PRIVACY POLICY

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:

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.
8. We retain your information as long as necessary to provide Services, comply 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 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.
• 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.

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, 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.

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.

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.

We collect information when you sign on using third-party networks. 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.

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, establish, manage, monitor, and maintain your account; improve and personalize your experience; verify your identity; and fulfill any other purpose for which you provide personal information.

We use personal information in connection with AI-enabled Services. We provide artificial intelligence (AI) enabled services or applications to enhance or help us provide the Services.

We use personal information to communicate with you about your account or our relationship. We may contact you about your account or feedback.

We use personal information to improve our products and services. We may use your personal information for research and development purposes, including to study usage trends and preferences of our users.

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 may share personal information with our vendors and partners.
• We may share personal information with our advertising partners.
• We may share personal information if we think we have to in order to comply with the law or for security reasons.
• We may share personal information with our professional advisors.
• We may share personal information as part of a business transaction.
• We may share personal information for other reasons we may describe to you.

YOU HAVE CERTAIN CHOICES ABOUT YOUR PERSONAL INFORMATION.

You can opt out of receiving our marketing emails.
You can review, update, and request the deletion of your account information.
You can manage social network logins.
You can opt-out of SMS/text messages.
You can control cookies.
You can limit interest-based advertising.
Our “Do Not Track” Policy.

NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents and supplements the practices described elsewhere in this Privacy Policy.

NOTICE TO NEVADA RESIDENTS.

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information.

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.

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.

NOTICE TO EUROPEAN USERS.

The information provided in this section applies only to individuals in the European Economic Area, the United Kingdom, and Switzerland.

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.

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.