INKO Drawing Projector Privacy Policy

For the purpose of this Policy, “personal information” means any information relating to an identified or identifiable individual. In certain jurisdictions, this may be referred to as “personal data”. However, for the sake of consistency, this Policy will use the term “personal information” throughout to refer to such data. To the extent that our processing of your personal information is subject to certain data privacy protection laws (including but not limited to the General Data Protection Regulation (“GDPR”), California Consumer Privacy Act of 2018 (“CCPA”), California Privacy Rights Act of 2020 (“CPRA”), etc., collectively hereafter “applicable laws”), we will also notify you about the legal basis on which we process your personal information and your rights under such laws.

We will only use your personal information when the applicable laws allow us to. Our legal bases for collecting and using the personal information described in this Policy depends on the personal information we collect and the specific context in which we collect the information:

• We need to perform a contract with you;

• You have given us consent to do so;

• In specific jurisdictions, processing your personal information is in our legitimate interests, including

• providing and maintaining our Services;

• detecting, preventing and enforcing violations of our Terms of Service including misuse of services, fraud, abuse, and other trust and safety protocols; and

• protecting our legal rights and the rights of others.

• We need to comply with our legal obligations under the applicable laws.

The purposes for which we process personal information, subject to applicable laws, and the legal basis on which we perform such processing, are as follows:

In order to provide you with more comprehensive and high-quality Services, we will authorize our commercial partners to provide certain services to you. In such cases, we may share some of your personal information with our partners.

We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share the personal information required to provide the Services. We will require our partners, through agreements, to retain data only for the necessary period and to implement adequate security measures to protect data security.

We will disclose personal information to the following categories of third parties for the purposes explained in this Policy:

• Affiliates and corporate partners. We may disclose the categories of personal information described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.

• Service providers and business partners. Third-party service providers who provide us with technology services (such as cloud storage service) and business support (such as payment service provider) may need to process your data. These third parties will process your personal information on our behalf under relevant contracts.

• Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose your personal information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our Terms of Service and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).

• Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

We will process your personal information on servers located in the United States. To support our global operations, we may allow remote access from Mainland China for troubleshooting and other technical support. What’s more, your personal information may also be transferred to third-party service providers and business partners, in connection with the purposes set out in this Policy. Accordingly, your personal information may be transferred to and processed in jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located.

In the event of an international transfer of personal information, when required by applicable laws, we will provide an adequate level of protection for your personal information using various means to enable lawful transfer of personal information from those countries. If you would like to have an overview of the safeguards which are in place, please contact us by using the contact details provided in Section “Contact Us” below.

We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable laws.

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If you have any concerns that your account or personal information has been put at risk, for example if someone could have found out your password, please contact us by using the contact details provided in Section “Contact Us” below.

Please note, the Internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal information , we cannot guarantee the security of your data transmitted to us using the Internet – any such transmission is at your own risk, and you are responsible for ensuring that any personal information that you send to us are sent securely.

We adhere to retention policies for the personal information we collect to ensure that it is not retained longer than necessary for the intended purpose.

If you deactivate your account, delete personal information, or the retention period is expired, we will delete or anonymize your personal information, except in the following cases:

• Compliance with legal requirements regarding data retention according to the applicable laws.

• Extension of the period for financial, audit, dispute resolution, or other legitimate purposes.

When assessing how long your personal information is retained, we consider criteria such as: (i) the nature of the personal information and the activities involved; (ii) when and for how long you use the Services; and (iii) our legitimate interests and our legal obligations.

Subject to applicable law and depending on where you reside, you may have some rights regarding your personal information, as described below. If you have any other requests relating to the access of your personal information, please contact us using the contact details listed in the Section “Contact Us”.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) require us to provide you with the following additional information:

To ensure privacy protections with respect to personal information we may collect from children (in US referring to users under 13, or under such other age as defined or required under applicable laws in the jurisdiction where the user is located) through our Services, all accounts must be registered and managed exclusively by parents or legal guardians.

When a parent creates an account or sets up the device, they may voluntarily provide limited basic information about their child, such as the child’s gender, nickname, profile photo, date of birth, and language preference. This information is used to set up a child profile within the account, allowing parents to customize settings, and helping us apply age-appropriate feature restrictions and tailor our product features to the child’s needs.

The Lingverse AI Projector hardware itself operates offline and does not transmit any usage data or personal information to our servers. We do not directly collect any personal data from children through the device. Any and all data collection relating to a child occurs strictly through the parent-managed account and is limited to the information explicitly provided by the parent.

We do not require or permit children to provide personal information on their own. If we discover that we have inadvertently collected personal information from a child without verifiable parental consent, we will promptly delete such data from our systems.

If we intend to collect personal information from children in the future due to product upgrades or service changes, we will take additional steps to protect children’s privacy, including:

• Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;

• In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children;

• Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and

• Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Policy. we recommend that you regularly check the latest version of this Policy via [*]. If there are any substantial changes to this Policy, depending on the nature of such changes, we will notify you in advance through pop-ups, push notifications, and other appropriate means.

For more information about your data subject rights, or how we process your personal information, please contact us by using the information below:

Lingverse Technology Pte. Ltd.

Address: PAYA LEBAR SQUARE 60 PAYA LEBAR ROAD #12-003 Singapore 409051

Contact Details: [Email Address] / [Phone Number]

If you use our Services within the European Economic Area, we have designated [name of the EEA representative] (email: [*]) as our representative in accordance with Article 27 of the GDPR.