Privacy Policy

The categories of personal information we collect depend on how you use 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. 1.1 Information You Provide to Us You provide us information about yourself when you register for and/or use the Services. The information you may provide includes: • Account Information: Name, email address, username, password, and profile information • User Content: Text, images, audio, video, and other content you create, upload, or share through our Services • AI Prompts and Instructions: Text, images, or other data you input as prompts for AI-powered features • Communication Data: Information you provide when you contact us for support, feedback, or other inquiries • Payment Information: Billing and payment details when you make purchases (processed through third-party payment processors) • Profile Data: Profile pictures, avatars, preferences, and settings • User-Generated Content: Books, stories, projects, notes, habits, trips, and other content created within our apps • Survey and Feedback Data: Responses to surveys, reviews, and feedback you provide 1.2 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: • Internet protocol (IP) address • Device identifiers (IDFA, Android ID, or other unique identifiers) • Device information (model, operating system, version, settings) • Mobile carrier information • Browser type and version • General location information (including approximate location derived from IP address and time zone) • Internet service provider • App usage data (features used, time spent, interactions) • Session data and analytics • Crash reports and performance data HealthKit Information (Applicable to iOS Apps Only): If you use our Services on an iOS device, we may collect data from the iOS Health app and/or HealthKit, including date of birth, height, sex, weight, heart rate, sleep data, respiratory data, blood oxygen levels, and workout information (collectively, "HealthKit Information"). This data is covered by this Privacy Policy and will only be collected if you choose to provide it. Users are not required to share this information and may opt out by not entering it when prompted. We will not use HealthKit Information for marketing purposes or share it with third parties for marketing or advertising. This provision does not apply to Android users, as our Android apps do not access or collect HealthKit data. Camera and Photo Access: Certain features may require access to your device's camera or photo library to upload images, create content, or use AI-powered image analysis features. We will request your explicit permission before accessing your camera or photos. Location Information: Some of our apps may collect precise or approximate location data to provide location-based features. Location data collection requires your explicit permission and can be disabled in your device settings. Information Collected by Cookies and Similar Tracking Technologies: We use different technologies to collect information, including: • Cookies: Small data files stored on your device • Web Beacons: Electronic images that allow us to count users and track usage patterns • SDKs: Software development kits that collect usage and analytics data • Local Storage: Technologies that store data locally on your device • Analytics Tools: Third-party analytics services that collect usage data 1.3 Information We Collect from Other Sources We also obtain information about you from other sources, including: • Third-Party App Stores: Transaction information from Apple App Store or Google Play Store when you install our app or purchase a subscription • Social Media Services: If you create or log into your account through a social media service account (e.g., Facebook, Google, Apple), we will have access to certain information from that account, such as your name, email address, profile picture, and other account information, in accordance with the authorization procedures set by that social media service • Payment Processors: Transaction and payment information from third-party payment processors • Analytics Partners: Usage and engagement data from analytics providers • Advertising Partners: Ad performance and attribution data from advertising networks • Public Sources: Publicly available information, business contact databases, and other legitimate sources

We may use your information for the following purposes: 2.1 Provide Our Services We use your information to fulfill our contract with you and provide you with our Services, such as: • Managing your information and accounts • Providing access to certain areas, functionalities, and features of our Services • Processing your requests, purchases, transactions, and payments • Using collected information (including HealthKit Information where applicable) to help generate dynamic plans, recommendations, and personalized content for you • Developing and improving AI features: Training, fine-tuning, and improving our artificial intelligence models and features to provide better, more personalized Services. This may include using your prompts, content, and usage patterns to enhance AI capabilities • Answering requests for customer or technical support • Communicating with you about your account, activities on our Services, and policy changes • Sending you technical notices, updates, security alerts, and administrative messages • Processing applications if you apply for a job we post • Keeping the screen active: Preventing screen timeout during certain operations (e.g., AI processing, content generation) to ensure smooth user experience • AI-Powered Features: Processing your text, images, and other inputs through AI services (including third-party AI providers like OpenAI) to provide content generation, analysis, recommendations, and other AI-powered functionality Image and Content Analysis Features (Applicable to Apps with These Features): If the app you are using includes image analysis, content recognition, or AI generation features, photos and content you take, upload, or create will be processed to provide the requested functionality. Such content will be viewable and usable by you within the app. In order to make such functions work, the app may need access to your camera, photo library, or storage, but this access will require that you grant specific permission through a request that will appear on your mobile device. This provision does not apply to apps that do not offer this functionality. Notifications, Reminders, and Alarms: We may request access to send you notifications to keep you updated about important activities, reminders, or personalized guidance. On Android devices, we may additionally request permission to use reminders and alarms to better support your progress and help you use our Services effectively. Granting these permissions is optional, and you may choose not to authorize them at any time through your device settings. 2.2 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 2.3 Marketing Communications and Advertising We may send you marketing communications and tailor promotions as permitted by applicable law. Where required, we will obtain your consent (opt-in) before sending marketing messages, and you can opt out at any time. Types of marketing communications may include: • Email campaigns, newsletters, and product updates • In-app messages and announcements • Push notifications (subject to device permissions) • SMS messages (where supported and where you have provided consent) Managing your preferences / opting out: • Email: You can unsubscribe using the link in our emails. • Push: You can disable notifications in your device settings (and/or in-app settings where available). • In-app: You can disable in-app marketing messages in your in-app settings where available. • SMS: You can stop receiving SMS by replying STOP (or as otherwise instructed in the message). Message and data rates may apply. Service communications vs. marketing: Even if you opt out of marketing communications, we may still send you non-marketing messages that are necessary to provide the Services (e.g., security alerts, account notices, transactional messages, or changes to our policies), to the extent permitted by applicable law. Advertising and personalization: We may work with analytics and advertising partners to measure performance and show relevant content, consistent with your choices and applicable law. In some jurisdictions (e.g., where required), you may have the right to opt out of certain targeted advertising or cross-context behavioral advertising. Important Limitation: We will not use or disclose to third parties any data gathered in the health and fitness context (including HealthKit Information) for advertising, marketing, or other use-based data mining purposes. 2.4 Other Purposes We also use your information for other purposes as requested by you or as permitted by applicable law.

SecondEarth does not sell your personal information. In certain circumstances, 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. 3.1 Vendors and Service Providers To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with vendors and service providers, including: • IT support and hosting providers • Cloud storage providers • Payment processing services • Customer service and support platforms • Analytics and data analysis providers • Marketing and advertising partners • Email and communication service providers • AI and machine learning service providers (including OpenAI) • Content delivery networks • Security and fraud prevention services Third-Party Services We Use (Non-Exhaustive List): • Firebase: https://policies.google.com/privacy • Google Analytics: https://policies.google.com/privacy • AppsFlyer: https://www.appsflyer.com/privacy-policy/ • Facebook/Meta: https://www.facebook.com/privacy/explanation • OpenAI: https://openai.com/privacy/ • RevenueCat: For subscription management • OneSignal: For push notifications and messaging • Mixpanel: For analytics • Apple App Store and Google Play Store: For app distribution and in-app purchases 3.2 Business Transfers If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a "Transaction"), your personal data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets. 3.3 Legal Requirements We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, respond to lawful requests from public authorities, protect and defend our rights or property, prevent fraud or illegal activity, act in urgent circumstances to protect the personal safety of users of the Services or the public, protect against legal liability, enforce our Terms of Service or other agreements, or investigate potential violations of our policies. 3.4 Other Users and Public Features Certain user profile information, including your name, username, profile picture, and any content that you have uploaded or shared publicly, may be displayed to other users to facilitate user interaction within the Services or address your request for our Services. 3.5 With Your Consent We may share your information with third parties when you give us explicit consent to do so. 3.6 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. Important Limitation: We do not use or disclose to third parties data gathered in the health and fitness context (including HealthKit Information) for advertising, marketing, or other use-based data mining purposes.

To be in control of your personal data, you have the following rights: 4.1 Accessing / Reviewing / Updating / Correcting Your Personal Data You have the right to review, edit, or change the personal data that you had previously provided to us. You can typically do this in the profile or settings section of the app. If you would like to receive a copy of the personal data we process about you, please send us a data access request at sunwoo@secondearth.io. 4.2 Deleting Your Personal Data You can request erasure of your personal data, as permitted by law. You may be able to delete your account directly through the app settings, or you can contact us to request account deletion. 4.3 Objecting to or Restricting the Use of Your Personal Data You can ask us to stop using all or some of your personal data or limit our use thereof. For example, you can: • Opt out of marketing emails by clicking the unsubscribe link • Disable push notifications in your device settings • Revoke permissions for camera, location, or other device features in your device settings • Opt out of interest-based advertising through device settings 4.4 Data Portability If you wish to receive your personal data in a machine-readable format, you can request a copy of your personal data. The data will be made available to you in JSON or another appropriate file format. 4.5 Additional Rights for EEA-Based Users If you are based in the European Economic Area (EEA), you have additional rights including the right to lodge a complaint with a supervisory authority and the right to withdraw consent. 4.6 Additional Rights for California Residents If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). 4.7 How to Exercise Your Rights To exercise any of the privacy rights available to you, please send a request to: Email: sunwoo@secondearth.io We will verify your identity and respond to your request in accordance with applicable law.

Our Services are not intended for children under the age of 13. Therefore, we do not knowingly collect or solicit any personal information from children under 13. No one under age 13 may provide any personal information to the Services or through any of its features. If you are under 13, do not: • Use or access the Services • Register for an account • Provide any information about yourself, including your email address • Use any interactive features or submit any content If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at sunwoo@secondearth.io. For parents and guardians: If you believe your child has provided personal information to us, please contact us immediately so we can delete such information.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We implement appropriate technical and organizational measures designed to protect your personal information, including: • Encryption of data in transit and at rest • Regular security assessments and audits • Access controls and authentication requirements • Employee training on data protection • Secure development practices • Incident response procedures However, please note: No system is 100% secure, and we cannot ensure or warrant the absolute security of any information you provide to us. The Internet and mobile networks are not completely secure environments, and we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of our safeguards. Your Responsibility: You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account. Please notify us immediately of any unauthorized use of your account.

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, audit, or other purposes), whichever is longer. The specific retention period depends on the nature of the information and why it is collected and processed. When we no longer need your personal information, we will securely delete or anonymize it.

SecondEarth operates globally, and we may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Services and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards, including standard contractual clauses approved by the European Commission or other relevant authorities. By using our Services, you acknowledge and consent to the transfer of your personal information to countries outside of your country of residence, which may have different data protection laws.

This section provides additional details about how we process personal information of California consumers and the rights available to them under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"). Therefore, this section applies only to residents of California, United States. 9.1 Categories of Personal Information For more details about the personal information we have collected over the past 12 months, including the categories of sources, please see Section 1 above. 9.2 Your California Privacy Rights Subject to certain limitations, the CCPA and CPRA provide California consumers with the following rights: • Right to Know: You have the right to request to know more details about the categories or specific pieces of personal information we collect • Right to Delete: You have the right to request deletion of your personal information • Right to Correct: You have the right to request correction of inaccurate personal information • Right to Opt-Out of Sales/Sharing: While we do not "sell" personal information in the traditional sense, if we engage in activities that constitute "sales" or "sharing" under the CCPA, you have the right to opt out • Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information to purposes permitted by law • Right to Non-Discrimination: You have the right not to be discriminated against for exercising these rights 9.3 How to Exercise Your Rights California consumers may make a request pursuant to their rights under the CCPA by contacting us at sunwoo@secondearth.io.

If you are located in the European Union or European Economic Area, you have certain rights under the General Data Protection Regulation (GDPR). 10.1 Legal Bases for Processing We process your personal information based on the following legal bases: • Contract Performance: Processing is necessary to perform a contract with you • Legitimate Interests: Processing is necessary for our legitimate interests • Consent: You have given clear consent for us to process your personal information • Legal Obligation: Processing is necessary for us to comply with the law 10.2 Your Rights Under GDPR Under GDPR, you have the following rights: • Right of access to your personal data • Right to rectification of inaccurate personal data • Right to erasure ("right to be forgotten") • Right to restriction of processing • Right to data portability • Right to object to processing • Right to withdraw consent • Right to lodge a complaint with a supervisory authority 10.3 Data Protection Officer You may contact our Data Protection Officer at: sunwoo@secondearth.io

We may change this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make changes, we will notify you by: • Revising the "Last Updated" date at the top of this Privacy Policy • Posting the updated Privacy Policy on our Services • Sending you a notification through the app or via email (for material changes) You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect. If you do not agree to the updated Privacy Policy, you must stop using our Services.

Our Services may contain links to third-party websites, applications, or services that are not operated or controlled by us. This Privacy Policy does not apply to such third-party services. We are not responsible for the content, privacy policies, or practices of third-party services. We encourage you to review the privacy policies of any third-party services before providing any personal information to them.

Some web browsers and mobile devices support "Do Not Track" ("DNT") signals. Because there is no common understanding of how to interpret DNT signals, we do not currently respond to DNT signals on our Services.

If you have any questions about this Privacy Policy, our privacy practices, or to exercise your rights as detailed in this Privacy Policy, please contact us at: SecondEarth Email: sunwoo@secondearth.io Response Time: We will respond to your inquiry within a reasonable timeframe as required by applicable law.