Privacy Notice

Effective as of: February 28, 2024

Neocortext Inc (d/b/a Reface) is a “controller” in relation to personal data (“Reface,” “we,” “us,” and “our”). This means that we are responsible for deciding how we hold and use personal information about you. This Privacy Notice is designed to help you understand how Reface collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.

1. Scope

This Privacy Notice applies to personal information processed by us on our website reface.ai and all of its subdomains (“Site”). To make this Privacy Notice easier to read, our Site and our related offerings available at the Site are collectively called “Services”.

2. Changes to our Privacy Notice

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

3. Personal information we collect

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

(a) Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

• Account Creation. We may collect information when you create an account on our blog available via blog.reface.ai , such as your name and email.
• Your Communications with Us. We may collect personal information, such as name, email address, job title, company name, phone number and other personal data you may share with us when you request information about our Services, register to receive our newsletter or marketing, request customer or technical support, request business collaborations, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Job Applications. We may post job openings and opportunities on our Services. You may reply to one of these postings by submitting your application, CV, resume, cover letter, and/or other information to us. Please read more about personal data processing of candidates at the Candidate Privacy Notice.

(b) Information Collected Automatically

We may collect personal information automatically when you use our Services:

• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address) and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, your history of using the app history, and other information about how you use our Services.
• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. Our uses of these Technologies fall into the following general categories:

1. Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
2. Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
3. Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
4. Advertising-or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
5. Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include Google Analytics. For more information, please visit Google Analytics’ Privacy Notice. To learn more about how to opt-out of Google Analytics’ use of your information on our Site, please click here. Please see Section 6 (“Your Privacy Choices and Rights”) below to understand your choices regarding these Technologies.

(c) Information Collected from Other Sources

Third-Party Sources. We may obtain information about you from other sources, including through third-party services and organizations, for example using third-party services for collection of personnel during the hiring process.

4. How we use your information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

(a) Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Answering requests for customer and technical support, as well as business collaborations;
• Communicating with you about your activities on our Services, and policy changes;
• Processing applications if you apply for a job, we post on our Services; and
• Allowing you to register for events.

(b) Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading or enhancing our Services;
• Developing new products and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions and other compliance activities;
• Enforcing our agreements and policies; and
• Complying with our legal obligations.

(c) Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

5. How we disclose your information

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

(a) Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
• Subsidiaries and Affiliates. We may share your personal information with members of our corporate family.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day).
• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.

(b) Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

(c) Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

6. Your privacy choices and rights

(a) Your Privacy Choices.

The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Use or this Privacy Notice).
• Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
• “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

(b) Your Privacy Rights.

In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (aka the right of data portability);
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information;
• Data Portability;
• Not to be subject to a decision based solely on automated processing;
• Request Restriction of or Object to our processing of your personal information; and
• Withdraw Your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in Section 16 (“Contact Us”) below. We will process such requests in accordance with applicable laws.

7. Security of your information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

8. International data transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

9. Retention of personal information

We may store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

10. Supplemental Notice for California Residents

This Section for California Residents only applies to our processing of personal information that is subject to the CCPA and the CPRA. The CCPA and the CPRA provide California residents with the right to know what categories of personal information a person (either a natural person or a legal entity) has collected about them and whether such person disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve (12) months. California residents can find this information below.

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

Additional Privacy Rights for California Residents

• “Sales” of Personal Information under the CCPA and CPRA. For purposes of the CCPA and CPRA, Reface does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
• Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA and CPRA.
• Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.
• Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.
• Limit of use and disclosure of sensitive personal information. You can ask us to only use your sensitive personal information (for example, your precise geolocation data) for limited purposes, such as providing you with the services you requested.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

11. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us as set forth below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

12. Supplemental Notice for Virginia Residents

Under the Virginia Consumer Data Protection Act, you may request us to exercise your right to access your personal data, to correct inaccuracies in your personal data, to obtain a copy of your personal data, to opt out of the processing of the personal data for purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not currently sell your personal information as sales are defined in Chapter 53 of the Code of Virginia.

13. Children’s information

The Services are not directed to children under 13, (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth in Section 16 (“Contact Us”) below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

14. Third-party websites/applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

15. Supervisory authority

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law. The full list of authorities on the protection of personal data in each EU Member State is here.

16. Contact us

Neocortext Inc (d/b/a Reface) is the controller of your personal information. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Neocortext Inc (d/b/a Reface) 251 Little Falls Drive, Wilmington, New Castle County, Delaware, 19808, USA

hi@reface.ai

Reface team