Last Updated: February 2026

PURPOSE OF THE PRIVACY POLICY.

‍We are committed to respecting and protecting your privacy rights, and we created this Privacy Policy to give you (the user, Customer, or Creator) notice of how your personal information may be used by soona co. and its subsidiaries and affiliates (collectively, “soona,” “we,” “our,” or “us”) in connection with the online booking service, video and photography portal, and AI Studio, located at our website, www.soona.co, including all of its webpages and subpages (collectively, the “Platform”), and the software that may be downloaded to your computer, smartphone or tablet to access services either directly from soona or via third parties (each, an “Application”). 

soona creates for its brand customers (each a “Customer”) custom images, photos, videos, and other content and materials (the “Content”), and also connects its Customers with content creators (“Creators”) to generate custom Content. soona relies on a variety of independent creative contributors that work with soona to help create and refine the Content. Creators include artists, designers, developers, models, stylists, shoppers, hair and makeup artists, post-production professionals, and other valuable providers.  

For purposes of this Privacy Policy, the Platform, Applications, our related online and offline services, events, social media pages, and email and other electronic communications, and the Content creation services and other licensed services that we provide to you in connection with the Platform and Applications, are referred to collectively as the “Services”. 

In simplified form, our Privacy Policy can be summarized as follows. This summary highlights key points but does not include all details—please review the full Privacy Policy for complete information.

1. We collect personal information about you directly from you, automatically as you use our Services, and from third parties.
2. Our Services are not intended for children and we do not knowingly collect personal information from anyone under 18 years of age.
3. We use AI-powered tools and features to generate and optimize Content, provide personalized recommendations, improve your experience, and enhance our Services.
4. We disclose personal information to service providers and other third parties to provide the Services, comply with legal obligations, and for other purposes described in this Privacy Policy or at the point of collection.
5. We engage in interest-based advertising. We and our advertising partners use cookies and tracking technologies to collect information about your activity on our Services and other websites to show you personalized ads. Under California law, this may constitute a "sale" or "share" of your personal information.
6. You have rights and choices regarding your personal information. California, Nevada, and European users may have additional legal rights.
7. We process personal information in the United States. Privacy protections may differ from those in your home country, and by using our Services, you consent to these transfers where permitted by law.
8. We retain your information as long as necessary to provide Services, compy with legal obligations, resolve disputes, and prevent fraud.
9. We implement security measures designed to protect your personal information, though no method of transmission or storage is completely secure.

‍WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

WE COLLECT PERSONAL INFORMATION IN DIFFERENT WAYS.

WE USE PERSONAL INFORMATION FOR BUSINESS & COMMERCIAL PURPOSES.

WE USE REASONABLE EFFORTS TO PROTECT PERSONAL INFORMATION.

‍WE MAY DISCLOSE PERSONAL INFORMATION TO THIRD PARTIES.

‍YOU HAVE CERTAIN CHOICES ABOUT YOUR PERSONAL INFORMATION.

NOTICE TO CALIFORNIA RESIDENTS

NOTICE TO NEVADA RESIDENTS.

THE SERVICES ARE NOT INTENDED FOR CHILDREN.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION.

WE MAY LINK TO OTHER SITES OR THIRD-PARTY SERVICES.

NOTICE TO EUROPEAN USERS.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.

‍WE MAY UPDATE THIS PRIVACY POLICY.

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‍WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

‍We collect contact information and other identifying information. Depending on how you engage our Services, we may collect the following categories of personal information about you:

• Identifiers, such as name, email address, phone number, photo, avatar, and social media handle or profile;
• Biographical information about our Creators, such as date of birth and locale;
• Demographic information about our Creators, such as age, gender, race and ethnicity;
• Professional information, such as company name, location, website, social media pages, and other details about your company;
• Payment information such as billing name and address, credit or debit card number, or bank account information. All payment processing services connected with your use of the Services are provided to you by third-party payment processors. soona may access the last four digits of your credit card and expiration but does not access or keep full credit card numbers or information related to banking information or other sensitive financial information;
• Account information, such as log-in credentials, information that you store in your account, and other details about your use of the Services;
• Preferences, such as any preferences you set in your account, information about products or services considered and your interaction with the Services, and any marketing or communications preferences;
• Transaction history, such as records of products and services you have purchased from us;
• Survey responses, such as the information you provide in response to our surveys, questionnaires, or contests; 
• User submissions, including your ratings, tips, updates, alerts, comments, feedback, or any other information that you voluntarily provide. 
• Communications,  such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us. We and our service providers may record or monitor any call or chat you have with us for quality control or training purposes, or to enforce our rights.

We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

We collect information about your device and Internet usage. If you use the Services, we, our service providers, and our advertising partners collect information from your computer or device. We also collect information about the parts of our Services you use or third party apps or websites you visit when you leave our Services. Information collected automatically may include:

• Online activity information, such as the website you visited before browsing to the Services, 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 duration of access.
• Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.

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WE COLLECT PERSONAL INFORMATION IN DIFFERENT WAYS.

We collect information directly from you. For example, we collect information if you register on the Services or otherwise voluntarily submit it to us, such as by filling out a form on the Platform, participating in a survey, visiting us in-person at one of our studios, or communicating with us.

We collect information from you passively. For example, we, our service providers, and advertising partners may automatically collect information about you, your device, or your computer, like the online activity and device information described above. Our vendors might also use scripts or other tools to track your activities on our Services. Like many online services, we use cookies and similar technologies to facilitate some of this automatic data collection, such as:

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. 
• Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data. 
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
• Local storage, which is used to save data on a visitor’s device. We may use data from local storage to turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our services, remember your preferences, and measure ad effectiveness.
• Session-replay technologies, which are third-party software used to record a video replay of users’ interactions with the Services. The video replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Services, understand how users interact with and use the Services, and identify areas for improvement. 
• Chat technologies, which are chat features that you can use to communicate with us or, in some cases, a digital "chatbot" that will help respond to your inquiries. Our chat vendors and other third parties may access and use the online activity information and device information described above, and monitor and record your chats, for the purposes described in this Privacy Policy. When you use these features, please note that you may not be communicating with a human.

We may get information about you from third parties. For example, our affiliates or partners, service providers, advertising partners, data analytics partners, operating systems and platforms, event sponsors, data providers, or publicly available sources, may give us information about you. If our Services have social media or other app integrations, such third parties may also give us information about you. We may merge or combine such personal information with the personal information we collect from you directly or passively.

We collect information when you sign-on using third-party networks. We may offer single sign-on services that allow you to use third party login credentials to sign into the Services. soona may collect profile information contained in your third-party profile (e.g., name, profile picture, and any other information you have authorized the third party to share with applications). If you choose to use a third-party application or service (complementary or an authentication service), the use of your information will be governed by that third party’s privacy policy.

Referrals. Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.

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WE USE PERSONAL INFORMATION FOR BUSINESS & COMMERCIAL PURPOSES.

We use personal information to administer the Services that you request. We also use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.

We use personal information to provide the Services. We use personal information to provide our Services and operate our business. For example, we use personal information to: process your transactions, including purchasing products and services; establish, manage, monitor, and maintain your account; improve and personalize your experience on or with the Services; verify your identity or determine your eligibility for offers and promotions; provide any contests, surveys, sweepstakes, or other promotions you participate in; provide maintenance and support; and fulfill any other purpose for which you provide personal information.

We use personal information in connection with AI-enabled Services. We provide and use artificial intelligence (AI) enabled services or applications to enhance or help us provide the Services. For example, the Services include AI tools to: generate, edit, optimize, and analyze visual and written Content; provide recommendations and insights about Content performance, product listing optimization, and competitive positioning; enable image editing, background manipulation, and asset management features; review and analyze the personal information that we have collected about our users and Customers from various sources to better understand their needs or help us assess our relationship; enhance our outreach and identify products and services that may be of interest to current and future Customers; provide quicker, more efficient responses to your customer service requests; and improve and personalize your experience on or with the Services. When you interact with those tools, your personal information may be used to provide you with a response or to otherwise provide the output or feature for which AI is being used. Personal information may also be used to help improve the AI functionality that we use, such as to provide better responses or gain knowledge about the Services. Unless you receive a supplemental privacy policy relating to such services, your personal information will continue to be treated in the same ways that are described in this Privacy Policy.

We use personal information to respond to your requests or questions. For example, we might use your information to respond to your customer feedback.

We use personal information to communicate with you about your account or our relationship. We may contact you about our account or feedback. We might also contact you about this Privacy Policy or our Terms.

We use personal information to improve our products and services. We may use your personal information for research and development purposes, including to study and make our Services and products better, to understand and analyze the usage trends and preferences of our users, to train and improve the AI models and machine learning algorithms that power certain features and Services, and to develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. To the extent we maintain de-identified information, we commit to maintaining and using such information in de-identified form and not attempting to re-identify such information (except as permitted by applicable law). We may use this anonymous data and share it with third parties for our lawful business purposes.

We use personal information for security purposes. We may use personal information to protect our company, our customers, and our Services. For example, we may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Services, products, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce our Terms; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

We use personal information for direct marketing purposes. We may send you soona-related or other direct marketing communications by email or text as permitted by law. For example, we might provide you with information about new products and special offers from us. We might tell you about new features or updates. These might be third party offers or products we think you might find interesting. If you enroll in or are signed up for one of our text messaging programs, we will use the mobile phone number that you provide to send you messages, operate our texting and customer support program, and manage and monitor any choices or opt-outs that you may provide. No mobile information will be shared with third parties for marketing or promotional purposes, but such information may be shared with our service providers to provide texting services or as legally required. To manage or opt-out of direct marketing communications, read the choices section below.

We use personal information for interest-based advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our products and services. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above) over time across our Services and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. To manage this, read the choices section below.

We use personal information to comply with law. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

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

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WE USE REASONABLE EFFORTS TO PROTECT PERSONAL INFORMATION.

We maintain commercially reasonable administrative and technical safeguards to protect your personal information.  However, no method of transmission over the Internet, or method of electronic storage, is fully secure and we cannot guarantee the security of your personal information.

WE MAY DISCLOSE PERSONAL INFORMATION TO THIRD PARTIES.

We may disclose your personal information for the purposes and to the third parties set forth below and as otherwise described in this Privacy Policy or at the time of collection.

We will share personal information with individuals and companies that you have designated.  We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent.

We may share personal information with our vendors and partners. These are third parties who perform services on our behalf, such as those who help us to improve our Services and products, send emails or text messages for us, host our Platform, provide database or customer relationship management, provide fraud protection, provide marketing services, and other purposes.

We may share personal information with our advertising partners. These are third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in the “Interest-Based Advertising” section above.

We may share personal information with sweepstakes and joint marketing partners. When you choose to enter a contest or sign up for a sweepstakes, we may share the personal information you provide as part of the offer with the named co-sponsors or other third parties affiliated with such offer.  

We may share personal information if we think we have to in order to comply with the law or for security reasons. For example, we may share personal information to respond to a court order or subpoena. We may share personal information if a government agency or investigatory body submits a valid request to us. We might share personal information when we are investigating potential fraud or for the security or legal compliance purposes described above.

We may share personal information with our professional advisors. We may share personal information with persons, companies, or professional firms providing soona with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

We may share personal information as part of a business transaction. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

We may share your contact information with other users and the public. We may provide functionality that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to share your edited content, which may contain information about yourself, your product or service, or your use of the Services that you can make available to other users or the public. You may also be able to submit other content to the Services (such as comments, questions, stories, reviews, surveys, blogs, photos, and videos), and we will identify you by displaying information such as your name, username, social media handle, or a link to your user profile along with the content you submit. If you are a Creator, in connection with the creator services and pursuant to the Creator Terms of Service, your likeness or other personal information may be available on the Platform and used in Content. We do not control how other users or third parties use any personal information that you make available to other users or the public. 

We may share your personal information with related companies. We may share your personal information with our current or future affiliates, subsidiaries, and other related companies.

We may share personal information for other reasons we may describe to you.

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YOU HAVE CERTAIN CHOICES ABOUT YOUR PERSONAL INFORMATION.

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages (such as notices about your account or transaction, and responses to your questions).

You can review, update, and request the deletion of your account information. When you register for an account with us and submit personal information through the Services, you can access and update certain information by logging into your account or by contacting customer service. We may maintain a copy of the original version of your account information in our records and may keep historical information in our backup files as permitted by law. If you would like us to delete certain of your information or your account, please contact customer service. 

You can manage social network logins. If you use the social networking connection functions offered through the Services, you may manage the information that is shared with us through your social network accounts.

You can opt-out of SMS/text messages. We may offer communications via text messages sent by soona or any of our service providers, such as for customer service, account-related, or marketing purposes. To stop receiving text messages from us, reply STOP to any text message you receive from us, or send your request and mobile telephone number to the email address listed at the end of this Privacy Policy. Note that we may send you a message to confirm receipt of your STOP request.

You can control cookies. Our Services use cookies, tags, and similar tracking technologies to improve functionality, monitor site activity, remember who you are, and customize your user experience. These include our own first-party cookies as well as the third-party cookies. Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. 

You can opt out of analytics cookies. The Services use Google Analytics, among other analytics providers, to help us analyze how the Services are being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here. 

You can limit interest-based advertising. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (https://thenai.org/how-to-opt-out/), the Digital Advertising Alliance (https://optout.aboutads.info), or the European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/). Users of our App may opt out of receiving interest-based 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. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.

Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Our “Do Not Track” Policy. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents and supplements the practices described elsewhere in this Privacy Policy. For purposes of this section “personal information” has the meaning given in the California Consumer Privacy Act of 2018, as amended (the “CCPA”), but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.

Personal Information Collected and Purposes of Collection and Use. The list below summarizes the personal information we collect, or have collected in the 12 months preceding the last updated date of this Privacy Policy, by reference to the categories specified in the CCPA. Examples in the list refer to the types of personal information described in the section titled “We Collect Personal Information From and About You.” 

• Identifiers.
• Customer Records, such as account information, payment information, transaction history, user submissions, preferences, survey responses and communications.
• Protected Classifications, such as biographical and demographic information about our Creators.
• Internet or Network Activity, such as online activity information and device information.
• Audio, Electronic, and Visual Information, such as recorded customer service calls, chatbot communications and other recordings via AI-enabled features or Services, and other communications.
• Professional Information.
• Inferences, such as inferences drawn from the personal information identified above to create a profile reflecting your preferences, characteristics, or behavior.

We may collect these categories of personal information as described in the section titled “We Collect Personal Information In Different Ways.”

The purposes, including the specific business and commercial purposes, for which we collect and use these categories of personal information are described in the section titled “We Use Personal Information for Business & Commercial Purposes.” 

Personal Information Disclosed for a Business Purpose, “Sold,” or “Shared.” Each of the categories of personal information listed above may have been disclosed for business purposes in the preceding 12 months to any of the third parties set forth in this Privacy Policy under the section titled “We May Disclose Personal Information to Third Parties.” 

The CCPA defines a “sale” of personal information to mean when a business discloses a California resident’s personal information to a third party for monetary or other valuable consideration. Where a business discloses personal information for purposes of cross-context behavioral advertising (i.e., interest-based advertising), whether or not for monetary or other valuable consideration, it qualifies as “sharing” under the CCPA. 

In the 12 months preceding the last updated date of this Privacy Policy, we have “sold” or “shared” Internet or Network Activity, Identifiers, Customer Records, and Inferences to our advertising partners for purposes of advertising our Platform and Services (including tracking the success of our advertising campaigns) and measuring activity on the Platform and Services, as further described in this Privacy Policy as “interest-based advertising” under the section titled “We Use Personal Information for Business & Commercial Purposes.” We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.

Retention of Personal Information. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your California Privacy Rights. As a California resident, in addition to the choices described elsewhere in this Privacy Policy, you have the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

• Right to Know/Access. You can request the following information about how we have collected and used your personal information:
  
  • the categories of personal information we collected;
  • the categories of sources from which we collected personal information;
  • the business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information;
  • the categories of third parties with whom we disclose personal information; and
  • a copy of the personal information that we collected about you.
• Right to Delete. You can request that we delete the personal information we collected from you.
• Right to Correct. You can request that we correct inaccurate personal information that we maintain about you.
• Right to Opt-Out of Sales/Sharing. If we “sell” or “share” your personal information, you can opt-out. 
• Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment. 

How to Exercise Your Rights. You may exercise the rights described above as follows:

• Know/Access, Delete, or Correct. You may exercise these California privacy rights by emailing legal@soona.co.

If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your right to know/access, delete, and correct. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request. 

Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests to know/access, delete, and correct within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

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NOTICE TO NEVADA RESIDENTS.

Nevada Revised Statutes Chapter 603A 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. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy.

THE SERVICES ARE NOT INTENDED FOR CHILDREN.

Our Services are meant for adults. We do not knowingly collect personal information from individuals under 18.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION.

Personal information we collect is processed and stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States and potentially other countries outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.

Users located in Europe can view more information about cross-border transfers in the section below titled “Notice To European Users.” 

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WE MAY LINK TO OTHER SITES OR THIRD-PARTY SERVICES.

Our Services may have links to websites or other online services we do not control. Our Services may also have plugins or host other third party services that we don’t control. This Privacy Policy does not apply to the privacy practices of those websites or third parties. When you interact with those websites or third parties, they may collect information from you. Read the privacy policy of other websites and online services carefully. We are not responsible for these third party practices.

NOTICE TO EUROPEAN USERS.

The information provided in this section applies only to individuals in the European Economic Area, the United Kingdom, and Switzerland (for purposes of this Privacy Policy, collectively, “Europe”). Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. 

Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is soona co., 1235 S. Broadway, Denver, Colorado 80210, USA.

Legal Bases for Processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact as provided at the end of this Privacy Policy.

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We may use personal information for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

We retain personal information to fulfill the purpose of collection. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights. European data protection laws may give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Port. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• 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 contacting us at legal@soona.co. We may request specific 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. 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. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at legal@soona.co for further information about any such transfers or the specific safeguards applied.

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FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.

If you have any questions about this Policy or want to correct or update your information, please email us at legal@soona.co.  

You can also write to us at: soona Co., 1235 S. Broadway, Denver, Colorado 80210.

‍WE MAY UPDATE THIS POLICY.

This Privacy Policy may be updated from time to time. We will notify you of any material changes to our Privacy Policy as required by law. We will also post an updated copy on our Services. Please check this page periodically for updates. In all cases, your continued use of the Services following posting or other notification of changes constitutes your acknowledgement of such changes.

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