PRIVACY NOTICE

Last updated March 9, 2026

This privacy notice for Hbrothers L.L.C. ("Hbrothers L.L.C.", "we", "us", or "our") describes how and why we collect, store, use, and/or share ("process") your information when you use our mobile application Haircut Simulator and related Services (collectively, the "Services"), for example when you:

Download and use our mobile application Haircut Simulator or any application that links to this notice;

Upload photos to generate an AI image; or

Interact with us via support, email, or social channels.

Questions or concerns? Reading this notice will help you understand your rights and choices. If you do not agree with our policies and practices, please do not use the Services. You can contact us at info@rivia.studio.

SUMMARY OF KEY POINTS

What do we collect? Photos you choose to upload, the AI images generated for you, and basic device/usage data. We do not require an account to use core features.

How do we use photos? To generate your requested AI image and to let you reuse uploaded parent photos and generated results for future generations. Your photos are sent to third-party AI services solely to generate the image you requested. Photos and generated results are stored securely on encrypted servers and remain until you uninstall the app, which deletes them from our servers. We do not use your photos or outputs to train AI models.

Do we sell or share your data? No. We do not "sell" or "share" your personal information for cross-context behavioral advertising. Your photos are shared with third-party AI services only as necessary to generate your requested image (see Section 4).

Your rights. Depending on where you live, you may request access, deletion, correction, portability, and to object or restrict processing. See Section 8. To delete stored photos and generated results, uninstalling the app will remove them from our servers.

TABLE OF CONTENTS

WHAT INFORMATION DO WE COLLECT? 1A. FACE DATA COLLECTION, USE, SHARING, STORAGE & RETENTION

HOW DO WE PROCESS YOUR INFORMATION?

WHAT LEGAL BASES DO WE RELY ON?

WHEN AND WITH WHOM DO WE DISCLOSE INFORMATION?

THIRD-PARTY WEBSITES & LINKS

HOW LONG DO WE KEEP INFORMATION?

HOW DO WE KEEP INFORMATION SAFE?

YOUR PRIVACY RIGHTS

CHILDREN'S PRIVACY

DO-NOT-TRACK

NOTICE FOR CALIFORNIA RESIDENTS

UPDATES TO THIS NOTICE

HOW TO CONTACT US

1. WHAT INFORMATION DO WE COLLECT?

Information you provide

In short: We collect personal information that you provide to us.

Photos & User Content: Images you upload to generate an AI image and the generated output returned to you. We do not extract or store biometric identifiers (e.g., faceprints) from your photos. Your photos are transmitted to third-party AI services solely for the purpose of generating the image you requested (see Section 4 for details).

Support & Feedback: Content of messages you send to us (e.g., email address, message text, attachments) if you contact support.

Purchases: If you buy a subscription or in-app product, we receive purchase confirmations from the app store; payment card details are handled by Apple/Google, not by us.

Information we collect automatically

In short: We collect minimal device and usage data to keep the app secure and working. This may include IP address, device model/OS version, app version, language, crash logs, and basic usage events. We do not create profiles for advertising.

App permissions

Camera & Photos: Used only so you can take or select images to generate the AI result.

Notifications (optional): To inform you about generation status or important updates. You can disable in device settings.

Sensitive information and biometrics

Some laws consider images of faces to be "biometric information." We do not create or store biometric identifiers and do not use your photos to identify anyone. We do not access or use device-level biometrics such as Face ID.

1A. FACE DATA COLLECTION, USE, SHARING, STORAGE & RETENTION

Haircut Simulator only processes the photos you choose to upload and the AI image generated for you. We do not collect facial recognition templates, embeddings, or geometry; any automated face detection used to center/crop is performed ephemerally and is not retained.

We collect images solely to generate and deliver the image you requested and to let you view/save/share it at your direction. We do not use face data for identification, advertising, profiling, or analytics, and we do not use your photos or outputs to train AI models.

To generate your AI image, your uploaded photo is transmitted to third-party AI processing services (see Section 4). These services receive your photo only to produce the requested result and are not authorized to retain, share, or use your photo for any other purpose, including AI model training.

Your uploaded parent photos and the generated results are stored securely on encrypted servers so you can reuse them for future generations. They will remain stored until you uninstall the app, which permanently deletes them from our servers.

At this time, the way to delete stored photos and generated results is to uninstall the app.

See Sections 1A (Face Data), 4 (Sharing), and 6 (Retention).

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to:

Provide the Service: Receive your photos, transmit them to third-party AI services to generate the AI image, return the result to you, and deliver features you request.

Maintain & Improve: Diagnose issues, prevent fraud/abuse, and understand app performance (e.g., crashes).

Support & Communication: Respond to your inquiries and provide important notices about the app.

Legal Compliance: Comply with applicable laws, lawful requests, and enforce our terms.

AI model training

We do not use your photos or generated images to train AI models. The third-party AI services we use are also not authorized to use your photos or results for model training.

3. WHAT LEGAL BASES DO WE RELY ON?

If you are in the EEA/UK: We process your information under these bases:

Consent: For uploading photos and transmitting them to third-party AI services, and, if applicable, optional notifications or minimal analytics; you can withdraw consent at any time.

Contract: To provide the Services you request (e.g., generate your AI image).

Legitimate Interests: To secure and improve the app (e.g., crash logs) in a way that doesn't override your rights.

Legal Obligations: Where processing is required by law.

If you are in Canada: We rely on your consent, which you may withdraw at any time, and on other grounds permitted by applicable law.

4. WHEN AND WITH WHOM DO WE DISCLOSE INFORMATION?

We do not sell or share your personal information for cross-context behavioral advertising. We may disclose information to the following parties:

Third-Party AI Processing Services

To generate AI images, your uploaded photo is transmitted to the following third-party services. These services receive your data solely to produce the result you requested. They are not authorized to retain your photos beyond what is necessary for processing, use them for model training, or share them with additional third parties.

Google Cloud (Vertex AI) -- receives your uploaded photo to generate AI hairstyle, hair color, and makeup images. Google processes this data in accordance with the Google Cloud Privacy Notice and Google Cloud Data Processing Terms.

Replicate, Inc. -- receives your uploaded photo to generate AI hairstyle images. Replicate processes this data in accordance with the Replicate Privacy Policy.

OpenAI -- receives text-based facial measurements only (no photos) for hairstyle suggestions. OpenAI processes this data in accordance with the OpenAI Privacy Policy.

Other Disclosures

Cloud Infrastructure (Google Cloud / Firebase): Your photos and generated results are stored on Google Cloud (Firebase) servers. Google processes this data in accordance with the Google Cloud Data Processing Terms.

App Stores / Payment Platforms: To process purchases and manage subscriptions (e.g., Apple App Store, Google Play).

Legal / Compliance: To comply with law, enforce our terms, or protect rights, safety, or property.

Business Transfers: In the event of a merger, acquisition, or asset sale, subject to this notice or a successor policy with comparable protections.

5. THIRD-PARTY WEBSITES & LINKS

Our Services may link to third-party sites or services. We are not responsible for their content or privacy practices. Review their policies before providing information.

6. HOW LONG DO WE KEEP INFORMATION?

Face Data Retention: Uploaded parent photos and generated results are stored securely on encrypted servers and retained so you can reuse them. They are kept until you uninstall the app, which permanently deletes them from our servers. We retain no facial templates or embeddings.

Third-Party AI Services: Photos transmitted to third-party AI services for processing are not retained by those services beyond the time necessary to generate your requested image.

Operational Logs: Minimal diagnostic data is retained only as long as needed for security, troubleshooting, and legal compliance and does not include face data.

7. HOW DO WE KEEP INFORMATION SAFE?

We use reasonable technical and organizational measures (e.g., encryption in transit, access controls). Data transmitted to third-party AI services is sent over encrypted connections. No system is 100% secure, and transmission is at your own risk. If a security incident occurs, we will notify you and/or regulators where required by law. Uninstalling the app triggers the deletion of your stored photos and generated results from our servers.

8. YOUR PRIVACY RIGHTS

Depending on your location, you may have rights to access, correct, delete, restrict, or object to processing, and to data portability. You may also withdraw consent at any time where processing is based on consent. To exercise rights, contact info@rivia.studio. We will respond in accordance with applicable law. To delete photos and generated results stored on our servers, uninstall the app.

EEA/UK users may lodge a complaint with a supervisory authority: EU contacts. Swiss users: FDPIC.

9. CHILDREN'S PRIVACY

The app is intended for adults to create novelty, synthetic images. Do not upload images of children unless you are their parent/legal guardian and have the legal right to do so. We do not knowingly collect personal information from children under 13 (or the applicable age in your jurisdiction). If you believe a child has provided us with personal information, contact us at info@rivia.studio and we will delete it.

10. DO-NOT-TRACK

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature. Because there is no uniform standard for DNT signals, we do not currently respond to them.

11. NOTICE FOR CALIFORNIA RESIDENTS

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA). We do not sell personal information. For questions or to exercise your rights, contact info@rivia.studio.

12. UPDATES TO THIS NOTICE

We may update this notice from time to time. The updated version will be indicated by an updated "Last updated" date. If we make material changes, we may notify you through the app or other means. We encourage you to review this notice periodically.

13. HOW TO CONTACT US

If you have questions or comments about this notice, you may email us at info@rivia.studio.