Privacy Policy

Effective as of January 10, 2022

Last updated: August 31, 2022

This Privacy Policy describes the privacy practices of Mannequin in connection with the websites, mobile application "Peruka" ("App "), and other online products and services (collectively, "Services") provided by Mannequin Technologies, Inc., which may be referred to in this Privacy Policy as "Mannequin", "we", "us", or "our".

Our Privacy Policy explains what information about you we collect, how we collect it, how we use it and for what purposes.

If you have any questions about our privacy practices or our Services, please contact us by email at privacy@mannequin.com, or by post at 5425 Grosvenor Blvd, Los Angeles, CA 90066.

1. Personal Information We Collect

The information we collect depends on the context of your interaction with our Services and the choices you make (including your privacy settings), the Services and features you use, your location, and applicable law.

When you interact with our Services, we may collect the following information about you:

• Name and contact information, such as first and last name, phone number, email address, postal address and other similar information, when you contact us or register an account with us.
• Photographs you provide when you use the App, via your camera or camera roll (if you have granted us permission to access your camera or camera roll), the in-App internet search functionality, or your social media account (if you choose to connect your social media account). We obtain only the specific images you chose to modify using the App; we do not collect your photo albums even if you grant us your access to them. We encrypt each photograph that you upload using the App. The only device that can view the photo is the device from which the photograph was uploaded using the App - the user's device. Please note that while we do not require or request any metadata attached to the photographs you upload, metadata (including, for example, geotags) may be associated with your photographs by default. We take steps to delete any metadata that may be associated with a photograph you provide when you use the App. We do not collect or use your biometric information.
• App usage information, such as information about how you use the App and interact with us, including your preferred language, the date and time when you first installed the App and the date and time you last used the App.
• Purchase history, if you choose to purchase an App subscription, such as confirmation that you are a paid subscriber to the App.
• Social media information, if you choose to login to the App via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to the App. We may collect information from that platform or network, such as your social media alias, first and last name, number of "friends"; on the social media platform and, depending on your network settings, a list of your friends or connections. Our collection and processing of the information we obtain from social media platforms is governed by the requirements these social media platforms impose on us in their relevant terms and conditions.
• Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, device ID, push tokens, browser type, screen resolution, IP address (and the associated country and town in which you are located), the websites you visited before visiting our Services; and other information about the device you are using to visit the Services.
• Online activity data, such as information about your use of and actions on the Services, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and certain third parties (e.g., online advertising networks and their clients) also may collect this type of information over time and across third-party websites and mobile applications. This information may be collected on our Services using cookies, browser web storage (also known as locally stored objects, or "LSOs"), web beacons, and similar technologies. We may collect this information directly or through our use of third-party software development kits ("SDKs"). SDKs may enable third parties to collect information directly from our App.

2. How We Use Your Information

We do not use the photographs you provide when you use the App for any reason other than to provide you with the editing functionality of the App. We may use information other than photographs for the following purposes:

To operate and improve the Services:

• Enable you to use the features of the Services;
• Establish and maintain your account, if you choose to login to the App using your social media account;
• Communicate with you about the Services, including by sending you announcements, updates, and security alerts, which we may send through a push notification, and responding to your requests, questions and feedback;
• Provide technical support and maintenance for the Services; and
• Perform statistical analysis about use of the Services (including through the use of Google Analytics).

To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the "Opt out of marketing" section below.

To display advertisements to you. If you use the free version of the App, we work with advertising partners to display advertisements within the App. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the "Targeted online advertising" section below.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes.

3. How We Share Your Information

We do not disclose user photographs or videos to third parties (with the exception of uploading an encrypted image to our cloud provider Amazon Web Services to provide the photo editing features of the App). We may share your non-photograph and non-video information with third parties who may use your personal information only as directed by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

We may share your non-photograph and non-video information in the following circumstances:

Affiliates. We may share "App usage information" with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with service providers that perform services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services).

Advertising partners. When we use third-party cookies and other tracking tools, our advertising partners may collect information from your device to help us analyze use of the Services, display advertisements on the App and advertise the Services (and related content) elsewhere online.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the App to a third-party platform or social media network (such as by logging into the App using your account with the third-party, providing your API key or similar access token for the App to a third-party, or otherwise linking your account with the App to a third-party's services), we may disclose the personal information that you authorized us to share (such as when you elect to upload a photograph or video to your social media account). We do not control the third-party platforms' use of your personal information, which is governed by that third party's privacy policy and terms and conditions.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

To comply with the law. We may be required to use and share your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

4. Your Choices

In this section, we describe the rights and choices available to all users. Users who are located within the European Union can find additional information about their rights below.

Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other notifications we may send you via push notification by changing the settings on your device.

Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera, camera roll, or microphone through the settings on your device.

Cloud processing. You may request that we remove your information, including photographs, from the cloud before the 24 hour period after which Amazon Web Services automatically deletes the information by contacting us at privacy@mannequin.com.

Cookies & Browser Web Storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Targeted online advertising. Some of the business partners that collect information about users' activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Website users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. App users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user's choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your device settings may provide functionality to limit our, or our partners', ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services. We will tell you what information you must provide to use the Services by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the App via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the App using the third-party's authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party's platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

5. Other Sites, Mobile Applications and Services

The Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

6. Security Practices

We use commercially reasonable security practices to help keep the information collected through the Services secure and take reasonable steps to verify your identity before granting you access to your account (if you have an account with us). However, we cannot ensure the security of any information you transmit to us or guarantee that information on the App or other Services may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the confidentiality of your login information and device identifiers, and for controlling access to communications between you and Mannequin, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.

7. Retention

We configure Amazon Web Services to delete photographs, and the information associated with the photographs within 24 hours after the photograph was last edited using the App. This allows you to revisit the image for additional modifications during that time.

With respect to non-photograph information that we may collect, we will retain such information in a personally identifiable format only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy, such as to the extent necessary to comply with our legal obligations, resolve disputes, enforce our legal agreements and policies, and for internal analysis purposes. You may also ask that we delete your information by contacting us at privacy@mannequin.com.

8. Transfer of Your Personal Information

We store the information we collect in connection with the Services on Amazon Web Services. For Amazon Web Services, we specify the US as the data storage location. Your personal information may be accessed by our service providers in other locations outside of your state, province, or country. Your device ID (and general App usage information) may also be accessed by the Company's technical support team in other locations outside of your state, province, or country.

We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or country unless there are adequate controls in place including the security of your information.

Your consent to this Privacy Policy followed by your submission of personal information represents your consent to the transfer.

9. Children

The Services are not directed at children under the age of 13, and our Terms of Service do not allow children under 13 years of age to use the Services. If we learn that we have collected personal information of a child under the age of 13, we will delete it. We encourage parents with concerns to contact us.

10. Do Not Track Signals

We do not sell your personal information, so our Services do not respond to Do Not Track signals.

11. Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App and other Services. We may, and if required by law, will provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the App.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the App (or as otherwise indicated at the time of posting). In all cases, your continued use of the App and other Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Notice to European Users

The information provided in this "Notice to European Users" section applies only to individuals who reside in the European Union.

Personal information. References to "personal information" in this Privacy Policy are equivalent to "personal data" governed by European data protection legislation.

Controller and EU Representative. Mannequin is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

We have appointed VeraSafe as our representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted only on matters related to the processing of personal data, to make an inquiry please use this contact form. Alternatively, you may call VeraSafe at +420 228 881 031, or write to VeraSafe Ireland Ltd., Unit 3D North Point House North Point Business Park New Mallow Road, Cork T23AT2P, Ireland.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described below.

Processing Purpose

Legal Basis

To operate and improve the Services

Processing is necessary to perform the contract governing our provision of services in connection with the Services, or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.

• To send you marketing and promotional communications
• To display advertisements to you
• For compliance, fraud prevention, and safety
• To create anonymous, aggregated or de-identified data

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

With your consent

Processing is based on your consent. Where we rely on your consent, you have the right to withdraw it any time in the manner indicated when you consent or in the Privacy Policy.

YOUR RIGHTS

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

• Right of Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Right to Rectification. Update or correct inaccuracies in your personal information. We may refuse to change your data if the proposed change contains inaccurate information.
• Right to Erasure. Delete your personal information under certain circumstances.
• Right to Data Portability. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Right to Restrict Processing. Restrict the processing of your personal information.
• Right to Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to privacy@mannequin.com or our postal address provided above.

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.