Effective date: January 01, 2023

Here are some important definitions to help you understand our terms and this Privacy Policy:

• NotMagic Limited, Inc. and our relevant affiliates are referred to as "NotMagic Limited," "we", "us", and "our."
• Our mobile application MAGIC ⋆ AI Avatar Maker is referred to as "MAGIC" or "application"
• Users are referred to as "users", "you" or "your", as applicable.
• Your use of the applications (including downloading, installing, registering with, accessing, or otherwise using it) is referred to as "Use".
• To the extent information is: (i) associated with an identified or identifiable natural person and (ii) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as "Personal Data".

MAGIC uses a Neural Network Model Stable Diffusion that allows users to generate personalized AI Avatars ("Avatars").

1. Users upload 10 to 20 photos of their face and select their gender.
2. Using this face data, a copy of the StableIffusion model is retrained to personalize the model
3. After the model copy is retrained, it generates the Avatars
4. After the Avatars are generated, the copy of the model, along with uploaded photos, are deleted permanently from our servers
5. We do not use your Personal Data to generally train and/or create our separate artificial intelligence/products.

We do our best to moderate the parameters of the Stable Diffusion model, however, it is still possible that you may encounter content that you may see as inappropriate for you.

We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively.

Please read this Privacy Policy carefully to understand our privacy practices. The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it. If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use MAGIC.

By Using MAGIC, you understand and agree that we are providing you with tools for editing and adjusting photos and videos that you upload, and, if you so request, for generating or creating new content from them, for example with our AI Avatars feature.

If you have any questions about this Privacy Policy or MAGIC, please contact us at privacy@notmagic.ai (for additional contact information, please, see Section 13 of this Privacy Policy "How to Contact Us").

This Privacy Policy DOES NOT apply to the information that:

• We collect offline or on any of our other apps or websites, including websites you may access to through MAGIC.
• You provide to or that is collected by any third party (e.g., any third-party application or website, even if the link to it is accessible through MAGIC).

We may collect several types of information, including but not limited to Personal Data, from and about you:

• Directly from you when you provide it to us.
• Automatically when you Use MAGIC. Information collected automatically may include Usage details and internet protocol ("IP") addresses.
• From third parties, for example, our Service Providers (as defined below).

When you Use MAGIC, you usually provide to us certain information, including your Personal Data:

Photos and (or) videos that you upload to MAGIC, for example to use the AI Avatars feature. Please note that we always delete all metadata that may be associated with your photos and (or) videos by default (including, for example, geotags) before temporarily storing them to our systems.

We can access your photos and videos only after you grant us permission to access your camera or your devices' photo library. You provide such a permission through the request that appears on your mobile device (it may differ depending on your device operating system). You may revoke permission to access your camera or photo library through the settings on your mobile device, and here's how to do it.

If you use an iOS device:

1. On your iPhone or iPad open the Settings app.
2. Scroll down and tap "Privacy".
3. Tap "Camera" or "Photos".
4. Next to MAGIC, toggle the permissions switching on or off.

Information about your gender: When you use our AI Avatars feature, we ask you about your gender. This information is used by the AI model solely to generate the Avatars in accordance with the indicated gender: for example, if you choose to identify your gender as a female, then you will receive conventionally more feminine-like Avatars.

Your email: When you create an account with Lensa, we ask you to provide your email that will be further used for your sign-in process.

If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users inquiries in relation to Lensa.

When you Use MAGIC, we may automatically collect certain data about you. This data is needed for operation of MAGIC and, among others, may be used for in-app analytics or marketing purposes. The data we collect automatically includes:

Device information: Information about your mobile device and internet connection, including your IP address, the device's unique device identifier, operating system, and mobile network information.

Usage details: Details of your Use of MAGIC, including frequency of Use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.

(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by MAGIC, please follow the instructions below.

If you use an iOS device:

1. Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
2. Tap to turn off or turn on permission to track for MAGIC.

Details about your in-app purchases. This data is used to provide you with the Services and for our in-app analytics.

Such automatically collected data helps us operate MAGIC and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use MAGIC and what you like and dislike the most.

The technologies we use for automatic data collection may include:

We use third-party analytics tools, such as Google Firebase, Meta, AppsFlyer and Amplitude, to help us measure traffic and usage trends for MAGIC. These tools collect information via third-party analytics software development kits incorporated into MAGIC, which includes your pseudonymised user ID and the information about MAGIC web pages you visit when following the links available to you on MAGIC, your actions in MAGIC application and basic information about the type of subscription you have. We collect and use this analytics information in an aggregated manner with analytics information from other users so that it cannot reasonably be used to identify any particular user.

We care about your privacy. With this in mind, most processing activities occur on your device only. There are, however, one exception to it: when you generate Avatars, since these functions require sophisticated computing resources to be performed.

AI Avatars. In order to generate AI Avatars, you have to upload 10-20 photos to MAGIC. At this point, your photos are stored on our servers (provided by Amazon Web Services (USA)). Then, a copy of the Stable Diffusion model is created to be retrained with your photos to personalize the model and to create your Avatars. Immediately after the successful generation of Avatars, your original photos are deleted from our servers. Your purchased Avatars are stored on our servers so that they remain accessible to you in MAGIC at any time and from any device until you decide to delete them.

You can also always request us to delete your photos or Avatars by contacting us at privacy@notmagic.ai.

Notwithstanding anything to the contrary elsewhere in this Privacy Policy:

• We do not use photos, videos or Avatars to identify any individual user.
• We do not use your photos, videos or Avatars for authentication, advertising, or marketing purposes, or to otherwise target a user in a similar manner.
• We do not use your photos, videos or Avatars to build a user profile, or otherwise attempt, facilitate, or encourage third parties to identify anonymous users or reconstruct user profiles based on your photos, videos or Avatars.
• We do not transfer, share, sell, or otherwise provide your photos, videos or Avatars to advertising platforms, analytics providers, data brokers, information resellers or other such parties.

We use your information other than photos and videos for the following purposes:

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to MAGIC (e.g., the Terms of Use).
• To provide you with support and to respond to your inquiries.
• To notify you about changes to MAGIC or any products or services we offer.
• To present to you and others with MAGIC and its contents and any other information, products or services that you request from us.
• To monitor aggregated metrics such as total number of users, traffic, and demographic patterns.
• To provide, improve, test, and monitor the effectiveness of MAGIC in an aggregated manner.
• When you choose to use the AI Avatars feature, you provide your gender identification, which is used to retrain the separate copy of the Stable Diffusion model to generate Avatars based on your particular photos.
• To provide personalized content and information to you in relation to MAGIC, which could include online ads or other forms of marketing.
• Upon users' consent, for marketing purposes in order to find audiences similar to our users.
• In any other way, as described in this Privacy Policy.

Access, modification, correction and erasure. You can send us an email at privacy@notmagic.ai to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you.

EEA/UK residents. Individuals residing in the European Economic Area ("EEA") and the United Kingdom ("UK") have certain statutory rights in relation to their Personal Data under the GDPR.

California, Virginia, Colorado, Utah, and Connecticut residents may have statutory rights under state comprehensive privacy law.

We do not rent or sell your Personal Data, including photos and videos, to any third parties outside the Company or its Affiliates. We may share your Personal Data with Service Providers who are bound by confidentiality and data protection terms.

We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure.

Your Personal Data, other than photos, videos and Avatars. We will retain your Personal Data until you delete your account or request us to delete your data.

Your original photos and videos that you upload for editing are processed on your device only and are not stored with our servers unless you choose to apply Art Styles to your photos.

Your original photos that you upload to generate Avatars are deleted immediately after successful Avatars generation.

The Company is incorporated in the United States. Accordingly, your Personal Data may be transferred to and stored in the United States or in other countries.

General age limitation. MAGIC is not intended for or directed at children under 13.

Age limitation for EEA residents. Due to requirements of the GDPR, you shall be at least 16 years old in order to Use MAGIC.

We are not responsible for the practices employed by any websites or services linked to or from MAGIC.

General contact details. If you have any questions about this Privacy Policy or MAGIC, please contact us via email at privacy@notmagic.ai or our mailing address:

NotMagic Limited
Suite D2028 440 N Wolfe Rd Sunnyvale, CA 94085.

The Company may modify or update this Privacy Policy from time to time. If the changes made may pose risk to your rights and freedoms, we will ask for your consent to those changes separately from this Policy.