Introduction

This Privacy Policy describes how VERSE12, Inc. ("VERSE12," "we" or "us") may collect, share, and use the information you provide to us, or we otherwise collect, when you use any VERSE12 website, application, or service, that link to this Privacy Policy (collectively, the "Services"). We are responsible for providing the Services to you and are the controller of personal data processed under this Privacy Policy.

Note that your use of the Services is also subject to the VERSE12 Terms of Use ("Terms of Use"), available at https://VERSE12.com/terms. Please read this entire privacy policy and Terms of Use, and confirm you understand and agree to them, before using the Services.

Information We Collect

We collect information on and through our Services. The specific types of information we collect vary depending on the nature of our relationship with you and how you choose to interact with us, but may include personal data. Generally speaking, we collect information in three main ways: A) when you provide it to us, B) automatically when you use the Services, and C) from service providers and third parties.

A. Information You Provide

You can provide us with different kinds of information depending on how you interact with the Services. Sometimes we'll ask you to provide specific pieces of information, such as where we require it to provide parts of the Services to you (for example, by prompting you to complete an online registration process). If we ask you to provide us with information in these cases and you choose not to, you may not be able to access the relevant Services and/or some features may not operate as intended. For instance, to register as a user and create a profile, you'll need to provide us with basic registration information like your name, a public-facing display name, password, country that you live in, and email address. If you want to make a purchase or become a seller, we ask that you provide payment-related information (like your PayPal e-mail address, VAT number, and business location).

We also collect the information you voluntarily provide as part of your user profile (like avatar, biography, skills, and interests), to sign up for email alerts, use social features and forums (likes, follows, comments, search queries), use our tools (including to create and publish images and other content), complete surveys, or contact us for customer support. If you enter a contest or competitive event, we'll collect your application information and other information we may need to help confirm your eligibility and process rewards. We collect whatever information you choose to provide to us in those or other similar cases.

B. Information We Collect Automatically

We collect some information automatically when you visit, access, or use the Services. This includes information about your site or application usage, user interactions, purchases, and other activity in the Services, typically associated with your account profile or with an identifier we have assigned to your device or profile. While the specific types of information that we automatically collect may vary, they generally include:

• Usage information and statistics about how you interact with the Services, including the application you used, saved preferences, crash reports, commenting data (for spam prevention via Akismet), and navigation data (like the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page;
• Technical information about your computer, device, hardware, or software you use to access our Services, such as IP address, device identifiers, your internet service provider, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and
• The general location of your device, which we typically derive from your device's IP address.

The Services use technologies such as cookies, log files, and web beacons to automatically collect the types of information listed above. Some of these technologies may create small files or record-keeping tools that may be stored on your device. They help us, our service providers, and third parties recognize your device and provide information about how you use and interact with the Services. For example, they support our ability to authenticate users, remember preferences, personalize experiences, and conduct data analytics. Please see the "Cookies" section below of this Privacy Policy for further information about what information will be automatically collected when you visit our Services.

Please note that if certain features on the Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Services or others' websites over time. These features are subject to those third parties' privacy notices and policies.

C. Information We Collect from Other Sources

In some cases, we may also receive information about you from third parties or service providers in connection with your use of the Services or your interactions with us on other platforms. For instance, while using the Services, individuals may provide information about another individual, or an authorized user (such as an account administrator) creating an account on your behalf may provide information about you.

As another example, if you choose to sign in to your VERSE12 account with your account on a third-party (like Facebook) website or service, or if you interact with VERSE12 on an external website or service (like LinkedIn), the company that operates that website or service may share some information with us in accordance with their own privacy practices. Your privacy settings on the other company's website or service typically control the specific types of information they can share with us, so please be sure to review and update them regularly.

How We Use Your Information

As a general matter, we use the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyze, and promote the Services.

This includes using it for purposes such as:

• Creating use profiles, verifying and managing user accounts and features;
• Providing the Services, as well as support and assistance for them, including by responding to inquiries, processing transactions or requests, and communicating with users (such as by sending service and account-related messages and updates);
• Developing, delivering, and improving the Services and other offerings, some of which may be offered in partnership with other parties;
• Personalizing your experience, including by presenting content or features better tailored to you or your interests, or our inferences about your interests;
• Promoting the Services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, contests or challenges, surveys, and events;
• Conducting research and data analytics (like analyzing how the Services are used so we can better understand, improve, and personalize them);
• Complying with our legal or contractual obligations and enforcing our terms; and
• Securing the Services, such as by detecting fraud and otherwise protecting OXCORP and other users from illegal or harmful actions.

We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this privacy policy. But please note that this privacy policy does not restrict our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.

Recipients of Your Information

We may share your information with our related entities including our parent and sister companies, but only for the business purposes specified in this Privacy Policy.

We may otherwise disclose your information:

1. to business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you, for example for hosting and operating the Services or providing support and maintenance services for the Services;
2. to analytics and search engine providers and other selected third parties that assist us in the improvement and optimization of our website;
3. to our regulators, law enforcement, or fraud prevention agencies, as well as our advisors (including legal advisors and auditors), courts, and any other authorized bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters;
4. in the event of certain types of corporate transactions (like in connection with a restructuring or sale of all or a significant part of our business);
5. if we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of VERSE12, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
6. to legal advisors and otherwise in connection with legal proceedings to enforce or apply our rights under any contract; and
7. otherwise where we have notified you of the intended disclosure, and where required, you have expressly given your prior consent to such disclosure.

You may provide information or content to be published or displayed on public areas of the Services, or transmitted to other users of the Services or third parties (including through the Forum and Store). Although you may set certain privacy settings for such information by logging into your account profile, anyone may view such information or content that you choose to submit or post in this manner.

Privacy Settings / Controls

We seek to provide you with meaningful choices about the personal data we collect. The specific choices available to you often vary depending on how you interact with the Services:

• If we process your personal data based on your consent, you have the right to withdraw your consent at any time by updating the settings in your user profile or contacting us at [email protected].
• You can also change your email marketing preferences at any time by using the opt-out mechanism provided in our marketing emails.
• If you wish to modify any of your user profile information, restrict the processing of your personal data, or cancel your account, you may update the settings in your user profile or contact us at [email protected].
• You can request that we provide access to, or that we correct or delete, personal information we've collected from you. Please submit requests to access, update, or delete personal information associated with your VERSE12 account by contacting us at [email protected]. Note that we may ask you for additional information to help us verify who you are before completing your request.
• You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. In some cases, blocking or disabling cookies may cause the Services not to work as intended and some features may not be available.
• Some parts of the world provide individuals with specific choices related to their personal information by right under local law. For example, Where the French Data Protection Act is applicable, you have the right to make arrangements for the storage and communication of your personal data after your death. To exercise this right (or others), you can send us your instructions at [email protected].

Children's Privacy

Our Services are not intended for persons under the age of 18. Individuals under the age of 18 are not permitted to use the Services, and we do not knowingly collect personal data from persons under the age of 18. By using our Services, you represent that you are 18 years of age or older.

Our Global Operations

A. Data Transfers

We operate and support the Services from different locations around the world (including the United States), which may have different data protection rules to those where you are located. Regardless of where your personal data is stored or processed, we will take all reasonable steps necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

If we transfer your personal data collected in the European Union to locations outside of the European Economic Area (for example, the United States), we do so pursuant to transfer mechanisms, such as the EU Standard Contractual Clauses ("SCCs"), adopted by the European Commission to help establish adequate safeguards for your personal data. The current version of the SCCs can be found at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN.

Please contact us using the information in the Contact Us section below if you would like more information regarding the transfer mechanisms we use for such transfers, or if you would like us to provide you with a copy of them.

B. Residents of the European Economic Area, the United Kingdom, and Switzerland

If you're located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed. Under the GDPR and, to the extent applicable under other privacy laws, you may have the rights listed below:

• The right to request access to your personal data (through us providing a copy).
• The right to correct your personal data if it is not accurate or complete.
• The right to erase or delete your personal data where there is no longer a reason for us to continue to process it.
• The right to object to or restrict or block the processing of your personal data, such as for direct marketing.
• The right to obtain a portable copy of the personal data you have provided.
• The right to not be subject to automated decisions, where the decision has a legal or significant impact on you.
• Where you have provided your consent to our data processing, you have the right to withdraw your consent.

You can request to exercise these rights, with a proof of your identity, by emailing [email protected].

We will respond to any request received from you within one month from the date of the request. If your request is not sufficiently precise or does not include all elements enabling us to answer your request, VERSE12 may ask you to provide additional elements.

You may also have the right to lodge a complaint with the applicable data protection authorities. Please click https://edpb.europa.eu/about-edpb/about-edpb/members_en for information about EU data protection authorities, and https://ico.org.uk/ for information about the UK data protection authority. We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Basis for Processing

The legal bases we rely on to process your personal data depend on the Services you use and how you interact with them. They primarily include:

• Contractual Necessity: we process personal data to perform the Services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal data to set up and maintain your account; process your purchases; provide user-experience features (like saving likes and follows); monitor and analyze the Services; and detect and prevent fraud or other similar misuse. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.
• Legitimate Interests: we process personal data as needed for VERSE12's business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you'd reasonably expect, such as to: communicate with you, respond to your requests, or provide you with account updates, upgrades, and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the Services and other offerings (some of which may be offered in partnership with other parties); manage and customize VERSE12 advertisements or promotional offers; secure and protect the Services; prevent fraud and illegal activity; and support internal purposes such as auditing and data analysis.
• Legal Obligations: we process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes.
• Consent: we process personal data when you provide us with your consent to do so. You aren't required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time.

Retention

We retain personal data for as long as we reasonably need it to fulfill the purposes for which it was collected. For example, if you create an account with us, we will store the personal data associated with your account for as long as needed to maintain your account, provide the Services you requested, enforce any applicable terms that govern your use of the Services, and maintain appropriate records to reflect our delivery of the Services to you.

C. California Residents

Pursuant to California's Shine the Light law, you can control if we share personal information with third parties for their marketing purposes. To opt-out of us sharing personal information with third parties for such purposes, email us at [email protected] or write to us in the "Contacting VERSE12" section of this Privacy Policy and include "Marketing Opt-Out" in your request.

In addition, pursuant to the California Consumer Privacy Act ("CCPA"), California residents may have certain other rights concerning their personal information, as described below.

California Personal Information We Collect

During the past twelve (12) months, we and our service providers have collected the categories of personal information listed below as described in the CCPA, and further detailed in the "Information We Collect" section above.

• Identifiers (for example, name, postal address, email address, IP address, and online identifiers);
• Categories of personal information as defined by Cal. Civ. Code § 1798.80 (for example, credit or debit card information);
• Protected classifications under California or federal law (for example, demographic information like age);
• Commercial information (for example, transaction history);
• Internet or other electronic network activity information (including information on your usage of the Services);
• Geolocation data (such as location derived from your IP address or included in your billing information;
• Professional or employment related information (if included in your profile); and
• Inferences drawn from any information identified above to create a profile.

Use of California Personal Information

We may use each of these categories of California personal information that we collect for the business and commercial purposes described in the "How We Use Your Information" section above.

Sharing California Personal Information

We may disclose each of these categories of California personal information that we collect as indicated above to the categories of third parties described in the "Recipients of Your Personal Data" section above.

We do not sell California personal information, and we do not have actual knowledge that we sell California personal information of California consumers under the age of 16 years old.

Your Privacy Rights

If you are a California resident, you may have the right to 1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights.

If you would like to exercise rights under the CCPA, please send (or have your authorized agent send) an email to [email protected]. You can also contact us using the other methods listed in the "Contacting VERSE12" section below.

We cannot respond to your request or provide you with California personal information if we cannot verify your identity or authority to make the request and confirm that the California personal information relates to you. If you have an online account with us, we may deliver our written response to that online account. If you do not have an online account with us, we will deliver our written response by email or electronically. If we refuse to act on the request, we will provide you notice and the reason for our refusal.

Cookies

We may use various cookies or other tracking technologies on our Services for analysis and improvement. When you visit our Services, these technologies may be placed on your device for the following purposes:

• Internal cookies required to run the website in the best possible manner (including for user authentication, to keep your session active when logged-in, and to indicate the content to display a user);
• Audience measurement and analytics; and
• Third party cookies improving the interactivity of the Services (including to help run our Blog, Forum, and Help Center).

Manage cookie settings

You may adjust your browser or website preferences to accept or reject cookies and similar technologies from us. Please consult your browser's settings or help menu for more information. However, blocking cookies or similar technology might prevent you from accessing some of our content or features of the Services.

MANAGE COOKIES

Security

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website and apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your data transmitted to the Services. Any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorized access, including keeping security patches up to date, and by constantly investigating new ways to keep data secure.

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes in our practices or relevant laws. The most current version of the Privacy Policy will govern our use of your personal data and will always be located at https://VERSE12.com/privacy. If we make a material change to this Privacy Policy (for example, if the modifications concern the categories of data we process or the purposes of the processing), we will notify you via the Services or via email (to the email address associated with your account) within thirty (30) days before publication.

Contacting VERSE12

If you have any questions about this Privacy Policy, or the privacy practices of VERSE12 please email us at [email protected] or write to us at:

VERSE12, OXCORP

If you are in the European Union, you may write to us at:

VERSE123 OXCORP