Polarr Privacy Policy
Last Updated: February 15, 2022

Polarr provides a variety of different digital offerings including but not limited to websites, mobile
applications for photo and video editing tools, photo and video filter creation tools and a
community for users to share their creations with each other.

Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use
and share your personal information and to assist you in exercising the privacy rights available
to you.

SCOPE
This Privacy Policy applies to personal information processed by us in our business, including
on our websites, mobile applications, and other online or offline offerings (collectively, the
“Services”).

I. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on whether you are a customer, user,
applicant or visitor, and the requirements of applicable law.

Information You Provide to Us.

Account Creation: You may use some of Polarr’s Services and features without creating an
account. If you choose to create a user account, we may collect information from you
including your name, email address, phone number, user name, and password. If you
choose to subscribe to our Services or purchase from us, we will also collect your payment
information. Note that we do not receive or store your payment information on our
systems—this information goes directly to our payment processor.

Your Communications with Us. We collect personal information from you such as email
address, phone number, or mailing address when you request information about our
Services, register for our newsletter, request customer or technical support, apply for a job
or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, you
may be asked to provide certain information which may include personal information.

Social Media Content. We may offer forums, blogs, or social media pages. Any content
you provide on these channels will be considered “public” and is not subject to privacy
protections.

Registration for Sweepstakes or Contests. We may run sweepstakes and contests.
Contact information you provide may be used to reach you about the sweepstakes or
contest and for other promotional, marketing and business purposes, if permitted by law. In
some jurisdictions, we are required to publicly share information about winners.

Information Collected Automatically or From Others

Automatic Data Collection. We may collect certain information automatically when you
use the Services. This information may include your Internet protocol (IP) address, user
settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other
unique identifiers, details about your browser, operating system or device, location

information, Internet service provider, pages that you visit before, during and after using the
Services, information about the links you click, and other information about how you use the
Services. Information we collect may be associated with accounts and other devices.

In addition, we may automatically collect data regarding your use of our Services, such as
the types of content you interact with and the frequency and duration of your activities. We
may combine your information with information that other people provide when they use our
Services, including information about you when they tag you.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based
Advertising technologies. We, as well as third parties that provide content, advertising, or
other functionality on the Services, may use cookies, pixel tags, local storage, and other
technologies (“Technologies”) to automatically collect information through the Services.
Technologies are essentially small data files placed on your computer, tablet, mobile phone,
or other devices that allow us and our partners to record certain pieces of information
whenever you visit or interact with our Services.


II. HOW WE USE YOUR INFORMATION.

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:
Analyze and improve our Services pursuant to our legitimate interest, such as:
Provide you with additional content and Services, such as:
Automated profiling. We may use technologies considered automated decision making or
profiling. We will not make automated decisions about you that would significantly affect you,
unless such a decision is necessary as part of a contract we have with you, we have your
consent, or we are permitted by law to use such technology. You may escalate any concerns
you have by contacting us below.

Use De-identified and Aggregated Information. We may use personal information and other
data about you to create de-identified and aggregated information, such as de-identified
demographic information, de-identified location information, information about the computer or
device from which you access our Services, or other analyses we create.

Share Content with Friends or Colleagues. Our Services may offer various tools and
functionalities. For example, we may allow you to provide information about your friends
through our referral services. Our referral services may allow you to forward or share certain
content with a friend or colleague, such as an email inviting your friend to use our Services.

Face and Facial Landmark Data. We do not, under any circumstances transfer or otherwise
use your face and/or facial landmark data for anything other than locating your face and facial
landmark in the photo or video editing process.

How We Use Automatic Collection Technologies. We, as well as third parties that provide
content, advertising, or other functionality on the Services, may use cookies, pixel tags, local
storage, and other technologies to automatically collect information through the Services. Our
uses of these Technologies fall into the following general categories:
Notice Regarding Third Party Websites, Social Media Platforms and Software
Development Kits. The Services may contain links to other websites, and other websites may
reference or link to our website or other Services. These other websites are not controlled by
us. We encourage our users to read the privacy policies of each website and application with
which they interact. We do not endorse, screen or approve and are not responsible for the
privacy practices or content of such other websites or applications. Visiting these other
websites or applications is at your own risk.
Our Services may include publicly accessible blogs, forums, social media pages, and private
messaging features. By using such Services, you assume the risk that the personal information
provided by you may be viewed and used by third parties for any number of purposes. In
addition, social media buttons such as Instagram, Facebook, and Twitter (that might include
widgets such as the “share this” button or other interactive mini-programs) may be on our site.
These features may collect your IP address, which page you are visiting on our site, and may
set a cookie to enable the feature to function properly. These social media features are either
hosted by a third party or hosted directly on our site. Your interactions with these features apart
from your visit to our site are governed by the privacy policy of the company providing it.
We may use third party application programming interfaces (“APIs”) and software development
kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties
including analytics and advertising partners to collect your personal information for various
purposes including to provide analytics services and content that is more relevant to you. For
more information about our use of APIs and SDKs, please contact us as set forth below.

III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.

Except as provided below, we do not disclose your personal information.
We have not sold consumers’ personal information in the preceding 12 months.

Service Providers. We may share any personal information we collect about you with our
third- party service providers. The categories of service providers (processors) to whom we
entrust personal information include: IT and related services; information and services; payment
processors; customer service providers; and vendors to support the provision of the Services.

Business Partners. We may provide personal information to business partners with whom we
jointly offer products or services. In such cases, our business partner’s name will appear along
with ours.

Affiliates. We may share personal information with our affiliated companies.

Advertising Partners. Through our Services, we may allow third party advertising partners to
set Technologies and other tracking tools to collect information regarding your activities and
your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We
may also combine and share such information and other information (such as demographic
information and past purchase history) with third party advertising partners. These advertising
partners may use this information (and similar information collected from other websites) for
purposes of delivering targeted advertisements to you when you visit third party websites within
their networks. This practice is commonly referred to as “interest-based advertising” or “online
behavioral advertising. We may allow access to other data collected by the Services to share
information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer
not to share your personal information with third party advertising partners, you may follow the
instructions below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information
we store associated with you to external parties if we, in good faith, believe doing so is required
or appropriate to: comply with law enforcement or national security requests and legal process,
such as a court order or subpoena; protect your, our or others’ rights, property, or safety;
enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or
prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a
merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase
or sale of assets, or transition of service to another provider, then your information may be sold
or transferred as part of such a transaction, as permitted by law and/or contract.

International Data Transfers. You agree that all information processed by us may be
transferred, processed, and stored anywhere in the world, including but not limited to, the United
States or other countries, which may have data protection laws that are different from the laws
where you live. We have taken appropriate safeguards to require that your personal information
will remain protected and require our third-party service providers and partners to have
appropriate safeguards as well. Further details can be provided upon request.

IV. YOUR CHOICES.

General.
You have certain choices about your personal information. Where you have consented to the
processing of your personal information, you may withdraw that consent at any time and prevent
further processing by contacting us as described below. Even if you opt out, we may still collect
and use non- personal information regarding your activities on our Services and for other legal
purposes as described above.

Email and Telephone Communications.
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom
of the email to opt out of receiving future emails. Note that you will continue to receive
transaction-related emails regarding products or Services you have requested. We may also
send you certain non-promotional communications regarding us and our Services, and you will
not be able to opt out of those communications (e.g., communications regarding the Services or
updates to our Terms or this Privacy Policy).
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as
required by applicable law.

Mobile Devices.
We may send you push notifications through our mobile application. You may at any time opt
out from receiving these types of communications by changing the settings on your mobile
device. We may also collect location-based information if you use our mobile applications. You
may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track.”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.
Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted
by web browsers.

Cookies and Interest-Based Advertising.
You may stop or restrict the placement of Technologies on your device or remove them by
adjusting your preferences as your browser or device permits. The online advertising industry
also provides websites from which you may opt out of receiving targeted ads from data partners
and other advertising partners that participate in self-regulatory programs. You can access
these and learn more about targeted advertising and consumer choice and privacy, at
www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/,
https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices
for mobile apps on a mobile device, you can download DAA’s AppChoices application from your
device’s app store. Alternatively, for some devices you may use your device’s platform controls
in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements
on third party websites that contain the AdChoices link may have been directed to you based on
information collected by advertising partners over time and across websites. These
advertisements provide a mechanism to opt out of the advertising partners’ use of this
information for interest-based advertising purposes.

Your Privacy Rights.

In accordance with applicable law, you may have the right to:


If you would like to exercise any of these rights, please contact us as set forth below. We will
process such requests in accordance with applicable laws. To protect your privacy, we will take
steps to verify your identity before fulfilling your request.

V. DATA RETENTION.

We store the personal information we receive as described in this Privacy Policy for as long as
you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide
our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate
business purposes, enforce our agreements, and comply with applicable laws.

VI. SECURITY OF YOUR INFORMATION.

We take steps to ensure that your information is treated securely and in accordance with this
Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the
security of any information you provide to us. To the fullest extent permitted by applicable law,
we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may
communicate with you electronically regarding security, privacy, and administrative issues
relating to your use of the Services. If we learn of a security system’s breach, we may attempt
to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail
to you.

VII. CHILDREN’S INFORMATION.

The Services are not directed to children under 13 (or other age as required by local law), and
we do not knowingly collect personal information from children. If you learn that your child has
provided us with personal information without your consent, you may contact us as set forth
below. If we learn that we have collected any personal information in violation of applicable law,
we will promptly take steps to delete such information and terminate the child’s account.

VIII. OTHER PROVISIONS.

SUPERVISORY AUTHORITY.

If you are located in the European Economic Area or the UK, you have the right to lodge a
complaint with a supervisory authority if you believe our processing of your personal information
violates applicable law.

CHANGES TO OUR PRIVACY POLICY.

We may revise this Privacy Policy from time to time at our sole discretion. If there are any
material changes to this Privacy Policy, we will notify you as required by applicable law. You
understand and agree that you will be deemed to have accepted the updated Privacy Policy if
you continue to use the Services after the new Privacy Policy takes effect.

IX. CONTACT US.

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to
submit a request to exercise your rights as detailed in this Privacy Policy, please contact us
here.

X. IMPORTANT INFORMATION REGARDING EUROPE

This section applies to individuals in the European Economic Area and the United Kingdom.
Controller: Polarr, Inc. is the controller of the personal data that we have about you and can be
reached at: 75 E Santa Clara St. STE 900, San Jose, CA 95113 or through email.
Your rights. You may ask us to take the following actions:
To request one of these actions, contact us. We may request information from you to help us
confirm your identity and process your request. Applicable law may require or permit us to
decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
Marketing emails. You can always opt out of our marketing emails by following the unsubscribe
prompt in the message. You may still receive administrative or other non-marketing messages.
Legal bases. We generally process your personal data on the following legal bases:
XI. IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

Scope. This addendum supplements our Privacy Policy and applies only to California residents
and the Personal Information we collect about them as a “business,” as defined under the
California Consumer Privacy Act of 2018 (“CCPA”). For purposes of this section, “Personal
Information” has the meaning given in the CCPA but does not include information exempted
from the scope of the CCPA. Additionally, this section does not apply to information we collect
from you in the course of communicating with you in your capacity as an employee, controlling
owner, director, officer or contractor of an organization (i.e., company, partnership, sole
proprietorship, non-profit or government agency) while we are providing or receiving products or
services to or from, or performing due diligence on, that organization.
Collection, use and disclosure of your Personal Information. For each category of data
described above in Section 1 and Section 2 of this Privacy Policy, the following list describes the
corresponding statutory categories of Personal Information specified by the CCPA in California

Civil Code § 1798.140(o), the sources of that Personal Information, and the
business/commercial purposes for collecting that Personal Information, as further described in
Section 1 and Section 2: