTS
DATA RETENTION
SECURITY MEASURES
ELIGIBILITY AND CHILDREN PRIVACY
SPECIFICATIONS
1. Additional Notice to California Residents
2. Additional Notice to Colorado Residents
3. Additional Notice to Virginia Residents
4. Additional Notice to Connecticut Residents
5. Additional Notice to Utah Residents
6. Additional Notice to Nevada Residents
7. Additional Notice to Brazil Residents

UPDATES AND AMENDMENTS‌

We may update and amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be accessible from our App. The updated date of the Policy will be reflected in the “Last Modified” heading. In case of a material change, or if required by law, we will provide notice reflecting these changes. Any amendments to our privacy practices described under this Policy will become effective within 30 days after we publish the modified Policy, other than any privacy practices related to new released features which will become effective as of the date of such release. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.

CONTACT INFORMATION AND ROLES‌

Future Copilot (HK) Limited is incorporated under the laws of Hong Kong, China and, unless otherwise explicitly mentioned in the table below, is the Controller of the Personal Data (as such terms are defined under the General Data Protection Regulations “GDPR” or equivalent privacy legislation).

For any questions, inquiries or concerns related to this Privacy Policy or the processing of your Personal Data, you may contact us as follows:

Data Protection Officer - Contact Information: By Email: contact@igen-ai.com

TYPE OF DATA SETS PROCESSED‌

During your use or interaction with the Services, we collect aggregated, non-personal, non-identifiable information (“Non-Personal Data“). Non-Personal Data collected includes aggregated usage information, anonymized information, and technical information, such as: type of device, language preference, time and date stamp, etc.

We further collect information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the tables below. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed Personal Data as long as such connection or linkage exists.

We may process demographic data and certain profiling criteria, which is either provided by you or otherwise inferred from the data sets listed below, by means of example, from your pictures we may determine your gender and age, as further explained below.

PURPOSE, LAWFUL BASIS, AND PROCESSING OPERATIONS‌

We have detailed below, for each type of Service, the Personal Data processed, the purpose and operation and the lawful basis for such processing. There are four tables below, Table A details the Personal Data processed while using our Apps, Table B details the Personal Data used for development, AI machine learning, or otherwise used for internal purposes, and Table C details the Personal Data processed when you interact with our website(s), ads, or other digital assets.

‌TABLE A: APPS, AI & GENERATING TOOLS AND TECHNOLOGIES‌

DATA SET

PURPOSE AND OPERATIONS

LAWFUL BASIS

Online Identifiers and UsageData:

When you use the Apps (including tools and features made available through our website or Third- Party Platforms), we, or our third- party partners, identify you through Online Identifiers. “Online Identifiers” are unique identifiers associated with your account, device or browser, which are either designated by us or transmitted from your device, and may include identifiers known as “IDFA” or “AAID”, IP address, cookie ID, agent, etc.

We further process, directly or indirectly through our third-party partners and service providers, usage data, which may or may not be associated with the Online Identifiers or your account. When associated with an Online Identifier or your account it will be treated as Personal Data, otherwise, if the usage data is aggregated, anonymized or de- identified, it will not be considered as Personal Data.

The usage data includes information regarding your interaction with the App and Services, features used, time stamp and duration of use, click stream data, errors that occurred, as well as your interaction with the content or ads displayed, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (collectively “Usage Data”).

Online Identifiers and Usage Data are used for analytics and operational purposes, correcting errors and bugs, adjust language preference, if applicable, to enable you to use the Services and to provide you with its functionalities. Some of the Apps further display interest-based ads or other marketing and promotions which are based on the Usage Data.

We may further use the Usage Data to customize our Services and offer you and our users content or other Services based on Usage Data or statistics and our analyze of Usage Data, meaning that we can assume you will be interested in based on other features you have used, etc.

When the processing is for marketing or tracking purposes, we will obtain your consent to process Personal Data (where required under applicable laws).

When the processing of Personal Data is for operations and providing the Services’ functionalities, the lawful basis is contract necessity.

Last, the Personal Data may be processed subject to our legitimate interest of understanding how our Services are used, correcting errors and enhancing experience, including by personalizing our offers, content and promotions.

Generating Tools – Images and Photos:

To enable the Services, you will either upload your photos from album or take photos on our App. Images and photos are processed on our server for the purpose of rendering AI Avatar that is used to help you generate images in real time.

Face Data is processed on our servers to only create AI Avatars, and it’s not shared with third parties. Once AI Avatar is created, face data will be deleted from our servers.

We also process demographic data, such as age (or age group) and gender and may process other characteristics such as skin tone, which are either inferred from your images, photos or otherwise provided by you (as part of your Account Data), as well as additional information you voluntarily choose to provide us.

We process the data to enable the use of the generating tools and features available within the Services (Apps and other editing tools), including the ability to further improve the results of the created artwork.

When photos are used for creating artwork or adding effects to your creations, the selected content is uploaded to our Cloud. Your output image or other created artwork will be stored on our Cloud until you request us to delete your Personal Data and your account. We will further process demographic data, and other characteristics (inferred or provided by you as part of your Account Data), as well as the features or effects you use through our Services in order to:

(i) market personalized offers by Future Copilot, and for example, to offer you features which are similar to the features you use or popular among users with similar characteristics. We do not use Face Data for marketing purposes and this information is not shared with any third parties; and (ii) AI machine learning and internal development (as further described in Table B, below).

We process the images, Face Data, demographic, and characteristics related data (inferred or provided by you as part of your Account Data), for

the purpose of providing the Services and performing our contract with you.

If you granted access to your photo gallery, you can revoke the permission at any time.

We will further process demographic or otherwise any characteristics related data (inferred or provided by you), as well as data related to the features or effects used, subject to our legitimate interest, to improve, enhance and customize our offers and Services.

AI Tools and Features:

Certain Services accessible through the Apps, our website or Third-Party Platforms include artificial intelligence (“AI”) technology for creating images and photos. This AI technology allows you to use various features, including, among others, personalized AI photos, “swap” features or other face manipulation features (collectively “AI Tools Outputs”).

To create the AI Tools Outputs, as well as to generate the Face Model, (called ‘Avatar’ in the app, as defined below), and as applicable, we process, including by our AI technology, the original imagesthat you upload (“Inputs”), as well as demographic data (such as gender and skin tone) provided by you under your Account Data. To create the AI Tools Outputs, including to improve and optimize the results, our AI technology further generates and processes types of information known as “metadata”, meaning, information extracted from your Inputs and describing certain elements of such Inputs such as estimated demographic data (for example age or age group, gender and skin tone of the character), and other labels or tags of items in such Inputs, as well as uses face detection to analyze Inputs (images) in order to estimate the posture and location of faces or of parts and areas of faces and other non-identifying characteristics of faces that appear in frame.

We may further process Non-User Personal Data (as defined and described in the section below), including for the purpose of generating Face Models (defined below) in the event your Inputs include any third party’s image.

To provide certain visual AI Tools Outputs, our AI technology uses images, as well as the “metadata” described above that may further generate facial features information such as facial geometry, topology, and face embedding, in order to create a model of the face that appears in your Input (“Face Model”). Face Models are not used to identify you or anyone else. However, Face Models may be deemed “biometric identifiers” according to the laws of your jurisdiction, and will only be processed with your consent, subject to the terms of such laws and this Policy.

Our AI technology may be further accessible through Third Party Platforms, which enable you to generate and receive the AI Tools Outputs within such Third-Party Platforms. Please note that, any information that you upload to, or obtain through, Third Party Platforms (even if using our pages and bots), shall be further subject to such Third-Party Platforms’ terms and policies that apply to you as their user and we do not have control nor responsibility in this regard.

Our Services may include interaction with chatbot, to be processed with your consent, subject to the terms of such laws and this Policy.

These chatbots may be powered by third party service providers AI tools to process your data and provide the AI Tools Output.

We process the data, including Inputs, Face Models, metadata, and other information you voluntarily choose to provide, for the purpose of providing the Services and generating the AI Tools Outputs.

Note that this data might be processed on your device or otherwise uploaded and processed on our Cloud – depending on the specific App, feature, or Service you use.

Specifically, to create the Face Model (called ‘Avatar’ in the App), we process 1 image or 8-20 images as Inputs, and we are currently usingthird-party services that allow Users to generate personalized Avatars.

In the event that the Face Models created from your Inputs are processed and stored on our Cloud, they will be stored to enable repeat experiences using them. Face Models will be permanently deleted within 3 years after the last time you have used them, or earlier if you ask us to delete all your information and your account or otherwise according to our retention policies.

Face Models, if retained and stored by us, are retained and used solely to provide you with additional AI Tools Outputs you request to generate through your use of the App and Services, unless you have otherwise provided us with consent to use Face Models for development and AI machine learning purposes (as detailed under Table B below) .

We do not share Face Models with third parties except in the limited circumstances described under this Policy (see Section 7 – Data Sharing, below).

Inputs, the gathered metadata, and AI Tools Outputs, will be further used for AI machine learning and internal development (as further described in Table B, below).

We will further process the inferred demographic data, tags, labels or otherwise any characteristics related data, as well as data related to the features or effects used, to improve, enhance and customize our offers and Services.

Note that, within the parameters set forth above, we may retain, store, or delete Inputs and AI Tools Outputs at our discretion and the above shall not be considered as any obligation on behalf of Future Copilot to store or retain any information.

We process the Inputs, metadata, or other information you voluntarily choose to provide, to generate the Face Models, and create the AI Tools Outputs and optimize their results, meaning, for the purpose of providing the Services and performing our contract with you.

Where required under applicable laws, we will obtain your consent for the processing of such data sets.

We will further process demographic information, the gathered metadata or otherwise any characteristics related data, as well as data related to the features used, subject to our legitimate interest to improve, enhance and customize our offers and Services, and for example, to offer you features which are similar to the features you use or popular among users with similar characteristics.

Non-User Personal Data:

You may only provide Inputs that include Personal Data of others (“Non-Users”) if you are authorized to consent and have consented (or otherwise acknowledge or approve, as required under applicable laws) to the terms of this Privacy Policy on their behalf.

We process the Input you upload for the purpose of providing the Services and the additional purposes described under this Privacy Policy.

Non-User data is processed based on our legitimate interest in providing the Services to our User.

Support:

When you contact us for customer support, we will process your contact information, as well as any information you choose to provide as part as our communications and correspondence.

We will use the contact information to provide the customer support and communicate with you. We will retain such communications to have records of the support that was provided, for any future needs as well as to further improve our Services and support.

We process such information, for the purpose of providing the support services and performing our contract with you.

We will further retain our communications for records keeping and services improvement, including to train our customer support team, based on our legitimate interest.

Survey and Feedback:

We may ask you to provide feedback on our Services through various means of communications such as through our App, or otherwise through third party survey platforms. If you choose to address our request for such feedback or participate in our survey, we will collect your feedback (as provided, i.e., in writing or otherwise any call recording) and may collect additional contact information such as your name, email address, etc.

We use this information to improve, revise and enhance our Service, as well as optimize and customize the Services.

We process such information subject to your consent. You may withdraw your consent at any time by contacting us through the contact information provided herein.

Purchase Details:

Certain features and Services are subject to payment. Payments are made through in app purchase (“IAP”), in which Google Play or Apple Store terms would govern such payments. However, we process the commercial transaction data such as, records of purchases and prices; shipping details (if applicable); address, contact telephone number and email address (“Transactions Data”).

We use Transactions Data to process your payments and provide the applicable Service you have purchased.

Any information related to your payment means and transactions is processed by the third parties' platforms or IAP and will be governed by such third parties' own privacy policy and terms, which we recommend that your review.

We process Transactions Data to provide the Services and perform our contract with you.

We may further use such information to analyze our Services and their performance (e.g., features’ popularity), as well as to customize and improve our offers and Services, based on our legitimate interests.

Permissions:

Depending on the App used or the features you wish to enjoy, you will be asked to grant us access permissions such as: access to photo gallery, enable tracking tools, push notification, access to your camera, etc. (“App Permissions”).

We will use these permissions to process the information needed to provide the Service or enhance the Service.

To access these App Permissions, you will need to actively and explicitly enable them through an in-app permission or the mobile settings. You can disable the App Permissions at any time, however note, depending on the App Permission if you disable App Permission, certain feature or all features might not properly operate.

Use of Third-Party Technologies:

Our Apps may include integration with third-party analytics service providers such as Google Analytics, Google’s Crashlytics and Firebase services, and Facebook. We may disclose your information (such as Online Identifiers and Usage Data) to these analytics providers to help us learn more about how you and others use our Services.

We will disclose the information to third party analytic providers for marketing and tracking purposes, analytics and operational purposes, correcting errors and bugs, enhance the Services such as to adjust language preference, if applicable, to enable you to use the App and to provide you with its functionalities.

When the processing is for marketing or tracking, where required under applicable laws we will process the Personal Data based on consent. Otherwise, we will process and share the Personal Data subject to our legitimate interest.

‌TABLE B: AI MACHINE LEARNING AND INTERNAL DEVELOPMENT‌

DATA SET

PURPOSE AND OPERATIONS

LAWFUL BASIS

Note that, all capitalized terms listed herein are defined under Table A above.

We will use the Usage Data and inferred data, labels, tags, and other metadata to enrich the content and improve the features available within the Services as well as) to personalize the Service offered to you, tailor offers to your interest and offering additional Future Copilot App products, apps or services which we believe you will enjoy, based on your use.

To improve the AI technology and to offer better Services, we use parts of your Inputs and Outputs for AI machine learning purposes, meaning to train our AI algorithm, develop and create models and features, as well as to improve our Services. Subject to your consent, we may further use Face Models for ML (Machine Learning) Purposes, and may retain Inputs for longer periods than as set forth under Table A above for our ML Purposes.

The Usage Data and inferred data, labels, tags, and other metadata as well as Inputs and Outputs used for services improvement, personalization and ML Purposes are processed subject to our legitimate interest to improve our Services and technology.

The Face Models processed for service development and improvement, including ML Purposes, as well as extending our retention of Inputs for such purposes, are subject to obtaining your consent. You have the right to withdraw your consent at any time, as set forth under the “User Rights” section below or through the app settings.

We ensure that identifying information, such as Online Identifiers, email address, etc. is not associated with the information used for ML Purposes.

Usage Data;
Inputs, including the posture, location and other non-identifying characteristics of faces detected in Inputs by our AI technology (but not including Face Data, defined above);
Outputs (including AI Tools Outputs);
Inferred demographic data and metadata such as estimated gender or age group and skin tone.
Face Models

The Inputs, Outputs, and Face Models we use for such purposes will not be used to identify you or any other individual, and we will remove any identifying information related to you or your account.

In addition, we automatically label certain images detected in your Input such as “dog”, “cat”, and male, female, estimated age group and skin tone to improve the performance of the AI technology and features and the outputs (including AI Tools Outputs), such as text-to-image and AI photo creation for purposes of labeling data for use in machine learning and improve and develop the features and Services. Note that labeled data is not tied to any identified individual.

Except as detailed above, Face Models used for training and learning will be permanently deleted within 3 years after the last time you have used them.

Please note that we do our best to moderate the setting of the AI Tools Output to not include any inappropriate or harmful content, however, it is your sole responsibility to upload images that are not unlawful, libelous, defamatory, obscene, pornographic, indecent, lewd, suggestive, harassing, threatening, invasive of privacy or publicity rights, abusive, inflammatory, fraudulent, or can be otherwise interpreted as harmful content. Please contact us at contact@igen-ai.com if you find any content to be offensive.

‌‌TABLE C: PROSPECTS AND INDIVIDUALS INTERACTION WITH OUR WEBSITE, ADS OR DIGITAL ASSETS‌

DATA SET	PURPOSE AND OPERATIONS	LAWFUL BASIS
Online Identifiers and UsageData: When you interact with our website or other digital assets, we, directly or indirectly collect Online Identifiers and Usage Data (i.e., access time and date, movement within the website, click stream, duration, referred URLs, content viewed, etc.).	We process this information to improve the website, identify errors and bugs as well as for statistic, analytic and marketing purposes.	The Personal Data processed for operating the website and our digital assets, through first party cookies, is based on our legitimate interest. Depending on your jurisdiction, third-party cookies will be able to process Personal Data solely if you provided consent through the consent management tool that is used on the website. You may withdraw consent or otherwise change your preferences at any time by using the cookie preference settings tool.
Advertising: When we market the Services, we use third party providers or tools to manage these ad campaigns. Through these tools, we collect information such as the individuals’ journey, when they clicked our ad and if they subscribed or engaged with such campaign or ad.	To perform, facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively, including on other websites and applications.	We process the Personal Data subject to your consent through in-app permission or cookie consent management tool, as applicable.
Contact Information: If you voluntarily contact us through email or other means, or if you fill in a survey, or provide feedback, you will be required to provide us with certain information such as your name, email address, and any additional information you decide to share with us. If you are contacting us on behalf of another person, we value your assistance and care for others, please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this Privacy Policy and agrees that you will provide Personal Data to us on this basis.	We process the information to respond to your inquiry. We may also process the correspondence information in order to improve our sales services or customer support and for record keeping purposes.	We process the information subject to our legitimate interest. We may keep such correspondence if we are legally required to or where we otherwise deem it is needed.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website, Apps, and web-services, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data for as long as it remains combined.

HOW WE COLLECT YOUR INFORMATION‌

Depending on the nature of your interaction with us, we may collect the above detailed Personal Data from you, as follows:

Automatically, when you visit our website or interact with our App and Services, including through the use of cookies (as detailed below) and similar tracking technologies.
When you voluntarily choose to provide us with information, such as when you create an Avatar, contact us or request a demo, all as detailed in this Policy.
By our third parties service providers which collect Personal Data on our behalf, such as analytics service providers.

COOKIES AND SIMILAR TECHNOLOGIES‌

We may use cookies, tracking pixels, third party software development kits (SDKs) as detailed in Table A above, and other technologies in order to maintain, provide, and improve our website, Apps and Services. We use Cookies for various purposes:

Strictly Necessary Cookies: these cookies are necessary for our website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the website will not work.

Functional Cookies: these cookies enable the website to provide enhanced functionality and personalization (e.g., remembers your preferences so you don’t have to re-set them each time you visit). They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Performance and Analytics Cookies: these cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the website. If you do not allow these cookies we will not know when you have visited our website, and will not be able to monitor its performance.

Marketing and Targeting Cookies: these cookies allow us to know whether or not you’ve seen an ad or a type of ad, how you interacted with such an ad, and how long it has been since you’ve seen it. We also use cookies to help us with targeted advertising. We may partner with ad networks and other ad serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your use of our website and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

The third-party cookies we currently use and purpose of use are listed under the Cookies Setting tool available on our website, which you may further use to opt-out of cookies or change your preferences at any time.

Also note that, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that once you choose to opt out or disable cookies, some features of the website may not operate properly and your online experience may be limited.

Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and are responsible for their practices.

DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH‌

We share your Personal Data with third parties, including our partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT	DATA THAT MAY BE SHARED	PURPOSE OF SHARING
Essential Service Providers, which process data on our behalf, for the purpose of providing the Services, securing and improving the Services.	All data except for data which is stored locally on your device.	We may disclose Personal Data to our trusted service providers that provide technology or platforms that are essential for providing the Services (“Essential Service Providers”). Such Essential Service Providers include hosting, and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platforms, data and cyber security services, fraud detection services, billing and payment processing services, shipping and handling services, session or activity recording services, AI tools, support and customer relation management systems. Essential Service Providers have access, or process on our behalf. The Essential Service Providers are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Marketing Service Providers	Usage Data, Online Identifiers, Registration Data, Account Data, and profiling or behavioral data.	Our marketing service providers, that either process on our behalf certain data which we use to target you and offer you our Services, or they provide us with tools to do so (“Marketing Service Providers”).
Consultants	Account Data and Registration data, contact information, and any other data except for data which is stored locally on your device.	Our legal, financial and compliance advisors (“Consultants”) may be exposed to certain Personal Data. The Consultants are bound by privilege obligations or confidentiality agreements and are prohibited to share any Personal Data except for providing the services we requested.
Third-Party Platforms	Registration data, creations, and Popular Pays Marketplace activity.	Our services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit, store or otherwise use with such websites and third-party services, are beyond the scope of our terms of use and Privacy Policy and will therefore be governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. Moreover, if the Services integrate with a third-party service, the API that performs the integration will enable the relevant third party to serve you certain content as well as access some of your content. For example, if you wish to upload or otherwise share your content to an integrated third-party service such as Instagram or TikTok, or to make use of certain functionality in those services, the API will enable the applicable third party to access your content (such as your photo library).
Subsidiaries and Affiliated Companies	All data except for data which is stored locally on your device.	We may share Personal Data, internally within our group or in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
Third Parties, Authorities, Security Providers, Governmental Agencies, or Authorized Third Parties.	Any data except for data which is stored locally on your device, depending on the purpose and needs.	For protecting rights and safety of our Services and Apps, we may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of users or individuals, or any members of the general public. This will include legal and law enforcement purposes, meaning, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our services.

When we share data with service providers and partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).

USER RIGHTS‌

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

Further, certain rights can be exercised from the App: you may correct, revise and delete information using the App settings at any time, any consent provided may be easily withdrawn, and you may opt-out from certain features and tracking, therefore we recommend you use the technical solutions we have provided you with to exercise your rights. Please further note that, AI Tools Output may contain Personal Data about you that you deem inaccurate, and if you would like us to correct the inaccuracy you may submit a correction request, however given the technical complexity of how our AI tools work, we may not be able to correct the inaccuracy in every instance. In that case, you may request that we delete your Personal Data from the AI Tools Outputs.

DATA RETENTION‌

In general, unless a different retention period is described above, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, when permissible by law or regulation, or until you request to delete your information, where applicable.

Other circumstances in which we may retain your Personal Data for longer periods of time when permissible by law or regulation include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at: contact@igen-ai.com.

SECURITY MEASURES‌

We implement appropriate and industry-standard technical, organizational, and security measures to reduce the risks of damage to (or loss of) information, or any unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your Personal Data, it is not guaranteed, and you cannot expect that the Services will be immune to information security risks or attacks. Also, as the security of information depends in part on the security of the computer, device or network you use to communicate with us, the security of your Personal Data depends on you as well. Please make sure to take appropriate measures to use secured networks, devices and to protect your access credentials.

Please contact us at: contact@igen-ai.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

ELIGIBILITY AND CHILDREN PRIVACY‌

The Services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law). We will discard any information we receive from a User that is considered a "child" immediately upon discovering that such a User shared information with us. Please contact us at: contact@igen-ai.com if you have reason to believe that a child has shared any information with us.

SPECIFICATIONS‌

‌Additional Notice to California Residents:‌

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018

(“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.

Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.

‌Additional Notice to Colorado Residents:‌

Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below.

“Personal Data” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include any of the following: publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

“Sensitive Data” includes (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) gnetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data. Please note, however, that while we do not deem Face Models or other such data we collect to be biometric data under the CPA because they are not used to uniquely identify an individual, we will obtain your consent before processing such Personal Data. You may exercise your rights, at any time, including to withdraw consent for us to process your Face Models or request its deletion (as part of a deletion request of all your information and your account, as detailed below).

Under section 4 “PURPOSE, LAWFUL BASIS, AND PROCESSING OPERATIONS” of the Privacy Policy, we describe our collection and processing of personal data, the categories of personal data that are collected or processed, and the purposes. Additionally, the Section describing the “DATA SHARING – CATEGORIESOF RECIPIENTS WE SHARE PERSONAL DATA WITH” details the categories of third-parties the controller shares for business purposes.

‌Your Rights Under CPA:

Herein below, we will detail how consumers can exercise their rights, and appeal such decision, or if we sell the personal data, or sell the personal data for advertising and how to opt-out.

Right to Access/ Right to Know	You have the right to confirm whether and know the Personal Data we collected on you		You can exercise your right by reviewing this Privacy Policy, in case you would like to receive the Personal Data please request it by contacting us at contact@igen-ai.com.
Right to Correction	You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.		You can exercise this right directly through your account.
Right to Deletion	You have the right to delete the Personal Data, this right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) Complete the transaction for which we		If you would like to delete your Personal Data please contact us at contact@igen-ai.com. You do not need to create an account with us to submit a request to delete.
	collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) Debug products to identify and repair errors that impair existing intended functionality; (4) Comply with the law or legal obligation; (5) Engage in public or peer- reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
		We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action.
Right to Appeal		If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal.		Not more than 60 days after receipt of an appeal we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decisions.
Duty not to violate the existing laws against discrimination or non- discrimination		Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices.		We do not discriminate our users.

‌‌Additional Notice to Virginia Residents:‌

Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.

The VCDPA defined “Personal Data”, and “Sensitive Data” as detailed above under “Additional Notice toColorado Residents”. Please note that we do not deem Face Models or other such data to be sensitive biometric data under the VCDPA because they are not used to uniquely identify an individual. However, we will obtain your consent before processing such Personal Data. You may exercise your rights, at any time, including to withdraw consent for us to process your Face Models or request its deletion (as part of a deletion request of all your information and your account, as detailed below).

The VCDPA requires us to discloses the Categories of data processing and the purpose of each category, as detailed in Section 4 “PURPOSE, LAWFUL BASIS, AND PROCESSING OPERATIONS” of the Privacy Policy, the categories of data shared and the third parties with whom it is shared, as detailed in the “DATASHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH” Section. Disclosure of sale of data or targeted advertising are detailed in the User Rights Section above. Further, the table above under “Additional Notice to Colorado Residents” details the rights you have under VCDPA and how you may exercise your rights.

‌How to Submit a Request Under VCDPA?

We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at contact@igen-ai.com and specifying your wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

‌Additional Notice to Connecticut Residents:‌

Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your personal data are described below.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include de-identified data or publicly available information. If further does not include information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.

“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; precise geolocation data. Please note that we do not deem Face Models or other such data to be sensitive biometric data under the CDPA because they are not used to uniquely identify an individual. However, we will obtain your consent before processing such Personal Data. You may exercise your rights, at any time, including to withdraw consent for us to process your Face Models or request its deletion (as part of a deletion request of all your information and your account, as detailed below).

The categories of personal data processed, purpose of processing, are as detailed in Section 4 “PURPOSE, LAWFUL BASIS, AND PROCESSING OPERATIONS”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in the “DATA SHARING – CATEGORIESOF RECIPIENTS WE SHARE PERSONAL DATA WITH” Section. Disclosure of sale of data or targeted advertising are detailed in Section 8 “USER RIGHTS.

Instructions on how to exercise your rights are detailed in the table above under “Additional Notice toColorado Residents” including the rights you have under CDPA and how you may exercise your rights. In addition to the table above, under CDPA you also have the right to withdraw consent which shall be provided within 15 days.

‌How to Submit a Request Under CDPA?

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45-day response period, together with the reason for the extension.

If we decline to take action on your request, we shall inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

‌Additional Notice to Utah Residents (Effective January 2024):‌

Under the Utah Consumer Privacy Act (the “UCPA”) if you are a resident of Utah, acting in an individual or household context (and not in a commercial or employment context) your rights with respect to your personal data are described below. The UCPA defined “Personal Data” and “Sensitive Data” as detailed above under “Additional Notice to Colorado Residents”. Please note that we do not deem Face Models or other such data to be sensitive biometric data under the UCPA because they are not used to uniquely identify an individual. However, we will obtain your consent before processing such Personal Data. You may exercise your rights, at any time, including to withdraw consent for us to process your Face Models or request its deletion (as part of a deletion request of all your information and your account, as detailed below). The categories of personal data processed, purpose of processing, are detailed in Section 4 “PURPOSE, LAWFUL BASIS, AND PROCESSING OPERATIONS”, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in the “DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH” Section. Disclosure of sale of data or targeted advertising are detailed in Section 8 "USER RIGHTS".

Further, the table above under “Additional Notice to Colorado Residents” details the rights you have under UCPA and how you may exercise your rights.

‌Additional Notice to Nevada Residents:‌

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to us at contact@igen-ai.com.