PRIVACY NOTICE

Welcome to ImagenAI, an automated smart editing Software (the “Software” Or “Service”). The Service is owned
and operated by ImagenAI ("ImagenAI" or "We"). This Privacy Notice explains our privacy practices in relation
to your information when you use our Service.
We are committed to protecting and respecting your privacy and any information that you may provide us. Please
read this Privacy Notice carefully before using the Service and review it periodically for any updates.

PERSONAL DATA WE PROCESS
Upon registration to theService we collect your fullname and contact detailsWhen you register to the Service, we collect your full name, email address,phone number, address and payment information ("RegistrationInformation").

We collect and process yourphotos and Editing Stylepreferences (togetherreferred as "Content") when
you upload your photos to theSoftware.

When you send us your edited photos, we log the data at our servers. We
will collect data regarding your editing preferences (“Editing Style”), thenumber of photos you upload and the number of events you manage, inorder to teach our algorithm your Editing Style and in order to provide youthe Service. We refer to this entire data as “Software Learning
Information”. Software Learning Information also includes answers andpreset that you provide to us as part of our “easy profile creation”, as wellas Additional Files that may be required as part of such process. Suchinformation is required in order to improve and per sonalize our Services.
“Additional Files” shall mean files that may be required for the presetfunctionality.
You do not have a legal obligation to provide us with your Registration
Information or Software Learning Information; however, if you choose notto share this information with us we will not be able to provide you theService.

We also collect analytics
information about your use ofthe Service.

When you use the Service, we record and collect certain information about
your interaction with the Software, including the IP address from which youaccess the Software, time and date of access, type of operating system used,
geo location and actions taken while using the Software. We refer to thisentire data as "Analytics Information".

HOW WE PROCESS AND USE YOUR PERSONAL DATA
We process your data for the following purposes
To operate the Service.

We will use your Registration Information to facilitate your access to anduse of the Service, and to operate the Service.

To send you administrativecommunications.

We process your Contact Information to send you communications andadministrative emails, to manage the provision of the Service to you and toprovide you with further information and updates about our products andtechnology.

To provide and maintain theSoftware.

We will use your Software Learning Information to provide, maintain andimprove yours and others' user experience when using the Software; toprovide, maintain and improve our Software, quality of Service and otherservices we are offering.
We might use our Algorithm
results for marketingpurposes subject to your priorconsent.

We might use our algorithm results and performances for marketing
purposes but only with your prior consent. Your Editing Style will not be
offered to other users and\or third parties without your prior consent.

We will use your Analytics
Information for enhancing
and developing the Software.

We will use the Analytics Information for quality assurance and fordevelopment and enhancement of the Software. We also use the Analytics
Information to adapt the Software, its content, and our services to users’
preferences. Finally, we will use the Analytics Information to track yourprogress when using the Software, prevent fraud, resolve disputes,troubleshoot problems, assist with any investigations, enforce the Terms ofUse, establishing your use of the Software, and take other actions otherwise
permitted by law.

WHEN IS YOUR PERSONAL DATA SHARED WITH OTHERS
We will not share your information with third parties, except in the events listed below or when you provide
us your explicit and informed consent.
Wewillshare
yourinformation with our service
providers helping us operatethe Service.

We will share your personal information with our service providers whoassist us with the internal operations of the Service such as backup andstorage services like AWS and Google Cloud. These companies areauthorized to use your personal information in this context only asnecessary to provide these services to us and not for their own
promotional purposes.

Wewillshare
yourinformation with competentauthorities, if you abuse yourright to use the Software, orviolate any applicable law.

If you have abused your rights to use the Software, or violated any
applicable law, we may share your information with competent authorities
and with third parties (such as legal counsels and advisors), for the purposeof handling of the violation or breach.

Wewillshare
yourinformation if we are legallyrequired.

If we are required to disclose your information by a judicial, governmental
or regulatory authority.

We
will
share
yourinformation with third parties
in any event of change in ourstructure.

If the operation of the Service is organized within a different framework, orthrough another legal structure or entity (such as due to a merger oracquisition), we will share your information only as required to enable thestructural change in the operation of the Service.

SECURITY AND DATA RETENTION
WewillretainyourRegistration Information for as
long as we need it for theprovision of the Service, andthereafter for compliance andlegal purposes.

We will retain your Registration Information and Software Learning
Information for the duration needed to support our ordinary businessactivities operating the Software and providing you the Service. Thereafter,
we will still retain your personal information as necessary to comply with
our legal obligations, resolve disputes, establish and defend legal claims andenforce our agreements.

We will store your Content aslong as you will not request its
deletion.

As part of our Service given to you, we will store your Content for as long as
your subscription runs and as long as you will not request to delete yourContent from the Software. To the extent selected by Customer, we will
provide you with backup services as well.
Nevertheless, we highly recommend that you backup your Content by
yourself. It is not guaranteed, and you cannot expect that the Software will
be immune from errors. ImagenAI will not be liable for any loss or damage s
resulting from unintentional deletion of Content. In case you cancel yoursubscription or fail to timely make any payment of subscription fees upon
30 days from receiving a notice from ImagenAI, ImagenAI may, at its sole
discretion, delete the backup data.

We implement measures tosecure your Information

We implement measures to reduce the risks of damage, loss of information
and unauthorized access or use of information. However, these measures
do not provide absolute information security. Therefore, although efforts
are made to secure your personal information, it is not guaranteed, and you
cannot expect that the Software will be immune from information security
risks.

INTERNATIONAL DATA TRANSFERS
We
will
internationallytransfer your Information onlyin accordance with applicabledata protection laws.

If we transfer your personal data for processing at locations outside yourjurisdiction, we will abide by data transfer rules applicable to thesesituations.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EU
ImagenAI is the data controllerof the personal data we collectvia the Software.

The following is the data controller for the purposes of the personal data
we collect via the Software:
Yotam Gil, ImagenAI
Ariel Sharon 4, Givatayim

ContactdetailsofourEuropean representative.

Our European representative, for the purposes of this Policy, will be
appointed when necessary, under applicable law and according to theGDPR. In the meantime, please contact the data controllers, ourrepresentatives in Israel as mentioned above, in : support@imagen-ai.com.
Legal basis under EU law forprocessing your personal data.

The legal basis under EU law for processing your Registration Information is
the performance of our Terms of Use contract with you and our legitimate
interest in the operation of the Service.
The legal basis under EU law for processing your Software Learning
Information is the performance of our Terms of Use contract with you.
The legal basis under EU law for processing your Analytics Information is ourlegitimate interest in providing, maintaining, developing and enhancing theSoftware.

The legal basis under EU law for processing your data for the purpose ofhandling instances of abusive use of the Service is our legitimate interest indefending and enforcing against violations and breaches that are harmful
to our business.
The legal basis under EU law for processing your data where we are legallyrequired to share it, is our legitimate interest in complying with mandatory
legal requirements imposed on us.
The legal basis under EU law for processing your data in the event of achange in our corporate structure is our legitimate interest in our business
continuity.
You have certain rights toaccess, update or delete yourinformation, obtain a copy ofyour information, withdraw
your consent and object orrestrict certain data processing
activities.

If you are in the EU, you have the following rights under the GDPR:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and tohave incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you
provided to us, in a structured, commonly used and machine -readable
format. You have the right to transmit this data to another service provider.
Where technically feasible, you have the right that your personal data betransmitted directly from us to the service provider you designate.
Right to Object, based on your particular situation, to using your personal
data on the basis of our legitimate interest. However, we may override theobjection if we demonstrate compelling legitimate grounds, or for theestablishment, exercise of defense of legal claims.
Right to Restrict the processing your personal data (except for storing it) if
you contest the accuracy of your personal data, for a period enabling us toverify its accuracy; if you believe that the processing is unlawful and you
oppose the erasure of the personal data and request instead to restrict its
use; if we no longer need the personal data for the purposes outlined in thisPolicy, but you require them to establish, exercise or defense relating tolegal claims, or if you object to processing, pending the verification whether
our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when you
object to us processing your data and we have no compelling legitimate
grounds to override your objection, you have the right to ask us to erase
your personal data. However, we may still process your personal data if it isnecessary to comply with a legal obligation that we are subject to underlaws in EU Member States or for the establishment, exercise or defense oflegal claims.
If you wish to exercise any of these rights, contact us at support@imagenai.com
We reserve the right to ask for reasonable evidence to verify your identity
before we provide you with information. Where we are not able to provide
you with information that you have asked for, we will explain the reason for
this.

Cross-border transfers

Information we collect from you will generally be processed within the EUand in Israel which is recognized by the European Commission as having
adequate protection for personal data.
If we transfer your information from the EU to other jurisdictions outside
the EU, we will do so using adequate safeguards determined by the EUCommission, such as Privacy-Shield certified companies in the UnitedStates.
You have a right to submit acomplaint to the relevantsupervisory data protection
authority.

Subject to applicable law, you have the right to lodge a complaint with yourlocal data protection authority. If you are in the EU, then according to Article
77 of the GDPR, you can lodge a complaint to the supervisor y authority, inparticular in the Member State of your residence, place of work or place ofalleged infringement of the GDPR. For a list of supervisory authorities in theEU, click here.

MINORSThe Service is not directed toindividuals under 18.

The Service is not directed to users under the age of 18. We do notknowingly collect information or data from children under the age of 18 or
knowingly allow children under the age of 18 to use the Service.

CHANGES TO THIS PRIVACY NOTICE
If we change this Notice, wewill
makeefforts
toproactively notify you of suchchanges.
Last Update: July 3, 2023.

From time to time, we may change this Notice. If we do so, we will makeefforts to proactively notify you of such changes by email. In any event, thelatest version of the Notice will always be accessible at imagen-ai.com.