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CONCEPTIV

Read the End User License Agreement here.

Last Updated: January 12, 2023

We at Conceptiv have created this Privacy Policy to explain how we collect, use,
disclose and otherwise process personal information in connection with operating
our business. Conceptiv, LLC. is a subsidiary of Apalon, LLC. (“Apalon”, "we",
"us" and "our"). Apalon is the controller of your personal data. This Privacy
Policy describes the practices concerning the information collected by us
through the use of our websites and mobile applications on which this Privacy
Policy is posted.

This Privacy Policy applies to our websites and mobile applications and other
online services we may provide on which this Privacy Policy is posted, and our
collection of information from our corresponding social media features and pages
(each a "Service" and collectively, the "Services"). In addition to describing
how we collect, use, disclose and otherwise process personal information, this
Privacy Policy explains the rights and choices available to individuals with
respect to their personal information.

We may provide additional privacy notices to you at the time we collect your
data. This type of an "in-time" notice will govern how we may process the
information you provide at that time.

California residents, please see section 8 for more information on Your
California Privacy Rights. Mainland China residents, please see section 9 for
more information on Your Privacy Rights

Click on the links below to jump directly to sections of the Privacy Policy:

1. Information We Collect
2. Sources of Information and Purposes of Use
3. How We May Use Your Personal Information
4. How We May Share Information about You with Others
5. Do Not Track Disclosures
6. Social Media and other Communications
7. Information for Individuals in the European Economic Area
8. Information for Residents of California

9. Information for Residents of Mainland China
10. Online Privacy Choices and Rights
11. Data Retention
12. How We Protect Personal Information
13. Links to Websites and Third-Party Content
14. Information Relating to Children
15. Updates to Our Privacy Policy
16. How to Contact Us


1. INFORMATION WE COLLECT

We may obtain information about you in a variety of ways, including through your
use of our Services, when you call, email or otherwise communicate with us
(including through social media), or when you participate in events or other
promotions.

The information that we collect, whether from you directly or automatically, may
be considered personal information in certain jurisdictions or personal data
under the European General Data Protection Regulation (the "GDPR"). Whenever we
refer to personal information in this Privacy Policy, it means personal
information or personal data as defined by applicable laws in the relevant
jurisdiction.

Categories of personal information we collect, which may vary based on the
Service being used:

Category Specific Examples A. Identifiers. A real name, alias, unique personal
identifier, online identifier, IP address, email address, account or other
similar identifiers. B. Personal Records. Name, Email address and username. Some
personal information included in this category may overlap with other
categories. C. Internet or other similar network activity. Information on a
consumer’s interaction with a website, application, or advertisement. See
Information collected by Automated Means below for further details. D.
Geolocation data. Physical location or movements. E. Sensory data. Audio,
electronic, visual, or similar information. F. Commercial information. Records
of products or services purchased, obtained or considered, or other purchasing
or consuming histories or tendencies. G. Inferences drawn from other personal
information. Profile reflecting a person's preferences, characteristics, and
behavior.

Please note that when using certain Services, you may choose to input or provide
access to certain physical or health-related information about yourself. Such
information will be stored locally on your device and accessed only as described
in the "Information collected from you" subsection below.

2. SOURCES OF INFORMATION AND PURPOSES OF USE

Some of this information you provide to us and some we collect when you use our
Services. We also may obtain information about you (including personal
information) from our business partners, such as vendors, and others.

You may choose not to provide some or all of your personal information to us but
doing so may prevent us from providing our Services to you or limit our ability
to provide you with the level of service that you would otherwise expect from
us.

Information collected from you

The following are examples of the types of information we may collect directly
from you:

 * Feedback: From time to time, we may request your opinions, suggestions, or
   modification and improvement ideas ("Feedback") through surveys, or other
   similar requests. Any responses you provide are voluntary.
 * Name: We require your name to personalize your user experience.
 * Telephone number: We may require your phone number for the technical
   provision of our Services to you.
 * Email address: We use your email address to communicate with you about the
   products and Services we offer, responding to requests, inquiries, comments,
   and suggestions and updating you with information about your account.
 * Username and/or PIN: Certain of our Services use this information to
   facilitate your access to our website or mobile application and validate your
   login for your security.
 * Other User Information: When using certain Services, you may choose to input
   or provide access to certain information about yourself, such as photographs,
   physical and health related information, or other information to enhance your
   experience of the Services we provide. This information will be stored on
   your device and will not be transmitted to us unless we notify you otherwise
   at the time of entering the information or granting access to the
   information.
 * Location Information: When you use our Apps, we and our third party partners
   may detect your general location (e.g., city and state). Additionally, we may
   also collect precise location data (e.g., longitude/latitude) but only when
   you consent within the app to sharing your precise location. Failure to
   provide such information will only prevent you from using the features of the
   app that require your precise location, or obtaining results that the service
   intends to provide you with based on your location information, but will not
   affect your use of other features. You authorize us and our third party
   partners to collect and use your location information. We may use location
   information to operate and enhance our service as well as customize the
   content, weather alerts, and advertising we provide to you. For Apps with
   advertisements, if you have enabled location tracking, our trusted
   third-party partners may also collect and use location data to customize
   advertisements shown to you. See Marketing Opt-Outs in Section 9 of this
   Privacy Policy for more information on how to opt-out of receiving relevant
   advertising.
 * Payment Information: In the event you purchase products or Services directly
   from us, we, or a third party on our behalf, may collect payment card and
   other payment information, solely as required to process payment for such
   purchase. If you pay for Services directly through our website, you authorize
   us to have our payment processor collect this information. Your failure to
   provide such information may prevent you from using our services.
 * Photograph: Photograph or photographs you may provide to the Services. Your
   photographs and pictures will remain on your device and will not be
   transmitted to us unless we notify you otherwise at the time of your sharing
   of those photos.

Information collected by automated means ("Automated Information")

We may collect Automated Information through the use of cookies, and other
technologies. Please see our Cookies Policy for more information on cookies. In
addition to cookies, such other technologies may include:

 * "Pixel tags" (also known as a "clear GIFs" or "web beacons") which are tiny
   images (in most cases, typically just one-pixel) that can be placed on a Web
   page or in our electronic communications to you in order to help us measure
   the effectiveness of our content by, for example, counting the number of
   individuals who visit us online or verifying whether you've opened one of our
   emails or seen one of our Web pages.
 * "HTML5" (the language some websites, such as mobile websites, are coded in)
   may be used to store information on your computer or device about your
   website usage activities and to help determine how our Services are being
   used by our visitors, how the services can be improved and to customize our
   Services for our users.

The above tracking technologies may be deployed by us or our service providers
on our behalf. You can find more information on our third-party service
providers in Section 3 of this Privacy Policy.

Automated Information includes information such as:

 * IP address
 * Operating system used (for example: iOS)
 * Internal resolution of the browser window
 * Device type
 * Country code
 * Identifiers associated with technologies that may uniquely identify your
   device or browser (e.g., IMEI/UDID and MAC address)
 * Dates and times of access
 * IDFA
 * Subscription information
 * Latitude/longitude (if you allow location tracking)
 * AdvertisingID (such as Google’s AdvertisingID and Apple’s IDFA, both of which
   are randomly generated numbers that you can reset by going into your device’s
   settings)
 * Adjust ID (this identifier lets us know where our users found our Services
   online, record user app events and optimize our advertising efforts)

We or our third-party service provider may assign you a unique identifier
through automated means in order to match information collected from you through
different means or at different times, (including both personal information and
Automated Information) and to use such information as described in this Privacy
Policy.

This Automated Information is generally used for the following purposes:

 * for the technical provision of our Services in order to be able to provide
   you with a functioning user-friendly experience
 * to provide you with a secure experience and to take measures to protect our
   website and mobile applications from cyber risks
 * to uncover insights about your use of our website and mobile applications in
   order to improve our Services and features, including developing new products
   and features
 * to facilitate your access to our website or mobile application
 * to customize our Services for you
 * to help us better understand our current and potential customers so that we
   may market our Services accordingly
 * events and usage data are captured for our internal business analytics in
   order to understand how our users interact with our mobile applications and
   use our services. For example, we may capture when a user visits a screen,
   taps a button, permits notifications, upgrades, or otherwise interacts with
   the app
 * Monitoring and analyzing the effectiveness of our communications (including
   by identifying when emails sent to you have been received and read)
 * Serving relevant advertising (where applicable)

Information collected from integrated services.

We may obtain information, including personal information from third parties and
sources that we integrate into our Services either for the provision of our
services or to facilitate your access to our Services such as described below.

You may be given the option to access or register for our services through the
use of your third-party social media account, such as Facebook or Google. If you
select this option, your social media provider may make some of your personal
information available to us, such as your email address or other unique
identifier or we may be asked to share certain information with such social
media provider. If you choose to sign on through your third party social media
provider, you authorize us to collect your information from such provider and
process it in accordance with this Privacy Policy and you also authorize us to
share your information with your social media provider as necessary to permit
you to access our services using your social media account. We recommend that
you review your social media provider's privacy policies carefully before using
their service to connect to our Services.

Email marketing

We may send you marketing emails to tell you about our products (including
promotions, offers, discounts and new features), and about products of our
affiliates. Where we require your consent to send you marketing emails, we will
ask for and keep a record of your consent. We will also provide you with an easy
way to opt-out of receiving future marketing emails at any time.

In our marketing emails to you, we may use pixel tags to help us learn how to
improve our email delivery and engagement. Data collected in this way is used
for aggregated analytics and may include the browser and email clients you use,
coarse location derived from your IP address and details about how you engage
with the email (eg, whether or not the email was read or forwarded).

3. HOW WE MAY USE YOUR PERSONAL INFORMATION

In addition to the purposes described above, we may use the information we
collect for a variety of purposes, such as the following:

 * Performing Our Services
   • maintaining or servicing accounts, providing customer service, operation
   our website and mobile applications; processing or fulfilling orders and
   transactions, verifying user information, processing payments
   • communicating about the products and Services we offer, and responding to
   requests, inquiries, comments, and suggestions
 * Internal Research
   • understanding and evaluating how our Services and features perform with our
   users
   • uncovering insights about usage in order to improve the Services and
   provide customers with enhanced features as well as inform our development of
   new features and products.
   • development of customized or personalized experiences of our Services, such
   as remembering your information, so you do not have to re-enter it each time
   you use one of our Services
 * Auditing Interactions with Consumers
   • measuring usage of our websites and mobile applications
   • measuring our advertising and marketing activity (e.g., measuring how a
   user was acquired)
 * Security
   • to provide you with a secure experience and to take measures to protect our
   website and mobile applications from cyber risks
   • protecting against, identifying, investigating, preventing, and responding
   to fraud, illegal activity (such as incidents of hacking or misuse of our
   websites and mobile applications), and claims and other liabilities,
   including by enforcing the terms and conditions that govern the Services we
   provide
 * Debugging/Repair
   • identification and repair of impairments to intended, existing
   functionality of our Services
 * Advertising/Marketing
   • understanding our customer in order to more effectively market our Services
   and if applicable, serving you relevant advertising.
 * Quality and Safety Maintenance and Verification
   • activities related to improving the quality of the Services we provide,
   including upgrade or enhancement of the Services
   • verification or maintenance of the quality or safety of Services
   • tracking and responding to quality and safety matters
   • protecting our rights and property
 * Machine Learning
   • improving our machine learning algorithms for certain features (such as the
   Magic Cut tool for Pixomatic).
 * Other Purposes
   • Complying with legal or regulatory requirements, judicial process, industry
   standards and our company policies
   • Other purposes that may be described at the time you choose to provide
   personal information to us

To perform the above functions, we may match information collected from you
through different means or at different times, including both personal
information and Automated Information, and use such information along with
information obtained from other sources. We may also aggregate and/or
de-identify any information that we collect, such that the information no longer
identifies any specific individual. We may use, disclose and otherwise process
such information for our own legitimate business purposes – including historical
and statistical analysis and business planning – pursuant to this Privacy Policy
and applicable privacy laws.

We will inform you if it is necessary for us to use your personal information
for any purpose other than those stated in this Privacy Policy, and obtain your
consent (where required by applicable privacy laws) before using your
information for such other purpose.

4. HOW WE MAY SHARE INFORMATION ABOUT YOU WITH OTHERS

We may share information about you for the purposes described in this Privacy
Policy or pursuant to a specific "in-time" privacy notice we may provide at the
time we collect the information.

Corporate Affiliates

Conceptiv (and its parent company Apalon) is part of the IAC Group family of
businesses. We share your information with other parts of IAC for legitimate
business purposes, including:

 * to assist us in technical processing operations, such as data hosting and
   maintenance, finance, legal, HR and accounting assistance, securing our data
   and systems and fighting against spam, abuse, fraud, infringement and other
   wrongdoings; and
 * for corporate audit, analysis and consolidated reporting as well as
   compliance with applicable laws.

Third Party Service Providers

We may share information about you with the following categories of third-party
providers for a variety of business purposes:

 * Customer Communications and Insights Platforms. We may share phone number,
   email, app usage and interactions with our third-party customer
   communications platform provider for the following business purposes:
   performing services that allow us to communicate with you and administer your
   account as well as track your usage for our internal analytics.
 * Internal Business Insights Platforms. Our third-party internal business
   analytics platform provides us with the tools to help us understand app usage
   and interactions and uncover insights that allow us to improve our product
   and features. We may share or make available unique user identifiers, IDFA,
   device ID, IP address and app usage and events (such as when you subscribed
   to our services) with these providers for the following business purposes:
   performing services that allow us to (i) monitor and understand usage in
   order to enhance existing Services or develop new products and features and
   (ii) better understand our customers in order to market our products more
   effectively.
 * Customer Support – When you contact us through our one of our support emails
   indicated in the "How to Contact Us" section at the bottom of this Privacy
   Policy, your email may be directed through our third party customer support
   platform which will have access to your personal information, the content of
   your email as well as date and time your request came into our system. We use
   this provider to allow us to communicate with you about your account and to
   receive reports from users about the quality or safety of our products.
 * Measurement and Attribution. These service providers offer tools that allow
   us to measure and attribute the source of new subscription sign ups and that
   allow us to uncover insights about usage and app events. We may use unique
   user identifiers made available to us from these third-party providers to
   help us measure the effectiveness of our ads (e.g., where and how a user is
   acquired) and to uncover information about how our customers are using our
   apps in order to improve their quality and safety. We may also share and/or
   store unique user identifiers, device IDs, IDFA or IP addresses with these
   providers for the same purpose.
 * Other technology providers necessary to provide our services (including cloud
   storage and web hosting providers). We may make certain Automated Information
   and/or aggregate or non-personally identifiable information available for
   various purposes including monitoring network traffic to detect malicious
   actors and to protect against malware, fraud or other unlawful uses or
   activity.
 * Payment Processors. If you purchase our services outside of the Apple or
   Google stores, we will process your payment through our third-party provider.
   When you pay in this manner, you authorize and direct us to process your
   payment through our payment processor. An example of this is our payment
   partner, Braintree (https://www.braintreepayments.com/). Please note we will
   share certain information such as your email address with our payment
   processor to facilitate the provision of receipts to you from the payment
   processor and to address any issues that may arise with your payment.
 * Advertising/Marketing providers. We, or the third-party service providers we
   use to assist us with marketing our own products to you and with third party
   in-app advertising, may use the information we collect from you to provide
   advertisements and offers. Additionally in connection with marketing our own
   products, we may share certain information with companies like Facebook,
   Pinterest or Snapchat that allows us to create Custom or Lookalike Audiences.
   You may learn more about your off-Facebook activity and how to opt out of
   having such activity sent to Facebook click here. You can also visit your
   Pinterest Settings and Snapchat Advertising Preferences to learn more about
   your privacy options on those platforms. We also use Google Ads to advertise
   our products. You may opt-out of the use of this tracking technology by
   visiting Google’s Advertising and Privacy page. Additionally, if we obtain
   your information in connection with a contest, sweepstakes, event, offering
   or other promotional activity that is jointly offered by us and any third
   parties. By entering such contest or sweepstakes, you authorize and direct us
   to share your information with our co-sponsor. We may also share your
   information with a third-party service provider who administers the
   promotion, contest and/or sweepstakes. We may also share aggregate
   information to third party providers and platforms that help us understand
   our user demographic, including user demographic interests, habits and usage
   patterns for certain of our Services so that we may market our products more
   effectively.

Corporate Transactions

We may share information about you in connection with (including during the
evaluation or negotiation of) a corporate change or dissolution, including for
example a merger, acquisition, reorganization, consolidation, bankruptcy,
liquidation, sale of assets or wind-down of a business (each a "Corporate
Transaction"). Unless prohibited by applicable law, we reserve the right to
transfer the information we maintain in the event we engage in any Corporate
Transaction (including, selling or transferring all or a portion of our business
or assets). If we engage in such a sale or transfer, we will, where feasible -
direct the recipient to use the information in a manner that is consistent with
this Privacy Policy. After such a sale or transfer, you may contact the
recipient with any inquiries concerning the processing of your personal
information.

Legal, Regulatory, Compliance and Similar reasons.

In addition, we may disclose and/or share your information to comply with legal
or regulatory requirements (including to comply with a court order, judicial
subpoena or other subpoena or warrant), industry standards, judicial process,
and our company policies, as well as to protect against, identify, investigate,
prevent and respond to fraud, illegal activity (such as identifying and
responding to incidents of hacking or misuse of our websites and mobile
applications), adverse event reporting, and claims and other liabilities.

We also reserve the right to disclose your information (i) when we believe in
good faith that disclosure is appropriate or necessary to take precautions
against liability, (ii) to protect our rights or property or the legal and
property rights of others and (iii) investigate and defend third party claims or
allegations against us.

In addition, we may collect, use and disclose your personal information as
required or permitted by applicable law, or as directed by you, in accordance
with this Privacy Policy.

5. DO NOT TRACK DISCLOSURES

Some web browsers may transmit "do-not-track" signals to the websites with which
the user communicates. Because of differences in how web browsers incorporate
and activate this feature, it is not always clear whether users intend for these
signals to be transmitted, or whether they even are aware of them. Because there
currently is no industry standard concerning what, if anything, websites should
do when they receive such signals, our sites do not currently process or respond
to "do-not-track" (DNT) settings in your web browser. If and when a final
standard is established and accepted, we will reassess how to respond to these
signals.

Certain third parties, such as ad networks, web analytics companies and social
media and networking platforms, collect information about your online activities
over time and across websites. These third parties may not change their tracking
practices in response to DNT settings in your web browser and we do not obligate
these parties to honor DNT settings. Information about how to opt out from your
data being used by third parties can be found above under "Information collected
by automated means."

6. SOCIAL MEDIA AND OTHER COMMUNICATIONS

We maintain a presence on several social networking and blogging platforms, such
as Facebook, Instagram, Google, LinkedIn, Twitter, Snap, TikTok and Pinterest.
We may incorporate some third-party social networking features into our Services
(including, allowing users to interact with others and share certain content and
information on social media platforms) or utilize third-party provided platforms
to publish or manage the Services or portions thereof. Through these platforms
and features, we receive or may share information about you, and this Privacy
Policy applies to that information as well. In addition, some providers of
third-party social media or blogging platforms we utilize have their own privacy
policies which explain how the third parties that provide them may collect, use
and protect your information (e.g., if you establish an account with such
platform providers directly). By using social features, you agree to those third
parties' privacy policies and terms of use.

If you choose to communicate with us or another user through social features
available on our websites or mobile applications or through our social media
pages, or other similar communication or messaging features or services, such
information may be made publicly available. For security purposes, please do not
include any password, social security number, payment card or other sensitive
information via these features. We have the right, but not the obligation to
monitor messages and communications between and among users for security and
training purposes. We may, but are not obligated to, remove any content we deem
inappropriate.

7. INFORMATION FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA)

Your Choices and Rights.

As a resident of the EEA, you may have some or all of the following rights in
relation to how we use your personal information:

 * Access: you may request access to your personal information and receive
   copies of it;
 * Correction: you may have inaccurate/incomplete personal information corrected
   and updated;
 * Object to, or Limit or Restrict, Use of Data: you can ask us to stop using
   all or some of your personal information or to limit our use of it;
 * Deletion: in certain circumstances, you can request a right "to be forgotten"
   (this is a right to have your information deleted or our use of your data
   restricted). We will honor such requests unless we have to retain this
   information to comply with a legal obligation or unless we have an overriding
   interest to retain it;
 * Portability: in certain circumstances, exercise the right to data portability
   (this is a right to obtain a transferable version of your personal
   information to transfer to another provider); and
 * Consent Management: where we rely on consent to process your personal data,
   you may withdraw consent at any time. You do not have to provide a reason for
   your withdrawal where processing is based on consent.
 * If you are a resident of the EEA and you wish to access, change or delete
   personal information we hold about you, you may contact us here. If we change
   or delete your personal information or if you decline to actively share
   certain personal information with us, we may not be able to provide you with
   our Services or some of the features and functionality of our Services. Keep
   in mind, we may reject requests for certain reasons, including if the request
   is unlawful or if it may infringe on the rights and freedoms of another
   person. For example, we may not be able to accommodate certain requests to
   object to the processing of personal information, notably where such requests
   would not allow us to provide our service to you anymore.
 * For your protection, we may require proof of identity and verification before
   we can answer the above requests.

Legal basis for processing data

In this section, we identify the legal grounds on which we rely to process
personal information.

In some cases, we have a legitimate interest to process the personal information
that we collect, such as to develop, administer and support our products and
services; to operate, evaluate and improve our business; to facilitate and
manage engagement programs; to promote research; to support our recruitment
activities; or to facilitate a Corporate Transaction (including a sale of assets
or merger or acquisition).

In other cases, we process personal information to fulfill our contracts with
business partners, such as third parties that distribute our products.

It may also be necessary for us to process personal information to establish,
exercise or defend against fraud, illegal activity, and claims and other
liabilities, including by enforcing the terms and conditions that govern the
services we provide.

Our processing of certain information may be necessary to comply with our legal
obligations, and for reasons of public interest, such as with respect to adverse
event and product safety reporting.

We may also process personal information as specifically permitted by applicable
legal requirements.

If we rely on consent for the processing of your personal information, we will
seek such consent at the time we collect your personal information.

International data transfers

We may transfer your personal information to countries other than the country in
which the data was originally collected for the purposes described in this
Privacy Notice. For example, if you are located outside of the United States, we
may transfer your personal information to the United States. The countries to
which we transfer personal information may not have the same data protection
laws as the country in which you initially provided the information. When we
transfer personal information across borders, we consider a variety of
requirements that may apply to such transfers.

Specifically, we may transfer personal information from the European Economic
Area to:

 * Countries that the European Commissions has deemed to adequately safeguard
   personal information,
 * Pursuant to the recipient's compliance with standard contractual clauses
   (also known as Model Clauses) or Binding Corporate Rules,
 * Pursuant to the consent of the individual to whom the personal information
   pertains, or
 * As otherwise permitted by applicable EEA requirements.

8. INFORMATION FOR RESIDENTS OF CALIFORNIA

If you are a California resident, the California Consumer Privacy Act ("CCPA")
may provide you with rights that are in addition to those set forth elsewhere in
this Privacy Policy regarding our use of your personal information. The CCPA
Notice applies to "Consumers" as defined by the law. This section describes your
CCPA rights as a California Consumer and explains how to exercise those rights.
See Sections 1 - 4 above to learn what information we collect from you and how
it is collected, used and shared.

Access to Information and Data Portability Rights

You have the right to send us a request, no more than twice in a twelve-month
period, for any of the following for the period that is twelve months prior to
the request date:

 * The categories of personal information we have collected about you.
 * The categories of sources from which we collected your personal information.
 * The business or commercial purposes for our collecting or selling your
   personal information.
 * The categories of third parties to whom we have shared your personal
   information.
 * The specific pieces of personal information we have collected about you.
 * A list of the categories of personal information disclosed for a business
   purpose in the prior 12 months, or that no disclosure occurred.
 * A list of the categories of personal information sold about you in the prior
   12 months, or that no sale occurred. If we sold your personal information, we
   will explain:
   • the categories of your personal information we have sold.
   • the categories of third parties to which we sold personal information, by
   categories of personal information sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in
a twelve-month period, of your personal information that we have collected in
the period that is 12 months prior to the request date and are maintaining.

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request
that we delete your personal information that we have collected directly from
you and are maintaining. Note also that we are not required to delete your
personal information that we did not collect directly from you.

Exercising Your Rights

To make a request for access, portability or deletion according to your rights
under CCPA, click here or mail your request for the attention of the Privacy /
Legal Department to Conceptiv Apps, LLC, 555 West 18th Street, 2nd Floor, New
York, NY 10011. California Consumers may exercise these rights via an authorized
agent who meets the agency requirements of the CCPA. We cannot respond to your
request or provide you with personal information if we cannot verify your
identity or authority to make the request and confirm that the personal
information relates to you. Any request you submit to us is subject to an
identification and residency verification process ("Verifiable Consumer
Request").

The Verifiable Consumer Request must:

 * Provide sufficient information that allows us to reasonably verify you are
   the person about whom we collected personal information or an authorized
   representative; and
 * Describe your request with sufficient detail that allows us to properly
   understand, evaluate, and respond to it.

Some personal information we maintain about Consumers is not sufficiently
associated with enough personal information about the Consumer for us to be able
to verify that it is a particular Consumer's personal information (e.g.,
clickstream data tied only to a pseudonymous browser ID). As required by the
CCPA, we do not include that personal information in response to Verifiable
Consumer Requests. If we cannot comply with a request, we will explain the
reasons in our response.

We will make commercially reasonable efforts to identify Consumer personal
information that we collect, process, store, disclose, and otherwise use and to
respond to your California Consumer privacy rights requests. We will typically
not charge a fee to fully respond to your requests, but we may charge a
reasonable fee, or refuse to act upon a request, if your request is excessive,
repetitive, unfounded, or overly burdensome.

Opt-Out

There is not yet a consensus as to whether third party cookies and tracking
devices associated with our websites and mobile apps may constitute a "sale" of
your PI as defined by the CCPA. To make a request to opt-out of sale under CCPA,
click here. See Section 9: Online Privacy Choices and Rights to learn how you
can exercise your rights regarding interest-based advertising.

We will not discriminate against you in a manner prohibited by the CCPA because
you exercise your CCPA rights. However, we may charge a different price or rate,
or offer a different level or quality of good or service, to the extent that
doing so is reasonably related to the value of the applicable data. In addition,
we may offer you financial incentives for the collection, sale and retention and
use of your personal information as permitted by the CCPA that can, without
limitation, result in reasonably different prices, rates, or quality levels. The
material aspects of any financial incentive will be explained and described in
its program terms. We may add or change incentive programs and/or their terms by
posting notice on the program descriptions and terms linked to above so check
them regularly.

California's "Shine the Light" law, Civil Code section 1798.83, requires certain
businesses to respond to requests from California customers asking about the
businesses' practices related to disclosing personal information to third
parties for the third parties' direct marketing purposes. Alternately, such
businesses may have in place a policy not to disclose personal information of
customers to third parties for the third parties' direct marketing purposes if
the customer has exercised an option to opt-out of such information-sharing. As
discussed above, if we share Personal Information with third parties for their
marketing purposes you will be able to elect for us not to do so by submitting
your request here (please include your name, mailing address, and email
address).

To find out more about our "do not track" practices under Cal. Bus. & Prof. Code
§ 22575, see the "Do Not Track Disclosures" section of this Privacy Policy.

9. INFORMATION FOR RESIDENTS OF MAINLAND CHINA

If you are a resident of Mainland China (“Mainland China”, for the purpose of
this Privacy Policy, excluding the Hong Kong Special Administrative Region and
the Macau Special Administrative Region, and Taiwan), the PRC laws and
regulations contain rules that are in addition to those set forth elsewhere in
this Privacy Policy regarding our collection, use, transfer and retention of
your personal information.

Principles of Collection

We only collect your information to the extent necessary to provide one or more
of the Services, and will do so only by fair and reasonable means. The legal
basis for collecting and using the information depends on what the information
is and the context in which we collect it. During your use of some features, we
will collect your personal information after obtaining your consent. Unless the
provision of such information is required by applicable laws and regulations,
refusing to provide such information will only result in your inability to use
the related features, and will not affect your use of other features.

Sensitive Personal Information

Access to sensitive personal information, such as contacts, exact location,
camera, microphone and album, is disabled by default, and will only be enabled
upon your express authorization. It is important to note that obtaining your
authorization to access sensitive personal information is a necessary but not
sufficient condition for us to collect certain information. Our acquisition of
your authorization to access sensitive personal information does not mean that
we will definitely collect your relevant information. We will only collect your
sensitive personal information when there is a specified purpose and sufficient
necessity and in accordance with this Privacy Policy. For the collection and
processing of sensitive personal information, specific consent shall be obtained
from you.

We place great value on the protection of minors’ personal information. As
required by applicable laws and regulations, any user under the age of 14 shall
obtain the written consent of his/her parent or statutory guardian prior to
providing sensitive personal information to us.

Information Shared with a Third Party

We will share your personal information with third parties only in accordance
with this Privacy Policy. Unless explicitly authorized by you, we will not share
any information that can be used to identify your identity (such as your name or
email address). We may, however, share non-personally identifiable, aggregated,
and/or public information with third parties. We will direct all such
third-party service providers to maintain the confidentiality of the information
disclosed to them and not to use your information for any purpose other than
that have been authorized by you.

Data Retention

We may retain personal information we collect from you where we have an ongoing
legitimate business need to do so. We may retain personal information for as
long as necessary for the purposes set out in this Privacy Policy, which
includes retention that may be required for regulatory purposes.

If we discontinue providing our Services, we will notify you of such change by
sending a notification, posting an announcement, or other means, and delete or
anonymize your sensitive personal information within a reasonable period.
“Anonymization” refers to the irreversible erasure or removal of sensitive
personal information that leads to the information owner being identified. Any
anonymized information shall not be considered as personal information.

Your personal information collected from Mainland China will be stored in a
location within Mainland China in accordance with applicable laws and
regulations. If it is necessary to change the location where your personal
information is stored from Mainland China to another location outside Mainland
China, the information transfer will be conducted in strict compliance with
applicable laws.

Right to Delete Information

We will delete, and you have the right to request the deletion of, your personal
information if:

 * the purpose of processing such personal information has been achieved or is
   unable to be achieved, or the personal information is no longer necessary for
   achieving such purpose;
 * we cease the provision of the Service, or the required information retention
   period has expired;
 * relevant authorization or consent is withdrawn by you;
 * the processing of personal information by us is in violation of any
   applicable law, regulations or agreement; or
 * any other circumstances as provided by applicable laws or regulations.

If the information retention period prescribed by law has not expired, or it is
technically difficult to delete the personal information, we will cease the
processing of such personal information, except for storage and any necessary
measure taken for security protection purpose.

10. ONLINE PRIVACY CHOICES AND RIGHTS

Access, Edit and Delete Your Information.

If you are a resident of the European Economic Area, your rights to access, edit
and delete your information can be found in the "Information for Individuals in
the European Economic Area" section of this Privacy Policy. If you are a
California resident, your rights to access, edit and delete can be found in the
"Information for Residents of California" section of this Privacy Policy.

If you are not a resident of the EEA or California, depending on your location,
you may be able make requests to access, correct and/or delete certain personal
information that you provide to us. For your protection, we may require proof
and verification of identity and jurisdiction of residency before we can answer
the above requests. If you wish to make such a request, you may contact us at
the applicable mobile application support email indicated in the "How to Contact
Us" section of this Privacy Policy. If we change or delete your personal
information or if you decline to actively share certain personal information
with us, we may not be able to provide to you our services or some of the
features and functionality of our services. Once we have verified that you own
the account, we will honor such requests at our discretion and in accordance
with applicable law.

Device permissions

Mobile platforms have permission systems for specific types of device data and
notifications, such as camera and microphone as well as push notifications.
Where applicable, you can change your settings on your device to either consent
or oppose the collection of the corresponding information or the display of the
corresponding notifications. Of course, if you do that, certain services may
lose full functionality.

Uninstall

You can stop all information collection by the app by disabling call forwarding
and deactivating your account by following the instructions on the Service's
Settings screen and then uninstalling the app using the standard uninstall
process for your device. If you uninstall the app from your mobile device, the
unique identifier associated with your device will continue to be stored. If you
re-install the application on the same mobile device, we will be able to
re-associate this identifier to your previous transactions and activities.

Email

If you receive commercial email from us, you may unsubscribe at any time by
following the instructions contained within the email. You may also opt-out from
receiving commercial email from us, and any other promotional communications
that we may send to you from time to time, by sending your request to us by the
applicable mobile application support email indicated in the "How to Contact Us"
section of this Privacy Policy. Please be aware that if you opt-out of receiving
commercial email from us or otherwise modify the nature or frequency of
promotional communications you receive from us, it may take up to ten business
days for us to process your request, and you may receive promotional
communications from us that you have opted-out from during that period.
Additionally, even after you opt-out from receiving commercial messages from us,
you will continue to receive transactional or administrative messages from us
regarding the Services.

Location information

If you choose to opt-in, some of our apps may collect your device's precise
real-time location, and in such cases, you may be able to opt out from further
allowing us to have access to such location data by managing your location
preferences in the app and/or on your device.

Notice to Nevada users

Under Nevada law, Nevada residents may opt out of the "sale" of certain "covered
information" (as defined under Nevada law) collected by operators of websites or
online services. We currently do not sell covered information, as "sale" is
defined by Nevada law, and we do not have plans to sell this information.
However, if you would like to be notified if we decide in the future to sell
personal information covered by the Act, please contact us here. You are
responsible for updating any change in your email address by the same method and
we are not obligated to cross-reference other emails you may have otherwise
provided us for other purposes. We will maintain this information and contact
you if our practices change.

New Privacy Laws

We understand that privacy laws are constantly evolving. New US state laws (eg,
Colorado, Virginia) and new international privacy laws (eg, Brazil’s LGPD and
China’s PIPL) are consistently emerging, developing and being enacted. These new
laws will help protect the rights of users located in those jurisdictions. We
will respect all new privacy laws and will ensure that we are fully compliant
with any new or emerging privacy law, rule or regulation.

International Transfers

Our Services are hosted in the United States. If you choose to use our services
from outside the United States, with laws governing data collection and use that
may differ from United States law, note that you are transferring your personal
information outside of those regions to the United States for storage and
processing. We may transfer your data from the United States to other countries
in connection with the storage and processing of data to operate our business.
By using our services and providing personal information, you consent to such
transfer, storage and processing. If you are a resident of the EEA, you can
learn more about transfers outside the EEA in the "Information for Individuals
in the European Economic Area" section of this Privacy Policy.

Marketing Opt-Outs

You may choose whether to receive some Interest-based Advertising by submitting
opt-outs. Some of the advertisers and Service Providers that perform
advertising-related services for us and third parties may participate in the
Digital Advertising Alliance's ("DAA") Self-Regulatory Program for Online
Behavioral Advertising. To learn more about how you can exercise certain choices
regarding Interest-based Advertising, including use of Cross-device Data for
serving ads, visit http://www.aboutads.info/choices/, and
http://www.aboutads.info/appchoices for information on the DAA's opt-out program
specifically for mobile apps (including use of precise location for third party
ads). Some of these companies may also be members of the Network Advertising
Initiative ("NAI"). To learn more about the NAI and your opt-out options for
their members, see http://www.networkadvertising.org/choices/. Please be aware
that, even if you are able to opt out of certain kinds of Interest-based
Advertising, you may continue to receive other types of ads. Opting out only
means that those selected members should no longer deliver certain
Interest-based Advertising to you but does not mean you will no longer receive
any targeted content and/or ads (e.g., from other ad networks). Also, if your
browsers are configured to reject cookies when you visit these opt-out webpages,
or you subsequently erase your cookies, use a different device or web browser or
use a non-browser-based method of access (e.g., mobile app), your NAI / DAA
browser-based opt-out may not, or may no longer, be effective.

For more information on our inbound advertising partners, click here.

11. DATA RETENTION

Except as provided below, we may retain your personal information for the longer
of three (3) years after we become aware that you have ceased using our services
or for so long as necessary to fulfill any contractual obligation governing the
information or our legal and regulatory obligations. However, we may not know if
you have stopped using our services, so we encourage you to contact us at the
appropriate support email in the "How to Contact Us" section of this Privacy
Policy if you are no longer using the services. We may retain other information
that is not personally identifiable for backups, archiving, prevention of fraud
and abuse, analytics, or where we otherwise reasonably believe that we have a
legitimate reason to do so.

12. HOW WE PROTECT PERSONAL INFORMATION

We use various efforts intended to safeguard the security and integrity of
personal information collected through our Services, against theft, improper
use, unauthorized access, or leakage. Despite these measures, however, we cannot
and do not guarantee that information will be absolutely safe from interception
or intrusion during transmission or while stored on our system, or otherwise,
and you provide information to us at your own risk.

If you correspond with us by email, text message or using Web forms like a
"contact us" feature available through our Services, you should be aware that
your transmission might not be secure from access by unauthorized parties. We
have no liability for disclosure of your information due to errors or
unauthorized acts of third parties during or after transmission. If you create
an account as part of using our Services, you are responsible for maintaining
the confidentiality of your account password and for any activity that occurs
under your account. Please notify us of any unauthorized use of your password or
account.

If we believe that the security of your personal information in our care may
have been compromised, we may seek to notify you. If we have your email address,
we may notify you by email to the most recent email address you have provided us
in your account profile. Please keep your email address in your account up to
date. You can change that email address anytime in your account profile. If you
receive a notice from us, you can print it to retain a copy of it. To receive
these notices, you must check your email account using your computer or mobile
device and email application software. We may also post a conspicuous notice on
our site or notify you through the mobile application. You consent to our use of
email, text message and/or notification through the app as a means of such
notification. If you prefer for us to use the postal service to notify you in
this situation, please let us know by submitting your request here. You can make
this election any time, and it will apply to notifications we make after a
reasonable time thereafter for us to process your request. You may also use this
email address to request a print copy, at no charge, of an electronic notice we
have sent to you regarding a compromise of your personal information.

13. LINKS TO WEBSITES AND THIRD-PARTY CONTENT

For your convenience and information, we may provide links to websites and other
third-party content that is not owned or operated by us. The websites and
third-party content to which we link may have separate privacy notices or
policies. We are not responsible for the privacy practices of any entity that it
does not own or control. We encourage you to review the privacy policies of such
third parties before providing them with any personal information.

14. INFORMATION RELATING TO CHILDREN

We do not knowingly collect information from children under the age of 16 years
old (or older if required in an applicable jurisdiction to comply with
applicable laws). If you are not over 16 years old (or older if required in an
applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR
USE THE SERVICES. If you believe that we may have personal information from or
about a child under the age of 16 years old, please contact us here. Note that
we'll attempt to delete the account of any child under the age of 16 that's
reported to us as soon as possible. You are responsible for any and all account
activity conducted by a minor on your account.

15. UPDATES TO OUR PRIVACY POLICY

We reserve the right to update this Privacy Policy to reflect changes in our
practices and services. When we post changes to this Privacy Policy, we will
update the date of this Privacy Policy. Continued use of the Services after such
date constitutes acceptance of such updates. When required by applicable law, we
may inform you by additional means, such as through a notification on the
website or in our mobile applications if we make material changes to how your
personal information is collected, accessed or otherwise used as a result of
your use of the Services or if your rights under this Privacy Policy are
materially impacted by changes to our privacy practices. We recommend that you
check this page from time to time to inform yourself of any changes in this
Privacy Policy.

16. HOW TO CONTACT US

Should you have any questions or comments, please email:

 * For Blossom: support@blossomplant.com
 * For Pixomatic: support@pixomatic.us

You may also contact us by postal mail:

Conceptiv Apps, LLC
555 West 18th Street, 2nd Floor,
New York, NY 10011
Attention: Legal Department

If you have any questions relating to privacy or if you wish to exercise a legal
right under applicable privacy law, please contact us here (for EEA residents)
or here (for California residents). In addition, California residents may reach
us by mail at the address detailed above. European users, please note that our
representative is IAC Search and Media Europe Limited, 10 Earlsfort Terrace,
Dublin 2, Ireland. If you live in the EEA, you may also file a complaint with
the competent data protection regulator.

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Conceptiv Apps is part of the Apalon family of brands. See more at Apalon.com.
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