Open Labs, LLC Privacy Policy

Your privacy is important to us. It is the policy of Open Labs, LLC, a Wyoming limited liability company (“Open Labs,” “we,” “us,” or “our”), to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, across every website, mobile application, and service we own and operate — including https://openluxe.co and each of the properties listed below (collectively, the “Services”). OpenLuxe™ is a brand operated by Open Labs, LLC; references in this policy to OpenLuxe mean Open Labs, LLC acting through that brand.

Properties Covered by This Policy

Open Labs, LLC operates a family of related online properties that share a single account system, a single credit balance, and common infrastructure. This Privacy Policy applies to all of them:

• OpenLuxe — openluxe.co — the luxury social marketplace and business platform.
• OpenVerce — openverce.com — the open platform hub and Surface experience.
• OpenFlix — openflix.co — creator video, streaming, and monetization.
• HoodGuess — hoodguess.com — the real-estate location and price guessing game.
• StickerVerce — stickerverce.com — AI-generated collectible card universes, battles, and trading.
• VidVerce — vidverce.com, ReelReel — reelreel.co, and Baddles — baddles.co — video and social talent properties.

Because these properties share one account system, one profile, and one credit balance, Open Labs is the single data controller across all of them, and personal information you provide on one property may be used to operate your account on the others as described in this policy. We may add, rename, combine, or retire properties; a new property is covered by this policy from the date it begins operating, and we will update this list. Where a property collects a category of information the others do not — for example, gameplay and scoring data on HoodGuess, or the prompts you submit to generate cards on StickerVerce — that collection is described in the relevant section below and is used for the purposes stated there.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

This policy is effective as of 1 February 2023.

Last updated: 6 July 2026

Our Privacy Promises

Before the legal detail below, here is what you can count on from us in plain language:

• We do not sell your personal information. We do not sell, rent, lease, license, or trade your personal information — including your name, email, phone number, address, contacts, messages, listings, voice, biometric data, location, or AI-conversation history — to data brokers, ad networks, marketers, list resellers, or any other third party for money or other valuable consideration.
• We do not share your data with data brokers. We do not provide your personal information to data-broker companies, people-search sites, identity- graph providers, or commercial profile databases for their own monetization, targeting, or resale.
• We do not sell your contacts or address book. Contacts you import into your CRM, address book, or gifting tools are yours. We do not sell, license, or share them with marketers, recruiters, or third parties for their own purposes.
• We do not use your private messages, calls, or end-to-end-encrypted content to train AI for anyone else. Your private DMs, encrypted chats, voice calls, AI- agent conversations, and uploaded documents are used to operate the platform for you — not as training data sold or shared with third-party AI model vendors for their general-purpose model training, except where you have explicitly opted in or as required by a vendor solely to deliver the feature you requested.
• We honor your opt-out signals. We recognize and honor the Global Privacy Control (GPC) browser signal as a valid request to opt out of any sale or sharing for cross-context behavioral advertising under applicable U.S. state laws.
• You can leave with your data. You can export and delete your account and associated personal information at any time, subject to limited legal-retention exceptions described below.

These promises are binding commitments under this Privacy Policy. The detailed sections below describe specifically how we collect, use, and disclose information consistent with them.

Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

Log Data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Device Data

When you visit our website or interact with our services, we may automatically collect data about your device, such as:

• Device Type
• Operating System
• Unique device identifiers
• Device settings
• Geo-location data

Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Personal Information

Depending on how you use the platform, we may collect personal information including:

• Name, username, profile photo, and biographical info
• Email address(es), phone number(s), and physical / mailing address(es)
• Date of birth (where required for age verification)
• Account credentials (passwords are stored only in hashed form; we cannot read them)
• Two-factor authentication factors (TOTP secret, backup codes, security keys)
• Social media profiles, professional profiles, and external account links you connect
• Payment and billing information (processed by Stripe and other PCI-compliant processors — we do not store full card numbers)
• A limited, non-sensitive record of the payment method used for a purchase — the processor's own card reference, the last four digits, brand, expiry, issuing country and the billing name. We use this to detect payment and referral fraud, including where a single payment method has been used across accounts presented as belonging to different people. We never receive or store full card numbers or security codes.
• Tax identification information where required for reporting (e.g., W-9 / 1099 information for creators, sellers, and affiliates)
• Recipient information you provide for gifting
• Real-estate licensing and brokerage information for agent users
• Demographic and preference data you provide voluntarily

Identity Verification and Sensitive Documents

For certain features (such as escrow, KYC-gated verifications, agent verification, marketplace transactions, age verification, or compliance review), we or our verification provider (currently Didit and other licensed identity-verification vendors) may collect: government-issued ID images, selfie or liveness images, facial-recognition feature data used solely to match the selfie to the ID, date of birth, citizenship, and similar information. These documents are stored encrypted and are handled in accordance with our Data Policy. You may request deletion of stored verification documents subject to legal-retention requirements.

Communications and AI Conversation Data

When you use messaging, email, AI chat assistants, AI voice agents, AI copilots, in-app comments, support tickets, livestream chat, or other communications features, we may collect the content, metadata, attachments, transcripts, summaries, sentiment, and associated participant identifiers necessary to deliver those features. AI-agent prompts, completions, and tool invocations may be stored to provide history, debugging, safety review, abuse prevention, and quality improvement. End-to-end encrypted (E2EE) message content is encrypted on your devices and is not accessible to us or to AI providers in plaintext.

Voice, Call, and Biometric-Adjacent Data

If you use phone, voice, or AI-receptionist features, we and our service providers may capture, transcribe, analyze, and store: call audio, call metadata (caller ID, duration, route), transcripts, speech embeddings, summaries, post-call CRM extractions, and recordings from livestreams or video rooms. Some processing may involve voice-feature analysis used to deliver the voice feature itself (e.g., transcription accuracy or speaker diarization). We do not use your voice recordings to create voice clones for resale or third-party use, and we do not enroll your voiceprint in any external biometric identification system without your express opt-in consent. Where biometric or biometric-adjacent information is processed, we do so in accordance with applicable law (including the Illinois Biometric Information Privacy Act, Texas CUBI, and Washington's My Health My Data Act, where applicable).

Voice Unlock. If you opt in to Voice Unlock as an alternative to your PIN, the short clip you record is sent to our speech-to-text provider (xAI) for transcription only. The audio is processed in-memory and is not stored, and no voiceprint, speaker embedding, or biometric identifier is ever created or retained — we keep only an encrypted copy of your chosen passphrase. Your PIN remains active as the fallback, and you can delete Voice Unlock at any time from Settings using your PIN.

Location Data

We may collect approximate (IP-based) and, with your permission, precise (GPS-based) location to power features such as maps, listings, meetups, search, fraud prevention, and regional compliance. You may revoke precise-location permission at any time in your device settings.

User-Generated Content

We consider “user-generated content” to be materials (text, image and/or video content) voluntarily supplied to us by our users for the purpose of publication, processing, or usage on our platform. All user-generated content is associated with the account or email address used to submit the materials.

Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published, it may be accessible to third parties not covered under this privacy policy.

Gameplay Data (HoodGuess, StickerVerce, and other games)

When you play a game or use a competitive or scored feature on any of our properties, we collect gameplay data: rounds played, guesses and answers submitted, scores, accuracy, timing, streaks, ranks and leaderboard position, matches and battles, opponents, trades, the virtual items you own or acquire, and the in-game events your account generates. We use this data to run the game, calculate scores and leaderboards, match players, deliver and track virtual items, balance gameplay, and detect cheating, automation, collusion, and multi-accounting. Your display name, avatar, scores, and ranking may be visible to other players on public leaderboards and in match results; the rest of your gameplay data is not published.

AI Generation Prompts and Outputs

When you generate content using an AI feature — including StickerVerce cards, characters, and artwork — we collect the prompts, reference material, and settings you submit, together with the output produced and the metadata of the request. Prompts and reference material are transmitted to the third-party AI providers listed on our Subprocessors page in order to produce the output, and are handled under those providers’ terms in addition to this policy. We use prompts and outputs to deliver the feature, to bill credits, to enforce our Acceptable Use Policy through automated and human safety review, and to investigate abuse or a rights-holder complaint. Do not include sensitive personal information in a prompt.

Transaction Data

Transaction data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.

Financial Data (Bank Accounts via Plaid)

If you choose to connect a bank account, we use Plaid Inc. (“Plaid”) to securely access your financial information. By connecting your account, you acknowledge and agree that the terms of Plaid’s privacy policy (available at https://plaid.com/legal ) will govern Plaid’s use of such information.

Through Plaid, we may collect the following financial data:

• Account holder name and contact information
• Account type, balances, and transaction history
• Routing and partial account numbers
• Identity verification documents (when requested)
• Asset report data for financial assessments

How we protect your financial data: All financial data received from Plaid is encrypted at-rest using AES-256 encryption. Access tokens used to retrieve your bank data are stored in encrypted form and are never exposed in application logs or API responses. Two-factor authentication is required before accessing any bank account features.

How you can disconnect: You may disconnect your bank account at any time from your account settings. When you disconnect, we revoke the access token with Plaid and remove the connection from our systems. Previously retrieved data (such as asset reports) may be retained in accordance with our data retention policy.

Sensitive and Special-Category Data (including Dating)

Some optional features let you provide information that is treated as “sensitive personal information” under U.S. state privacy laws and as “special category data” under the EU/UK GDPR (Article 9). This includes, depending on the features you choose to use: government-ID and identity-verification data; precise geolocation; financial-account information; biometric or voice-derived data; the contents of your private communications; and, if you use our Dating features, information you may choose to share about your sexual orientation, religious or spiritual beliefs, political or social views, relationship intentions, and related personal preferences.

We collect and use this information only where you knowingly and voluntarily provide it to power the specific feature you have chosen, and — where required by law (including GDPR Article 9) — on the basis of your explicit consent, which you may withdraw at any time. We do not use sensitive or special-category data for advertising, we do not sell or share it, and we do not use it to infer characteristics about you for marketing. You may delete this information (for example, by deleting your dating profile or the relevant records) or ask us to limit our use of it, subject to the limited legal-retention exceptions described below.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our website:

• Register for an account
• Purchase a subscription
• Use a mobile device or web browser to access our content
• Contact us via email, social media, or on any similar technologies
• When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide you with our platform's core features and services
• to enable you to customize or personalize your experience of our website
• to enable you to access and use our website, associated applications, and associated social media platforms
• for internal record keeping and administrative purposes
• to comply with our legal obligations and resolve any disputes that we may have
• for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use
• for technical assessment, including to operate and improve our app, associated applications, and associated social media platforms

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you provide us with your location, we may combine this with general information about currency and language to provide you with an enhanced experience of our site and service.

Security of Your Personal Information

We implement administrative, technical, and physical safeguards designed to protect personal information, including: TLS 1.2+ encryption in transit; AES-256 encryption at rest for sensitive data stores; end-to-end encryption (ECDH-P256 + AES-256-GCM) for designated chat features; encrypted database fields for tokens, secrets, and connected-account credentials; role-based access controls and least-privilege permissions for personnel; mandatory two-factor authentication for administrative access; centralized logging and intrusion monitoring; secret-scanning and dependency-vulnerability scanning in our build pipeline; vendor security reviews; and ongoing security training. We use AWS, Cloudflare, and other providers that maintain industry-standard security certifications.

No system can be guaranteed 100% secure. You are responsible for selecting a strong, unique password, enabling two-factor authentication where available, safeguarding your devices and recovery materials, and promptly notifying us of any actual or suspected unauthorized access to your account at support@openluxe.co.

Data Breach Notification

In the event of a confirmed personal-data breach affecting your information, we will notify you and applicable authorities within the timelines required by applicable law (for example, without undue delay and where feasible within 72 hours of becoming aware under the GDPR; promptly under U.S. state breach- notification statutes). Our notice will describe the nature of the breach, the categories of information involved, the likely consequences, the measures we have taken or propose to take, and steps you can take to protect yourself.

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

To give you specific guidance, the retention periods we apply to the main categories of information include:

• Account and profile data: for the life of your account. When you delete your account, we remove or anonymize your personal information, and complete the process within 360 days, except for records we are required or permitted to keep (see below).
• Identity-verification / KYC documents: kept only as long as necessary for the verification and for the period we are required to retain them under applicable anti-fraud, financial, or “know-your-customer” rules, then securely deleted.
• Financial, transaction, and tax records: retained for the period required by tax, accounting, and financial-record-keeping laws (typically up to seven years), even after account deletion.
• Cross-app activity / usage intelligence: retained for up to 180 days and then pruned after being rolled up into aggregate insights; you can pause or purge this at any time from your Intelligence settings.
• Disappearing messages, expiring media, and recordings: deleted automatically on the timer or retention window you or the relevant community set.
• Immutable audit and security logs: retained for the period necessary for security, fraud-prevention, and to establish, exercise, or defend legal claims, with actor references anonymized when the related account is deleted.

Where a fixed period is not practical to state in advance, we determine how long to keep information based on criteria such as: whether we still need it to provide the service, the sensitivity of the information, our legal and contractual obligations, and whether the information is needed to resolve disputes or enforce our agreements.

Children's Privacy

OpenLuxe is intended for users who are at least 18 years old (or the age of majority in their jurisdiction, whichever is older). We do not direct the platform to children under 13, and we do not knowingly collect or process personal information from children under 13 in violation of the U.S. Children's Online Privacy Protection Act (COPPA), the FTC's COPPA Rule, the EU GDPR's age-of-consent rules, the UK Children's Code (Age-Appropriate Design Code), or similar laws.

If we learn that we have collected personal information from a child under 13 without verifiable parental consent (or, in jurisdictions with a higher digital age of consent, from a person under that age without appropriate consent), we will promptly delete that information and terminate the associated account. If you are a parent or legal guardian and believe a child has provided us with personal information, please contact support@openluxe.co so we can take appropriate action.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• a parent, subsidiary, or affiliate of our company
• third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
• our employees, contractors, and/or related entities
• our existing or potential agents or business partners
• credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
• third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
• third parties to collect and process data
• an entity that buys, or to which we transfer all or substantially all of our assets and business

The third-party service providers and processors we currently use include the categories and providers listed below. The specific providers may change from time to time as we add, remove, or replace vendors. We select providers we believe meet appropriate security and data-protection standards, and we bind them contractually to use your data only for the purposes we authorize.

• Cloud infrastructure and storage: Amazon Web Services (AWS), Cloudflare, Backblaze B2, Laravel Cloud
• Payment processing: Stripe; other processors as offered for specific products
• Banking / financial data linking: Plaid (governed by Plaid’s privacy policy)
• Identity verification (KYC / age / ID): Didit and similar verification vendors as configured per feature
• Telecommunications and SMS: Twilio (calls, SMS, programmable voice)
• Email delivery: Amazon SES, Mailgun
• Live video, audio, and streaming: LiveKit
• AI model providers (used to power AI features such as chat assistants, voice agents, summarizers, generators, and search): Anthropic, OpenAI, xAI, Replicate, and other model and inference providers as we add or replace them. AI providers are bound by their own terms and our data-protection terms; where offered, we use enterprise / non-training tiers so that your inputs are not used by the provider to train their general models.
• Gift fulfillment and vendors: Snappy, Giftsenda, and other gifting vendors we may integrate (e.g., Ongoody)
• Escrow: Escrow.com and other licensed escrow providers as integrated
• Real-estate, mapping, and property data: RentCast, MLS / IDX providers, and mapping providers
• Analytics and product instrumentation: Google Analytics, Laravel Pulse / Nightwatch (internal performance and error monitoring)
• Voice and call AI (transcription, speech): Vapi, Deepgram, ElevenLabs, Inworld, and similar providers used to transcribe, synthesize, or route calls and voice features
• Contact data enrichment: Apollo, People Data Labs, Hunter, Proxycurl, and similar providers used, at your direction, to append business/professional details to contacts you add to your CRM
• External CRM and productivity sync: HubSpot, Zoho, Pipedrive, Follow Up Boss, Google, and Microsoft, where you connect those accounts to sync contacts, email, or calendar
• Social login and import: Google, Microsoft, Meta (Facebook/Instagram), X (Twitter), LinkedIn, Dropbox, and Box, where you choose to connect them to sign in or import content
• Shipping, fulfillment, and returns: EasyPost, Shippo, ShipStation, UPS, USPS, FedEx, DHL, and similar carriers and returns providers used to generate labels and track orders (they receive ship-to details)
• Maps, geolocation, and property data: Mapbox, the U.S. Census, RentCast, and similar providers
• Video, meetings, and media: LiveKit, Mux, Zoom, and image/CDN providers
• Crypto payments (optional): CoinGate, WalletConnect, and on-chain infrastructure where you pay with cryptocurrency
• Customer support and ticketing: as configured for support and abuse-handling workflows

A complete, current sub-processor list is published at openluxe.co/subprocessors and is also available on request to support@openluxe.co.

Restriction on data brokers and resale: We do not authorize any third-party service provider to sell, rent, license, or otherwise re-market the personal information we provide to them, and we do not engage providers whose business model is the resale of consumer data to data brokers, identity graphs, or list resellers. Service providers are contractually limited to using your data to deliver the service we have asked them to perform.

Your Rights and Controlling Your Personal Information

Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example processing transaction data), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.

Please refer to our Cookie Policy for more information.

Advertising

Some pages display advertising served through Google AdSense (and, where enabled, the Ezoic ad service). We run these ads in contextual, non-personalized mode — ads are selected based on the content of the page you are viewing, not on a behavioral profile built from your activity across other sites and apps. We instruct Google to serve non-personalized ads for every request and, through Google Consent Mode, we deny ad personalization and the sharing of user data for advertising. Our advertising partners may still set a limited set of cookies for frequency capping, aggregated reporting, and ad-fraud detection, as described in our Cookie Policy. Because these ads are contextual and we do not enable interest-based advertising, we do not treat this as a “sale” or “sharing” of personal information for cross-context behavioral advertising, and we honor the Global Privacy Control (GPC) signal.

Business Email

When your team hosts mailboxes with us, we process the email sent to and from those mailboxes in order to deliver it, store it and show it to you. Incoming mail is received by Amazon Web Services (our email infrastructure provider), which checks it for spam and viruses; messages that fail the virus check are not delivered, and likely spam is filed in a separate Spam folder. Mail sent to an address on your domain that has no mailbox and no catch-all is discarded. Messages are stored with your account, and attachments with our file storage provider.

Mail in these mailboxes belongs to your team. Your team's owner and admins can create, suspend and delete its mailboxes. We do not run our AI lead-finding on mail in a team's mailboxes unless the mailbox's user turns it on. Mail that has already been received stays with the account after a mailbox is deleted, until it is deleted too; you can ask us for a copy of a mailbox's mail by contacting support.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for Australian Privacy Act Compliance (AU)

International Transfers of Personal Information

Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

The GDPR distinguishes between organisations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, OpenLuxe, located at the address provided in our Contact Us section, are a Data Controller and/or Processor with respect to the personal information you provide to us.

Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent From You

Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. When you contact us, you may consent to your name and email address being used so we can respond to your enquiry. While you may request that we delete your contact details at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you purchase a product, service, or subscription from us, we may need to use your personal and payment information in order to process and deliver your order.

Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance with Law

In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Information

Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.

Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.

Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 360 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.

California, Virginia, Colorado, Connecticut, Texas, and Other U.S. State Privacy Rights

If you are a resident of California (CCPA / CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), Utah (UCPA), Oregon (OCPA), or another U.S. state with a comprehensive consumer privacy law, you have certain rights with respect to your personal information. These rights generally include the right to:

• Know / access the categories and specific pieces of personal information we have collected about you, the sources, the business purpose, and the categories of third parties to whom we disclose it;
• Delete personal information we have collected about you, subject to permitted exceptions (e.g., legal obligations, security, completing a transaction);
• Correct inaccurate personal information;
• Receive a portable copy of your personal information in a structured, commonly used machine-readable format;
• Opt out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising;
• Limit the use and disclosure of sensitive personal information beyond what is necessary to deliver the requested service;
• Opt out of automated decision-making / profiling that produces legal or similarly significant effects, where applicable under your state law;
• Appeal a denial of your privacy request, where applicable; and
• Be free from retaliation for exercising your privacy rights.

No Sale; No Sharing for Cross-Context Behavioral Advertising: Consistent with our Privacy Promises above, OpenLuxe does not sell your personal information for monetary or other valuable consideration, and does not share your personal information for cross-context behavioral advertising, as those terms are defined under the CCPA / CPRA and similar state laws. Because we do not sell or share your personal information in this sense, we do not operate a “Do Not Sell or Share My Personal Information” sale-opt-out link as a sale would typically require — but we honor any such request you submit and we honor the Global Privacy Control (GPC) browser signal as a valid opt-out request.

Sensitive Personal Information: We use sensitive personal information (such as government-ID, precise geolocation, financial-account details, biometric / voice data, the contents of your communications, and — where you use Dating features — information about your sexual orientation and religious or political views) only to deliver the services you request, to comply with legal obligations, to detect and respond to security incidents and fraud, and for other purposes permitted under CCPA / CPRA Section 7027 and analogous state-law provisions. We do not use sensitive personal information to infer characteristics about you for advertising purposes. You may request that we limit our use and disclosure of sensitive personal information to those necessary purposes.

Automated Decision-Making and AI Profiling: Some platform features use automated processing (and in some cases AI models) to rank, recommend, score, match, summarize, prioritize, or extract information. Where such processing produces legal or similarly significant effects under applicable law (e.g., Colorado AI Act, EU AI Act, CCPA/CPRA ADMT regulations), you may have the right to access meaningful information about the logic involved, opt out of solely-automated decisions, or request human review. To exercise these rights, contact support@openluxe.co.

How to Exercise Your Rights: To submit a verifiable consumer privacy request, email support@openluxe.co with the subject line “Privacy Request” and your state of residence. We may need to verify your identity (typically by confirming control of the account email and certain account details). You may use an authorized agent; we will require proof of authorization. We respond within the timelines required by your state's law (generally 45 days, with one extension where permitted).

Shine the Light (California Civil Code 1798.83): If you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may also request, once per calendar year, information about the categories of personal information (if any) we disclosed to third parties for their direct marketing purposes in the prior calendar year. Because we do not share personal information with third parties for their own direct marketing purposes, our response to such a request will typically state that.

To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do Not Track and Global Privacy Control

Some browsers offer a “Do Not Track” (DNT) feature. Because no industry consensus has emerged on how to interpret DNT signals, we do not respond to DNT specifically. However, we recognize and honor the Global Privacy Control (GPC) browser signal as a valid request to opt out of any “sale” or “sharing” of personal information for cross-context behavioral advertising under applicable U.S. state laws.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

Cookies and Pixels

At all times, you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please refer to the Cookies section of this privacy policy for more information.

CCPA-permitted financial incentives

In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.

Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California Notice of Collection

In the preceding 12 months, we have collected the following statutory categories of personal information (as enumerated in Cal. Civ. Code § 1798.140). For every category, we do not sell and do not share for cross-context behavioral advertising, and we disclose to service providers/contractors for business purposes only as needed to operate the platform (e.g., hosting, payment processing, communications, verification, fulfillment). Sources and business purposes are described in the “Information We Collect” and “Collection and Use of Information” sections; retention is described in “How Long We Keep Your Personal Information.”

We collect and use these categories for the business purposes described in this policy, including to provide and manage the Service. We use sensitive personal information only for the purposes permitted by Cal. Civ. Code § 7027 (such as delivering the service you requested, security, and fraud prevention) and not to infer characteristics about you.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Contact Us

For any questions, requests, or concerns regarding your privacy or this Privacy Policy, please contact us:

• Privacy / data-rights requests:support@openluxe.co
• Security incidents and vulnerability reports:support@openluxe.co
• Legal notices:support@openluxe.co
• Copyright (DMCA) notices:support@openluxe.co
• General support:support@openluxe.co

Data Controller: Open Labs, LLC, a Wyoming limited liability company that operates the OpenLuxe platform and each of the other properties listed in the Properties Covered by This Policy section above — including OpenVerce, OpenFlix, HoodGuess, and StickerVerce. Registered mailing address: 1621 Central Ave, Cheyenne, Wyoming 82001, United States. For purposes of EU and UK GDPR, Open Labs acts as a Data Controller for personal information you provide directly, and as a Data Processor for personal information you process about other people through the platform (such as your CRM contacts, gift recipients, or campaign audiences). If you require a Data Processing Agreement (DPA) for your business use of the platform, please contact support@openluxe.co.

EU / UK Representative: If you require an EU or UK GDPR Article 27 representative, please contact support@openluxe.co and we will direct you to the appropriate representative as required.