Privacy Policy

Privacy Policy (Builda)

Effective as of June 6th, 2026

Last updated: June 6th, 2026

Version 1.0

This Privacy Policy describes how Oceano HK Holding Limited (“Company”), and our website and mobile application (collectively, “Builda”, “we,” “us,” or “our”) collect, use, disclose, transfer and store your Personal Data when you access our website or use the Builda mobile application, services, online platform or any other digital properties (collectively, the “Services”) as well as what choices you have about it.

Builda’ Services allows users to convert unstructured data—such as text and image prompts—into AI-driven 2D/3D content, including images, models, textures, animations, and interactive elements. You can also order customized physical products (such as figurines, accessories and keycaps, etc.) produced from such content from our platform. Please read carefully and fully understand this Privacy Policy together with our Terms of User Agreement to make choices that you deem appropriate before using the Builda’ Services.

The Privacy Policy only applies to the Personal Data we collect.

The Privacy Policy will help you understand the followings:

Index

1.Definitions

2.Collecting and Using Your Personal Data

3.How We Store Your Personal Data

4.How and When We Share Your Personal Data

5.Your Rights and Choices

6.Security

7.How Your Personal Data Transferred Globally

8.Our Policy on Children’s Data

9.Other Sites and Services

10.How We Make Changes to This Policy

11.Contact Us

Annex 1 – Privacy Notice for U.S. State Residents

1. Definitions

“Collect” refers to the behaviour of gaining control over Personal Data, including voluntary provision by the data subject, automatic collection by interaction with the data subject or recording the behaviour of the data subject, and indirect acquisition by sharing, transferring and collecting public information.

“Controller” refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Children” is a term defined differently under different jurisdictions, e.g., it refers to an individual who is under the age of 13 pursuant to Children’s Online Privacy Protection Act (“COPPA”), in the U.S.

“Delete” refers to the behaviour of removing Personal Data from the system involved in the implementation of daily business functions, so that it cannot be retrieved and accessed.

“Personal Data” refers to any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” refers to any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Publicly disclose” refers to the behaviour of releasing information to the society or to non-specific groups of people.

“Share” refers to the process of Personal Data controller providing Personal Data to other controllers, and both sides have independent control over Personal Data.

“Third Parties” refer to companies or persons who do not have a related relationship arising out of joint ownership or control with Builda (i.e., a non-Affiliated Company) or other non-related persons. Third parties can be financial or non-financial companies, or persons other than you and Builda;

“Transfer” refers to the process of transferring Personal Data control from one controller to another.

“You” or “your” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

“Prompts” refers to the text or image inputs you provide to the Services in order to generate content.

“Outputs” refers to the content (such as images and 2D/3D models) that the Services generate in response to your Prompts.

“Sensitive Personal Data” refers to categories of Personal Data that are afforded special protection under applicable law, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, precise geolocation, government identifiers, or financial account information.

2. Collecting and Using Your Personal Data

2.1 Personal Data that We Collect

Builda collects information for more efficient operations and provides you with the best product experience. We collect Personal Data in a few different ways including: (1) information directly provided by you; (2) data recorded by us about how you interact with our products; (3) data from Third Parties.

2.1.1 Information you provide to us

When you use Builda’ Services, you voluntarily share certain information.

• Account and login information: you can create an account and sign in using your Google account or your Apple ID. We use your email address as your unique account identifier. If the email associated with your Google and Apple sign-in is the same, we may merge them into a single account; if you sign in with Apple using a non-email Apple ID, we may ask you to confirm and bind an email address.
• Basic information: when you join our Services, we collect information like name, email address, country of residence, and preferred language.
• Profile data: a username, profile picture, and other optional information you choose to add to your profile, which may include gender, date of birth, preferred language, and a short bio or personal description.
• Payment and Transaction data: when you subscribe to paid Services, purchase points/credits, or order customized physical products, you provide payment information to our third-party payment processors (we currently support credit/debit card payments and PayPal). This typically includes your name, billing address, and payment card or payment account details. Our third-party payment processors receive and process your payment information directly; we typically receive and may store limited billing information—such as the last four digits of your card, card expiration date, and transaction history—to provide customer support and manage your account. We do not directly store your full payment card number. We also collect and store information about your points/credits balance, purchase history, and order history.
• Order and delivery information: when you order a customized physical product from Builda, we collect the information needed to produce and deliver it, including the recipient’s name, shipping address, postal code, contact phone number, and country/region, together with your order details. If you place an order on behalf of another person, you confirm that you have obtained their consent to provide their information to us.
• Referral information / inviting friends: when you invite a friend to the Services (for example, through a referral feature), we collect the information you provide about your friend, such as their email address. By providing this information, you confirm that you have your friend’s consent to share their details with us for this purpose. We use this information to send the invitation and, where applicable, to administer and track our referral program.
• Your communications with us: if you contact us through the Services or social media (including through our third-party support channel, including Discord) for customer support, provide feedback, or otherwise communicate with us, we collect the content of these communications.
• User-generated content data: the text or image prompts you provide (the “Prompts”), the AI-driven 2D/3D models and other content you generate (the “Outputs”), and other content you create, upload, submit, post, or otherwise make available through the Services—such as photos, images, models, textures, animations, comments, and content you publish to public areas of the Services (for example, a creation showcase feed)—including your history of such Prompts and Outputs and associated metadata. Metadata includes information on how, when, where and by whom content was collected, and how that content has been formatted or edited. We do not actively solicit or intend to collect “Sensitive Personal Data” (such as data revealing racial or ethnic origin, political opinions, religious beliefs, or health) as part of your Prompts. You should avoid inputting such information; if you do include it, you do so voluntarily.
• Marketing data: such as your preferences for receiving our marketing communications and details about your engagement with them.
• Creator and artist information (where applicable): if, in the future, you take part in any creator or artist program we make available, or you enter into a separate agreement with us, we may collect additional information from you in connection with that program or agreement—for example, information needed to set up and administer your participation and, where you are eligible to receive payments, to process payments to you and comply with applicable tax and legal requirements. The specific information we collect for these purposes will be as described in the applicable program terms or separate agreement.

Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

2.1.2 Technical information when you use and interface with our Services

When you use a website or other internet service, certain internet and electronic network activity information gets created and logged automatically via event tracking and other technical methods, which is adopted for device performance detecting, user behavior analysis and subsequent product optimization. This is also true when you use Builda. Here are some of the types of information we collect:

• Device information: we collect information about the device you use to access our Services, including the type of device, operating system, network service provider, settings, and unique device identifiers.
• Log data: when you use our Services, our servers record information, including information that your browser automatically sends whenever you visit a website. This log data includes, for example, your Internet Protocol (IP) address, activity on websites you visit that incorporate Builda features browser type and settings, and the date and time of when you accessed the Services.
• Cookies and similar technologies: some of our automatic data collection is facilitated by cookies and similar technologies. We will also store a record of your preferences in respect of the use of these technologies in connection with the Services.
• Usage data and inferences: when you’re on our Services, we use your activity—such as which posts you click on, terms you search for, our interactions with our community and rewards features (such as “want it”, following, and comments), and any text that you add in a comment or description—along with other information you’ve provided when you first signed up and information from our partners and advertisers to make inferences about you and your preferences.
• User Choices: We will keep a record of choices you’ve selected in your settings.

2.1.3 Third Parties (such as our partners and advertisers) share information with us

We also receive information about you and your activity outside Builda from our affiliates, advertisers, partners and other third parties we work with. For example:

• Google and Apple (sign-in): When you register or log in using Google or Apple, they will furnish certain information to us to facilitate your account creation or log-in with us. By registering and logging in through these third-party accounts, you consent to the third party providing us with the relevant Personal Data.
• Payment processors: our third-party payment processors may provide us with information related to your payment status or transaction confirmations.
• Technical service partners: We sometimes receive information about you from technical service partners.
• Advertisers or other partners: Online advertisers or third parties share information with us about you to measure, report on or improve the performance of ads on Builda, or to help us better understand what kinds of ads to show you on Builda. This may include information about how you interacted with our advertisements or referral links before or around the time you installed or first opened our application, which we and our attribution and measurement partners use to attribute installs, conversions and referrals to their advertising, campaign or referral source and to measure the performance of our marketing and user-acquisition campaigns.

2.2 How We Use your Personal Data

We process your Personal Data for purposes described in the Privacy Policy based on your prior consent and our legitimate interests. We also process your Personal Data pursuant to legal obligations imposed on us or to perform contracts between Builda and you such as the Terms of Use Agreement. Builda will strictly comply with the Privacy Policy and its updates to use your Personal Data. If your Personal Data is used for other purposes that is not stipulated in the Privacy Policy, we will additionally obtain your specific consent or other legal basis. Examples of our processing activities are as follows:

2.2.1 Service Delivery and Maintenance

We’re committed to showing you content that’s relevant, interesting and personal to you. To do that, we may use your Personal Data to:

• Identify you when you use our Services;
• Manage your registration as a user of the Services (via Google or Apple sign-in). The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user;
• Provide the AI 2D/3D content-generation features and give you access to and management of your generation history (Prompts and Outputs);
• Process your orders, subscriptions, points/credits and payments, and produce, fulfill, and ship customized physical products to you;
• Establish and maintain your user profile on the Service;
• Provide, operate, maintain and improve the Services and our business;
• Personalize the Services, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Services;
• Operate social and community features of the Services—such as a creation showcase feed, following, comments, and the “want it” and referral features—and, where available, suggest content or creators that may interest you;
• Provide you with Service-related general information, announcements, news, updates, security alerts, and support and administrative messages;
• Communicate with you about events, promotions and contests in which you may be interested in, or you participate;
• Understand your needs and interests, and personalize your experience with the Services and our communications;
• Provide customer support for our Services, and respond to and manage your requests, comments, questions and feedback.

2.2.2 Product & Services Improvement and Analytics

As part of our efforts to improve Services provided by Builda, we may use your Personal Data to analyze product usage condition so as to constantly create, develop, and analyze business operation efficiency, and include new features and functions. Specifically, we use the information we collect to:

• Create aggregated, de-identified and/or anonymized data from Personal Data we collect. We make Personal Data into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with Third Parties for our lawful purposes of this Privacy Policy and our business, including to analyze and improve the Services and promote our business, and will not attempt to re-identify any such data; and
• Analyze your usage of the Services so as to constantly create, develop and improve the Services, improve the rest of our business, include new features and functions, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Services, as well as user interactions with our emails, and to develop new products and services.
• Based on our legitimate interests in operating, securing and improving the Services and our technology, operate, develop, train and improve our own AI models, algorithms and related technology (including for labeling, classification, content moderation and model-training purposes) using data derived from your use of the Services, including Prompts and Outputs. We apply appropriate safeguards and, where feasible, endeavor to de-identify or aggregate such data before using it for these purposes. You can opt out of our use of your Prompts and Outputs to train and improve our models at any time through your account settings or by contacting us at the address in the “Contact Us” section; opting out will not affect any processing carried out before we receive your request.

2.2.3 Compliance and protection

We use your information in our efforts to keep our users and the public safe, and to protect legal interests. To do so, we may use your personal information to:

• Review your activity and messages on our Services to detect spam or activity that poses a risk to our community or the public. This can include working with law enforcement to keep Builda safe;
• Analyze users’ log data and device information to identify and investigate suspicious behavior or violations of our policies or terms;
• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• Access user information in relation to a legal claim, litigation, or regulatory proceeding;
• Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• Enforce the terms and conditions that govern the service; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

2.2.4 Limits on Use of Your Google User Data

Notwithstanding anything else in this Privacy Policy, if you provide Builda access to your Google data, our use of that data will adhere to the Google API Services User Data Policy andLimited Use Policy and will be subject to these restrictions, as required by Google:

• We will only use our access to read, write, or modify your Google data to perform the specific services that you request from us (for example, to authenticate you and create or access your Builda account), and we will not transfer the Google data to others unless doing so is necessary to perform such services, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
• We will not allow humans to read the Google data unless doing so is necessary to perform the services or tasks that you’ve requested of our specialists or guides, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.

2.2.5 Limits on Use of Information from Sign in with Apple

If you choose to sign in using Sign in with Apple, Apple shares with us only the information you authorize, which may include your name and either your personal email address (or private-relay email address you authorize Apple to share).

We use this information solely to authenticate you and to create, secure and operate your account, and we handle any private-relay address in accordance with Apple's requirements. We do not use information obtained through Sign in with Apple for advertising, profiling, or any purpose unrelated to your account without your consent. You can manage the information you share, disable forwarding for the private-relay address, or revoke this application's access at any time in your Apple ID settings. For more information about how Apple processes your data, see Apple's Privacy Policy at https://www.apple.com/legal/privacy/.

2.3 How We Use Cookies and Similar Technologies

Using cookies can help you personalize your online experience. You can accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser's settings to reject cookies if you want. Cookies do not track personal data. We may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Services, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Services, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.

You can choose to enable or disable cookies in your Internet browser. Most Internet browsers also allow you to choose whether you want to disable all cookies or only third-party cookies. By default, most Internet browsers accept cookies, but this can be changed. For more information, please see the help menu in your Internet browser or the documentation that came with your device.

The following link provides instructions on how to manage cookies in the relevant browser:

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• IE: https://support.microsoft.com/en-us/help/260971/description-of-cookies
• Safari (Desktop): https://support.apple.com/kb/PH5042?locale=en_US
• Safari (Mobile): https://support.apple.com/en-us/HT201265

If you use other browsers, please refer to the documentation provided by the browser manufacturer.

Please note that if you refuse to use, or clear existing cookies, you may need to change your user settings personally for each visit, and we may not be able to provide a better and quality experience to you or parts of our services may not function correctly.

3. How We Store Your Personal Data

We will strictly abide by our internal retention policy to store your Personal Data. We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, except a longer period required by applicable laws and regulations or your explicit consent. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will either remove the Personal Data exceeding the above retention period upon expiration from our systems or depersonalize it so that we can't use it to identify you.

Retention periods vary depending on the type of data and the purpose for which it is used. We keep your account and profile data for as long as your account remains active, and your Prompts, Outputs and generation history for as long as needed to provide the Services to you, unless you delete them or close your account earlier. Where you place orders for physical products or make payments, we retain the related order, transaction and tax records for the period required by applicable accounting, tax, anti-fraud and consumer-protection laws, even after your account is closed. We may also retain certain data for a limited period as necessary to resolve disputes, enforce our agreements, or comply with our legal obligations.

4. How and When We Share Your Personal Data

We may share your Personal Data with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection:

• Service Providers, Third Party Vendors, Consultants, and other Business Partners: We may share your Personal Data with these parties in order to provide services on our behalf, monitor and analyze the use of our Services, or help us operate the Services or our business. These may include:

1. Cloud hosting and storage providers (including providers located outside your country) that host and store data for the Services;
2. Third-party payment processors that process your payments and transactions (for example, PayPal and our credit- and debit-card payment processors) and, where you pay by card, the relevant card networks and your card-issuing bank, as needed to authorize and complete your transaction;
3. Third-party AI model, tool and infrastructure providers that support or are integrated into the generation features. For example, when you use the Services to generate certain images or visual effects, your prompts and related inputs may be processed by these third-party AI models, tools or providers in order to produce the Outputs you request;
4. Manufacturing, production, fulfillment and logistics partners (which may be located overseas) that produce and ship your customized physical products, together with international couriers and delivery partners;
5. Customer support providers, including our third-party support channel;
6. Email delivery and marketing service providers that help us send communications and administer our marketing.

• **Third Parties designated by you. **We may share your Personal Data with Third Parties where you have instructed us or provided your consent to do so. For example, when you decide to link your Builda account to third party services, or when you publish your content on Builda to such services, you direct disclosure of certain information to those services.
• Business Partners and Professional advisors. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or Services, or whose products or Services may be of interest to you. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Advertising Platforms and Marketing Partners: We may share limited Personal Data (such as device identifiers, hashed email addresses, or information about actions you take on our Services, like account registration) with advertising and marketing platforms (for example, Google and Meta) and with attribution, measurement and analytics providers (including mobile measurement partners) to help us reach individuals who might be interested in our Services, to attribute installs, conversions and referrals to their advertising, campaign or referral source, to measure and improve the performance of our advertising and of our referral and user-acquisition campaigns, to personalize the content, recommendations and ads you see, and to create custom audiences. You may have choices regarding this type of sharing through your settings on those third-party platforms, through our cookie controls (if applicable) or
• Affiliates: We may share Personal Data with our corporate parent, subsidiaries and other affiliated companies for purposes consistent with this Privacy Policy and for legitimate business operations. For example, certain features or parts of the Services may be provided or supported by our affiliates; in those cases, we require them to protect your Personal Data in accordance with data protection standards consistent with this Privacy Policy.
• **Law Enforcement Agencies, Government Agencies, Researchers, or Other Parties in Compliance with Laws, Rules, or Regulations. **For example, we may get requests for account information from law enforcement authorities like the police or courts. We only disclose information in response to such requests if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Builda; or to detect, prevent, or otherwise address fraud, security or technical issues. We may also share information if we believe it is necessary to prevent imminent and serious bodily harm to a person in emergency situations.
• Business Transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Builda, financing of Builda, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Builda as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
• Aggregated or De-identified Data: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with Third Parties for research, marketing, analytics or other purposes.
• Other users and the public. Your profile and other user-generated content data (except for messages) may be visible to other users of the Services and the public. For example, content you post to public areas such as the creation showcase feed, and your public interactions such as comments, follows and “want it” votes, can be seen by other users and the public. Once content is public, such information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. You should not include in public content any information you wish to keep private.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

5. Your Rights and Choices

We offer you certain choices to control your data. Depending on where you live, these choices may also be privacy rights you have under local law. To exercise these rights, please visit your account settings.

• Right to Know: We publish the Privacy Policy to inform you of how we handle your Personal Data. We are committed to the transparency of the use of your Personal Data.
• Access Right: You are entitled to exercise your access right to visit data.
• Opt-out of Communications: You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Opt-out of AI model training: you may opt out of our use of your Prompts and Outputs to train and improve our own AI models at any time through your account settings or by contacting us. Opting out will not affect any processing carried out before we receive your request.
• Right of Rectification: If you find there is a mistake with your Personal Data we process, you are entitled to ask us to make rectifications. When your identity is confirmed, we will rectify accordingly.
• **Right to Delete: **you may make a request to us to delete your Personal Data under the following circumstances:

1. Our processing of your Personal Data violates the applicable laws or regulations;
2. We collect or use your Personal Data without your prior consent;
3. Our processing of your Personal Data violates the agreement with you;
4. You stop using our products or services;
5. We no longer provide you with products or services;
6. Other circumstances stipulated by the laws and regulations.

• Delete your content or close your account: You can choose to delete your account, which deletes all of your assets tied to that account. If you wish to request to close your account, please contact us or request that we delete your account from within Builda’ websites.
• **Right to Restrict Processing: **You are entitled to request Builda to restrict processing of your Personal Data under the following circumstances:

1. You contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of the Personal Data;
2. The processing is unlawful and you oppose the erasure of your Personal Data and requests the restriction of their use instead;
3. We no longer need your Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
4. You have objected to processing, pending the verification whether the legitimate grounds of us override those of you.

This means we can store your Personal Data but cannot process it.

• Right of Data Portability: To the extent permitted by laws and regulations, you are entitled to obtain your Personal Data in a structured, commonly used, and machine readable format. For instance, if you decide to change the service provider, this right enables you to reliably and safely move, copy or easily transfer your Personal Data between IT systems without affecting its use.
• Right of Refusal: To the extent permitted by the applicable laws and regulations, you have right to refuse our processing for these purposes.
• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
• **Linked third-party platforms. **If you choose to connect to the Service through a third-party platform like Google, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
• Right to Withdraw Consent: If you agree to our processing of your Personal Data but later changes mind, you can withdraw your consent at any time and we must stop processing.
• Right to Refuse Automated Decision: You have rights not to be bound by automatic decisions (if any), including user profiling. If these decisions will significantly affect your legitimate rights, you can refuse to be subject to automated decisions. We will respond to your request and take appropriate measures when necessary.
• Right to Complaint: You are entitled to file a complaint with the data protection authority of your country about our processing of your Personal Data.

6. Security

The security of your Personal Data is important to us. We have taken safeguarding measures in accordance with industry standards to protect the Personal Data you provided and prevent data from unauthorized access, public disclose, use, modification, damage or loss.

With regard to the security control of data access and use, we have implemented a strict data authorization control mechanism, adopted multiple identity authentication technology, and monitored the processing of your personal information to prevent illegal access and unauthorized use of data. We also monitor the entire lifecycle of data to protect your personal information from unauthorized access, public disclosure, use, modification, and intentional or accidental damage or loss, etc. We employ encryption for data in transit and at rest where appropriate, and we conduct regular security assessments and updates to our security practices, in accordance with industry standards and applicable laws.

The security of your Personal Data also depends on you. Your account is accessed through your Google or Apple sign-in, and you are responsible for maintaining the security of your linked account and for any activities that occur under your account. We recommend that you access the Services only in secure environments, use strong authentication, and sign out after use. If you believe the security of your account or Personal Data has been compromised, please contact us immediately at legal@mathmagical.com.

However, please be attention, even if we undertake reasonable measures to protect your data, there is no website, internet transmission, computer system or wireless connection that are definitely safe. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In case of Personal Data security incident where it is likely to result in a high risk to the rights and freedoms of you, we shall communicate the Personal Data breach to you in accordance with the requirements of laws and regulations such as basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc.

We will inform you in a timely manner by email, mail, telephone, push notification, etc., regarding the relevant situations of the incident. When it is difficult to notify each Personal Data subject individually, we will issue a notice in a reasonable and effective manner. In the meantime, we will take the initiative to report on the handling of Personal Data security incident in accordance with regulatory department’s requirements.

7. How Your Personal Data Transferred Globally

Builda is a worldwide service, and cross-border transfer and storage of your Personal Data is an inevitable part of providing the Services. By agreeing to the Privacy Policy and using our Services, you authorize us to transfer and store your Personal Data outside your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction, for the purposes described in this Privacy Policy. Your Personal Data may be stored and processed in countries other than the one in which you are located, including countries where our group companies, our service providers, and our production and logistics partners operate.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Our Policy on Children’s Data

Our services are not designed to target children, and therefore, we do not intentionally collect any data pertaining to children. We do not knowingly gather personally identifiable information from any children as defined by applicable laws.

If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us immediately. We take the privacy and protection of children's data very seriously. Should we become aware that we have inadvertently collected Personal Data from any child without obtaining verifiable parental consent, we will promptly take all necessary steps to remove such information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

9. Other Sites and Services

The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

10. How We Make Changes to This Policy

We may change this Privacy Policy from time to time and if we do, we’ll post any changes on this page and update the “Last updated” date at the top of this Privacy Policy. If the changes are significant, we may provide a more prominent notice, such as by sending you an email.

You are advised to review this Privacy Policy periodically for any changes. If you continue to use Builda after those changes are in effect, the new policy applies to you.

11. Contact Us

If you have any concerns or doubt over our Privacy Policy or our practices, please contact us via following channels: The data controller responsible for your Personal Data is Oceano HK Holding Limited.

1. logging on the Builda products and/or services interface to provide feedback, consultation and complaint to our online customer service (including through our third-party support channel);
2. sending email to legal@mathmagical.com.

Any review and processing will normally be completed within thirty (30) days after verifying your user identity. If it takes more time to respond to your request or if we are unable to respond to your request, we will send you a notice and explain the reasons within the maximum timeframe required by law.

Annex 1 – Privacy Notice for U.S. State Residents

This Annex provides additional privacy disclosures and rights and supplements the rest of this Privacy Policy. It applies to you if you are a resident of, or your Personal Data is collected while you are in, one of the U.S. states listed below that has enacted a comprehensive privacy law. If there is any conflict between this Annex and the rest of the Privacy Policy with respect to such residents, this Annex controls.

• Part 1 applies to residents of California.
• Part 2 applies to residents of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire and New Jersey.

Part 1 – California Residents

This Statement applies solely to residents of California or individuals whose information has been collected in California. Builda has adopted and included this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms used in this Statement that are defined in the CCPA have the same meaning given therein.

1. INFORMATION WE COLLECT

1. YOUR ADDITIONAL RIGHTS AND CHOICES

The CCPA provides individuals residing in California or whose Personal Information was collected in California with specific rights regarding their Personal Data. We recognize and protect your lawful rights under CCPA and other California Law. You may exercise your rights at any time via methods stipulated below. Besides, you also have the following rights:

• **Right to Know Information Regarding Participation in Data Sharing for Financial Incentives: **We will ask for your consent before collecting your Personal Data in connection with offering a financial incentive.
• **Right to Opt Out of Sale or Sharing of Personal Data and Targeted Advertising: **You have the right to opt out of the “sale” or “sharing” of your Personal Data and of the use of your Personal Data for cross-context behavioral (targeted) advertising. While we do not sell your Personal Data for monetary consideration, our sharing of certain identifiers and activity data with advertising platforms for the purposes described in this Privacy Policy may be considered a “sale” or “sharing” under applicable law. You may exercise this right through your cookie and advertising settings or by emailing us at legal@mathmagical.com, and we will treat an opt-out preference signal that we detect as a valid request to opt out for that browser or device. Your right to opt out does not apply to our sharing of Personal Data with service providers who are contractually obligated to use it only on our behalf.
• Right to be Free from Discrimination: You may always exercise all rights and we will not unlawfully discriminate against you for exercising your rights under the CCPA.
• “Shine the Light” Law: Residents of the State of California also have the right to request information regarding Third Parties to whom Builda has disclosed certain categories of Personal Data during the preceding year for the Third Parties' direct marketing purposes. If you are a California resident and you wish to opt out, please send us an email at legal@mathmagical.com.

Part 2 – Residents of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire and New Jersey

This Statement applies solely to residents of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire and New Jersey, or to individuals whose Personal Data is collected while they are in these states. These states have enacted comprehensive privacy laws that grant their residents the rights described below. Any terms defined in the applicable state privacy law have the same meaning when used in this Statement, and each right applies only to the extent, and subject to the exceptions, provided by the law of your state of residence.

• Right to Access and Know: you may request to confirm whether we are processing your Personal Data and to access that data.
• Right to Correct: you may request that we correct inaccuracies in your Personal Data, taking into account its nature and the purposes of processing (this right is not available in Iowa and Utah).
• Right to Delete: you may request that we delete Personal Data that you provided or that we obtained about you, subject to certain exceptions.
• Right to Data Portability: you may request a copy of the Personal Data you previously provided in a portable and, to the extent technically feasible, readily usable format.
• Right to Opt-Out: you may opt out of the processing of your Personal Data for (i) targeted advertising, (ii) the sale of Personal Data, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Right to Appeal: if we decline to act on your request, you may appeal our decision by contacting us at legal@mathmagical.commailto:legal@mathmagical.com within a reasonable time after our decision.

To exercise any of these rights, please use your account settings or email us at legal@mathmagical.com. We will not discriminate against you for exercising your rights. We may need to verify your identity before responding, and we will respond within the time period required by applicable law.