QOOB SEARCH, LLC

This Privacy Policy describes how QOOB SEARCH, LLC (“we”, “us,” “our” or the “Company”) collects, uses and discloses information about individuals who use our website theqoob.com to access our proprietary software application and/or hardware product known as qoob (the “Beta Product”), other applications, services, tools and features, or who purchase our products or otherwise interact with us (collectively, the “Services”).

For the purposes of this Privacy Policy, we are the data controller, and “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, job applicant, representative of a company with whom we do business, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access the Services.

Remember that your use of Services is always subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

1. Changes to This Privacy Notice

We may modify this Privacy Policy from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Policy. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not continue using or accessing the Services.

2. Collection and Use of Your Information

When you use or access the Services, we collect certain categories of information about you from a variety of sources. We use the Content you provide—including prompts, inputs, and uploaded files—to train, test, and improve our artificial intelligence models and machine learning technologies. This processing helps us refine the accuracy and performance of our Services for all users. While you may opt out of having your Content used for training through your account settings, doing so may limit our ability to tailor the Services to your specific needs.

Information You Provide to Us:

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• Basic contact details, such as name, address, phone number, and email (“Contact Information”).
• Account information, such as name, username, email and password (“Account Information”). If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately at support@theqoob.com.
• Payment information, such as credit or debit card information and billing address, which we may collect using a third party payment processor (“Payment Information”).
• Your input and output, such as questions, prompts and other content that you input, upload or submit to the Services, and the output that you create, and any collections or pages that you generate using the Services (“Service Interaction Information”). This content may constitute or contain personal information, depending on the substance and how it is associated with your account. If you make content publicly available or share content with third parties, please note that it may be stored, displayed, reproduced, published, or otherwise used or disclosed without your permission, and may or may not be attributed to you.
• Any other information you choose to include in communications with us when necessary to perform our contract with you, for example, when sending a message through the Services or providing your size when purchasing certain products (“Other Information You Provide”).

Information Collected Automatically:

We and certain third parties also automatically collect certain information about your interaction with the Services (“Usage Data”) through the use of cookies, pixels, tags and other tracking technologies (“Tracking Technologies”). Usage Data includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Location information, such as approximate location.
• Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, interactions with marketing emails, and ad impressions.

We use Usage Data in our legitimate interests to tailor features and content to you, run analytics and measure and better understand user interaction with the Services, and we may permit third parties to use Usage Data for such purposes. For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected From Other Sources:

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:

• Analytics data we receive from analytics providers such as Google Analytics (“Analytics Information”).
• Information we receive from consumer marketing databases or other data enrichment companies (“Advertising Information”).
• Information we receive from business partners and other companies that we partner with to provide you with free or discounted access to the Services or other offers or promotions (“Partner Information”).
• Information we receive when you choose to link any third-party platforms to your account, such as when you sign into your account through Google or Apple (“Third Party Platform Information”). Third Party Platform Information may include your name, profile picture and email address.
• Information from publicly accessible sources, such as information that's publicly available online (like articles, websites, and journals) or from other public sources (“Public Information”).

In addition to the specific uses described above, we may use any of the above information to provide you with and improve the Services and to maintain our business relationship, including by enhancing the safety and security of our Services, providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, and conducting internal research and development.

We may use the information we collect to conduct research and develop new products, hardware, and features that enhance the Company ecosystem. This includes analyzing user interactions to design and launch future proprietary hardware devices and software applications. We may also use publicly available information to assist in the training of new AI models and the development of cross-platform features.

We may also use the information to comply with applicable legal obligations, enforce any applicable terms of service, and protect the Services, our rights, and the rights of our employees, users or other individuals.

You may also have the ability to sync your third party email account or calendar (such as Gmail and Google Calendar) with the Services. If you choose to sync these accounts, we will have access to your contacts and information from the email messages and calendar appointments in your email account, including the content of your emails (together, “Email Service Information”). Notwithstanding anything else in this Privacy Policy, we only use and disclose Email Service Information to provide the Services or as otherwise required by applicable law, and we do not use or disclose Email Service Information to create, train, improve or fine-tune AI models. If you sync your Google account with the Services, we only use and disclose information from your Google account in accordance with the Google API Services User Data Policy, including the Limited Use requirements.

Finally, we may, in our legitimate interests, deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (“Deidentified Information”) (or we may collect information that has already been deidentified/anonymized), and we may use such Deidentified Information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified/anonymized form and not attempt to reidentify the information, except solely for the purpose of determining whether our deidentification/anonymization process satisfies legal requirements.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third Party Websites and Links. To the extent the laws in your jurisdiction do not recognize the legal basis of legitimate interest or another legal basis specified above for a particular purpose, you consent to the processing of your personal data for that purpose through using the Services.

Our Services utilize probabilistic algorithms and large-scale language models to predict and generate content. Because these models function by predicting the most likely next sequence of data, outputs may occasionally be factually inaccurate, incomplete, or otherwise unreliable. You should not rely on the factual accuracy of any generated output and are responsible for independently verifying any information provided by the Services.

3. Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser or limit cross-site tracking; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

To opt out of tracking by Google Analytics, click here.

Your browser settings may allow you to transmit a ‘do not track’ signal. Like many websites, our website is not designed to respond to such signals. To learn more about ‘do not track’ signals, you can visit http://www.allaboutdnt.com/.

4. Disclosure of Your Information

We may disclose your information to third parties subject to this Privacy Policy, including the following categories of third parties:

• Company Group: Our parents, subsidiaries, affiliates or others within our corporate group, in accordance with our contract with you, and for internal administration or support purposes, in our legitimate interest to run a successful business and in order to provide our Services.
• Service Providers: Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, generative AI and content creation, security, customer transaction facilitation and relationship management, marketing communications, web analytics, payment networks, and payment processing.
• Business Partners: Third parties through whom you receive access to our Services, including via use of a promotion code or other method provided by such business partners, in our legitimate interest to provide you with free or discounted access to our Services.
• Other Third Parties, including other users: Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integrations, when you purchase third-party goods through the Services, send an email or interact with your third party email or calendar account through the Services, or otherwise choose to share or make output or other information visible to others, including other users. We do this as necessary for the performance of a contract, or in our legitimate interest to provide you with access to the Services and integrations with third parties, or with your consent.
• Advertising Partners: Third parties who display advertising information on our Services or otherwise assist with the delivery of ads.
• Professional Advisors: As necessary, we will share your personal data with professional advisors such as auditors, law firms, or accounting firms.
• Business Transactions: We will share personal information with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, asset sale or purchase, bankruptcy or other business transaction or re-organization. We do this in our legitimate interest to run a successful and compliant business, and as required by applicable law.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users. We do this in our legitimate interest to protect our Service and business and to comply with applicable law.

5. Social Features

Certain features of the Services may allow you to initiate interactions between the Services and third-party services or platforms, such as Discord, X, and other social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms, and from there ‘like’ or ‘share’ our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third Party Websites and Links.

6. Third Party Websites and Links

We may provide links to third-party websites or platforms, such as Discord and X. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

7. Children's Privacy

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children, particularly those under 13 years of age or in the case of a region where the minimum age for processing personal information differs, such different age. For users above the age of 13 but below the age where you are able to consent to the processing of your personal information, please obtain your parent or guardian's consent prior to using the Services.

If we become aware that we have unknowingly collected information about a child under 13 years of age or the relevant minimum age in your jurisdiction, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under the relevant minimum age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

8. Data Security and Retention

We seek to protect your personal data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain personal data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your personal data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the personal data, why we collected the personal data, and the sensitivity of the personal data. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

In addition, we may retain certain personal data for longer periods when necessary for legitimate business or legal purposes. This includes retaining data for financial record-keeping, resolving disputes, internal auditing, and ensuring the safety and security of our systems. Furthermore, we retain a record of data erasure requests to verify and maintain our compliance with your privacy rights.

We may offer features such as “Temporary Sessions” or “Private Modes” that allow you to interact with the Services without the content being saved to your account history. Interactions within these sessions are generally not used to train our AI models. However, we may still retain logs of these interactions for up to 30 days for safety, security, and abuse-prevention purposes before they are permanently deleted or de-identified.

9. Your Rights and Choices

Depending on where you live, you may have some or all of the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to Access / Know. You may have a right to request access to personal information that we hold about you, or to request information about our collection, use and disclosure of your personal information, such as the categories of personal information we have collected or disclosed for a business purpose.
• Right to Delete. You may have a right to request that we delete personal information we maintain about you.
• Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
• Right of Portability. You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party.
• Restriction of Processing. You may have the right to ask us to stop, suspend or restrict our processing of personal information.
• Objection. You may have the right to object to our processing of personal information.
• Withdrawal of Consent. Where we rely on consent to process your personal information, you may have the right to withdraw this consent at any time by contacting us at support@theqoob.com. Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal, and that where you withdraw your consent, we may not be able to deliver the expected service to you.

You may choose to stop receiving personalized advertising or marketing promotions from us when using the Services by contacting us at our email address provided below.

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address and government issued ID, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. If we deny your request, you may appeal our decision by contacting us using the information provided below. You may opt out of information collection for AI (which would prohibit us from using your search information to improve our AI models) in your settings page if you are logged into the Services. You may also request to delete your account through the settings page or by contacting us at support@theqoob.com. If you delete your account, we aim to delete your personal information from our servers within 30 days. Please contact us at support@theqoob.com to request deletion.

10. U.S. Residents

This section supplements the other sections of this Privacy Policy and applies to you only if you are a resident of California or another U.S. state that has passed a privacy law similar to the California Consumer Privacy Act (“CCPA”) that applies to us, and the law requires specific privacy notice disclosures. For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the CCPA.

Processing of Personal Information:

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information and sensitive personal information (denoted by *) about residents:

• Identifiers, such as name, e-mail address and IP address
• Personal information categories listed in the California Customer Records statute such as name, address and telephone number
• Commercial information such as records of products or services purchased
• Internet or other similar network activity such as usage data
• Geolocation data such as IP address
• Professional or employment-related information such as title of profession, employer, professional background and other information provided by you when you apply for a job with us
• Non-public education information collected by certain federally funded institutions such as education records that you provide when you apply for a job with us
• Account access credentials* for the Services
• The contents of email messages in the email inboxes that you connect to your account, and the content of email messages you send through Qoob*

The specific business or commercial purposes for which we have collected and disclosed your personal information and the categories of sources from which we collect your personal information are described in the section above, Collection and Use Your Information. The third parties that we have disclosed your information to are described in Section 4 (Disclosure of Your Information) above. We only use and disclose sensitive personal information for the purposes specified in the CCPA or otherwise in line with your consent. The criteria we use to determine how long to retain your personal information is described in the section above, Data Security and Retention.

Selling and/or Sharing of Personal Information:

We do not “sell” or “share” (as those terms are defined under the CCPA / CPRA) personal information, nor have we done so in the preceding 12 months. We do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

When you visit our Services we may load the Meta (Facebook) advertising pixel and the TikTok Pixel for conversion measurement, and we may transmit corresponding events to Meta’s Conversions API and TikTok’s Events API. Every Meta event is transmitted under Meta’s Limited Data Use mode (parameter data_processing_options=["LDU"]), and every TikTok event is transmitted under TikTok’s equivalent Limited Data Use mode — via data_processing_options=["LDU"] on browser Pixel events and the corresponding limited_data_use: true flag on server-side Events API calls. These restrictions contractually limit Meta and TikTok to acting as our service providers for limited purposes. Under those restrictions, neither Meta nor TikTok uses your data to personalize advertising, build retargeting or lookalike audiences, or train its advertising models. As a result, the transmissions are not a “sale” or “share” under the CPRA. Pursuant to California Civil Code § 1798.135(c)(4), because we do not sell or share personal information and we state this in our Privacy Policy, we are not required to provide a “Do Not Sell or Share My Personal Information” link on our website.

Other vendors that receive personal information — including Amplitude (product analytics), Sentry (error monitoring), Google Analytics (website analytics, configured without ad personalization features), and our cloud hosting providers (Google Cloud / Firebase) — act as our service providers under written data processing agreements. They are contractually restricted from using your data for their own advertising or other independent purposes, and their receipt of data is not a sale or share under the CPRA.

Your Privacy Rights:

Depending on your state of residence, you may have the right to know what personal information we have collected, request a copy, request correction or deletion, opt out of the sale or sharing of personal information for cross-context behavioral advertising, and limit our use of sensitive personal information. To exercise any of these rights, email privacy@aprenew.com. We will not deny service, charge different prices, or provide a different level of service because you exercised your rights.

California Account Holders Under 18:

Any California residents under the age of eighteen (18) who have registered to use the Services and who have posted content or information available to others on the Services can request that such information be removed from the Services by contacting us at the e-mail address set forth in the section below, How to Contact Us. Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

11. Data Transfers

The personal information that we collect will be transferred to, stored at/processed in, or accessed from countries outside the jurisdiction in which you are based in, for the purposes described in this Privacy Policy, including countries in which our service providers or other third parties are located. Specifically, we have servers for the Service in the US. We also have support, engineering and other teams who may support the Service, including from the United States.

We process the personal information that you provide to us by creating an account and using our Services in countries outside the relevant jurisdiction you are resident in in order to perform our contract with you (to provide you with our Services). By using the Services and acknowledging the Privacy Policy, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified herein. For such transfers of data outside the relevant jurisdiction we will use applicable safeguards, for example, for UK and EEA users, the European Commission's model contracts for the transfer of personal information to third countries (i.e., the standard contractual clauses) (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals' rights and freedoms for their personal information. Please contact us at support@theqoob.com should you wish to inquire further as to such data transfer mechanisms.

12. Complaints

If you have complaints about how we process your personal information, please contact us at support@theqoob.com, and we will respond to your request as soon as possible.

If you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the country in which you live or work or where you think we have infringed data protection laws.

13. How to Contact Us

Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@theqoob.com.

14. Language

Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Policy, the English language version will prevail.