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Privacy Policy

Privacy Policy for GenZone.ai

Date of Revision: [May, 2025]

Introduction

Welcome to GenZone.ai (the “Website,” "Platform," or “Service”). We, MINDSPARK AI LIMITED, a company registered in Ireland with registration number 777085 and its registered office at Coliemore House, Coliemore Road, Dalkey, DUBLIN, Ireland ("us," "we," or "our"), are committed to protecting and respecting your privacy. We take your privacy seriously and will collect, process, and use your personal information to provide the Services in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

Please read this notice carefully to understand our views and practices regarding your personal data and how we will treat it. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us as described at the end of this Policy. Please note that your use of our Website is also subject to our Terms of Service.

Scope; Third Party Sites

This Privacy Policy applies only to information we collect at and through the Website. Our Website may also contain links to third - party sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other third - party sites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that collects personal information.

1. Information We Collect

1.1 Information Categories

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information. “Voluntarily provided” information refers to any information you knowingly and actively provide us when using our Website and its associated Services. “Automatically collected” information refers to any information automatically sent by your device in the course of accessing our Website and its associated services.

1.2 Information Collection Based on Different Functions

a. When you upload images, videos, audio, text prompts, or other media files for content generation or modification (e.g., for AI Photo Editor, Background Remover, Face Swap, AI Video, AI Voice, AI Writer), or save your creations (“Creations”) on your device or our platform, we need to process this content. This may involve accessing your device's camera or media library/album if you use such features to upload content. If you do not allow us to access such information through device permissions, certain upload functionalities may not be available. b. When you use the creating functions, the text you enter, the files you upload, and the according created content (“User Created Content” or "Creations") will be processed and may be temporarily stored on our servers (e.g., located in the European Economic Area (EEA) and the United States of America for service delivery and backup purposes) for a period necessary to provide the service, for you to access, and potentially for service improvement as described herein (e.g., User Created Content not actively saved by you may be stored for up to 7 days for your convenience, after which it may be automatically deleted. Content actively saved to your account will be retained as long as your account is active or until you delete it). You may be able to delete your User Created Content at any time through your account. Please note that even after deletion, content might persist in backup copies for a limited time.

1.3 Types of Information We Collect

a. Log Data: When you access our servers via our Website, we may automatically log the standard data provided by your device. It may include your device's Internet Protocol (IP) address, your device type and version, your activity within the Website (e.g., features used, pages visited, time spent), time and date, and other details about your usage. Additionally, when you encounter certain errors while using the Website, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. b. Personal Information: We may ask for personal information:

  • When you register for an account or use Website functions that require login: This may include your Email address, and if you use third - party login, information from your third - party profiles (e.g., Google, as permitted by you and that platform).

  • When you contact us: This may include your Email address and any other information you provide in your communication. c. User Account: To use certain features of the Website, you can register your account by using an email address or a third - party's account, such as Google (each “Connected Platform” and collectively, the “Connected Platforms”).

  • Third - party's account: If you register by using a Connected Platform's account, you agree to provide us with certain permissions to receive certain data and information collected by such Connected Platform, which may be different for each Connected Platform. We collect the data and information that we need to authenticate your registration with the Connected Platform and to enable you to use the Website safely and securely. Any personal information that you share through the Connected Platform will also be covered by the Connected Platform's privacy policy.

  • Email Address: If you apply for registration directly from the Website, we need to collect your email address from the registration form, and then may send a verification code to your email address in order to complete your registration. d. Payment data: Purchase transactions (e.g., for subscriptions or credits) are done through third - party payment platforms (e.g., Stripe, PayPal). You shall carefully read their payment terms, terms of services, privacy policies, and any other related terms. We do NOT directly collect or store your full payment card information. We may receive transaction confirmations, subscription status, and partial payment information from the payment processor. e. Device Information: We may collect information about your device and internet connection, including your device's unique device identifier (or a non - persistent identifier), operating system, browser type, and mobile network information (if applicable). f. User Content: As detailed in 1.2.a and 1.2.b, this includes text prompts, images, videos, audio, and other data you provide or generate using the Services.

2. How We Collect It (Lawful Basis for Processing)

We collect and process your personal data based on one or more of the following lawful bases under GDPR and other applicable data protection laws:

  • Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., for marketing communications, or for the use of non - essential cookies).

  • Contract: The processing is necessary for a contract we have with you (e.g., to provide you with the Services you have subscribed to, including processing your User Content to generate results).

  • Legal Obligation: The processing is necessary for us to comply with the law (not including contractual obligations).

  • Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party (e.g., improving our services, security, preventing fraud), unless there is a good reason to protect your personal data which overrides those legitimate interests.

The technologies used for automatic information collection may include: a. Cookies (and similar technologies): When you visit our Website, we may send one or more “cookies” to your computer or other device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies for purposes such as authentication, preferences, performance, analytics, and advertising (if applicable, and with your consent where required by law). You will be provided with options to manage your cookie preferences through our cookie consent banner/tool. b. Web Beacons: Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single - pixel gifs) that permit us, for example, to count users who have visited those pages and for other related Website statistics. c. Analytics Services: We may use third - party analytics tools (like Google Analytics, with appropriate data processing agreements and anonymization features enabled where possible) to help us measure traffic and usage trends for the Service.

3. How We Use Your Information

3.1 Purposes of Information Collection

We collect and use information from you for the following purposes, based on the lawful bases mentioned above: a. To provide, operate, maintain, and improve the Website and our Services (Contract; Legitimate Interests). b. To fulfill any other purpose for which you provide it, including processing your User Content to generate requested outputs (Contract; Consent for specific optional features). c. To personalize your experience on the Website (Legitimate Interests; Consent). d. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (Contract; Legal Obligation). e. To notify you about changes to our Service or Website updates (Contract; Legitimate Interests). f. To send you information about surveys, promotions, and contests, as well as newsletters or other marketing communications, where you have consented or where permitted by law (Consent; Legitimate Interests for existing customers regarding similar products/services, with an opt - out option). g. For customer support and to respond to your inquiries (Contract; Legitimate Interests). h. To monitor and analyze trends, usage, and activities in connection with our Services for service improvement (Legitimate Interests). i. To detect, prevent, and address technical issues, fraud, or security concerns (Legitimate Interests; Legal Obligation). j. For research and development, including training and improving our AI models (Legitimate Interests for anonymized and aggregated data; explicit Consent for use of identifiable User Content for model training beyond direct service provision. We will ensure that any such use complies with GDPR principles, including data minimization and purpose limitation).

3.2 Changes in Processing Purposes

If we decide to change the purposes of processing specified above, we will inform you of such changes PRIOR to using your personal information within the newly set purposes and ensure a lawful basis applies, including obtaining your separate consent if required.

3.3 Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (a) the pseudonymisation and encryption of personal data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; (d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. However, please be aware that no system or network is 100% risk - free. If a personal data breach occurs that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by GDPR.

4. Third - Party Information Collection (Data Processors)

4.1 Third - Party Data Collection

When you use the Website, certain third parties (acting as our data processors) may use automatic information collection technologies to collect information about you or your device. We have data processing agreements in place with these third parties where required by GDPR. These may include: a. Analytics Providers (e.g., Google Analytics). b. Payment Processors (e.g., Stripe, PayPal). c. Cloud Service Providers (e.g., Amazon Web Services (AWS), Google Cloud Platform (GCP) for hosting our Website, Services, and storing data, including User Created Content). d. Authentication Providers (e.g., Google for social login). e. Error Tracking Services (e.g., Firebase Crashlytics, Sentry).

Their use of information on our behalf is governed by our instructions and data processing agreements.

4.2 Lack of Control over Third - Party Tracking

We do NOT control these third parties' tracking technologies for their own independent purposes.

5. Data Retention and Transfer

5.1 Data Retention

User Created Content that you generate and do not delete may be stored on our servers for the periods outlined in section 1.2.b. For example, Creations not actively saved by you may be stored for up to 7 days, while content actively saved to your account will be retained as long as your account is active or until you delete it, subject to backup cycles.

We keep your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements (e.g., account information may be retained for the duration of your account and for a period of up to 6 years after account closure for legal and audit purposes). To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. When your personal data is no longer required, we will delete it or anonymize it.

5.2 Data Transfer

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (EEA), such as the United States of America, where some of our service providers (e.g., cloud hosting, analytics) are located. Where your personal data is transferred outside the EEA, we will ensure that appropriate safeguards are in place to protect your personal data, such as by using Standard Contractual Clauses approved by the European Commission, or by transferring to countries that have been deemed to provide an adequate level of data protection by the European Commission, or other legally permitted transfer mechanisms like adequacy decisions or Binding Corporate Rules where applicable. By using our Services and providing your data, you acknowledge such transfers where necessary

6. Disclosure of Your Information

We may disclose personal information that we collect or you provide under these circumstances, ensuring a lawful basis for each disclosure: a. To our subsidiaries and affiliates, where necessary for the provision of Services or for administrative purposes, under appropriate intra - group data transfer agreements if applicable. b. To contractors, service providers (data processors), and other third parties we use to support our business, who are bound by contractual obligations (including data processing agreements under GDPR) to keep personal information confidential and use it only for the purposes for which we disclose it to them. c. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets. We will notify you of such a transfer as required by applicable law. d. To fulfil the purpose for which you provide it. e. For any other purpose disclosed by us when you provide the information, with your consent where required. f. To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law. g. To enforce our rights arising from any contracts entered into between you and us, including our Terms of Service. h. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MINDSPARK AI LIMITED, our customers, or others. i. We may share aggregated or de - identified information, which cannot reasonably be used to identify you.

7. Your Rights Under GDPR

As a data subject under GDPR, you have certain rights regarding your personal data. These include: a. The right to be informed: About how your personal data is being used (which this Privacy Policy aims to do). b. The right of access: To request a copy of the personal data we hold about you. c. The right to rectification: To request that we correct any inaccurate or incomplete personal data. d. The right to erasure (right to be forgotten): To request that we delete your personal data, under certain conditions. e. The right to restrict processing: To request that we limit the processing of your personal data, under certain conditions. f. The right to data portability: To request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. g. The right to object: To object to the processing of your personal data, under certain conditions (e.g., for direct marketing, or processing based on legitimate interests). h. Rights in relation to automated decision making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, under certain conditions.

7.1 To exercise these rights

You can often manage your information directly through your account settings. For requests not manageable through your account, or to exercise any of your rights, please contact us at [email protected]. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will respond to legitimate requests within one month, or inform you if an extension is needed.

7.2 Withdraw your consent

Where we rely on consent as the legal basis for processing, you can withdraw your consent at any time by contacting us at [email protected] or by adjusting your settings within the Website (e.g., cookie settings, marketing preferences). This will not affect the lawfulness of processing based on consent before its withdrawal.

8. Children's Policy

The Website is not intended for children under 18 years of age (the “Minimum User Age”). We do not knowingly collect personal information from children under the Minimum User Age. If you are under the Minimum User Age, please do not attempt to register for this Website or provide any personal information about yourself to us. If we learn we have collected or received personal information from a child under the Minimum User Age without verification of parental consent (where required by applicable law, e.g., for users between 13 and 16 in some EU member states if processing is based on consent), we will delete that information. If you believe we might have any information from or about a child under the Minimum User Age, please contact us at [email protected].

9. Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page, by email to the primary email address specified in your account (if you have one), or by other means prior to the change becoming effective, as required by law. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up - to - date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

10. How to Contact Us & Your Right to Lodge a Complaint

To ask questions, comment about this privacy policy and our privacy practices, or to exercise your rights, contact us at:

MINDSPARK AI LIMITED Coliemore House, Coliemore Road, Dalkey, DUBLIN, Ireland Email: [email protected]

If you have unresolved concerns, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.