Privacy Policy

1. About This Policy

Mintgrams Technologies, Inc. d/b/a Refabric ("Refabric," "we", "us", or "our") is committed to protecting your privacy. We have prepared this privacy policy ("Privacy Policy") to describe to you our practices regarding the information we collect, use, and share in connection with the Refabric platform and services (the "Service").

Before using the Service or submitting any information to us, please review this Privacy Policy carefully and contact us if you have any questions. By continuing to use our Service, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy.

Data Controller and Processor Roles. Refabric is the "data controller" of the personal data described in this Privacy Policy, and assumes the responsibilities of data controller as set forth herein. Please note that this Privacy Policy describes Refabric's privacy practices for purposes determined by Refabric and does not apply to Refabric's processing of photos, designs, or other content our customers upload to the Platform. We process such data solely on behalf of our customers and under their instructions in accordance with our commercial agreements and data processing addendum with them, as applicable. In such instances, Refabric acts as a "data processor" on behalf of our customers.

2. Types of Information We Collect

We collect information about our users, which may be identifiable, pseudonymous, or anonymous (including aggregated and de-identified data), as described below.

No Biometric Data Collection. We do not process any biometric information or biometric identifiers from the images uploaded to the Platform, nor do we collect any other types of sensitive personal data as part of the Services.

Information You Provide Us

We collect your Personal Data when you register to use the Service, provide information when using the Service, update your account information, purchase additional Services, submit information to verify your identity, contact Refabric customer support, contact us with questions or feedback, or otherwise communicate with us.

• Contact Data: Your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Profile Data: Username and password that you set to establish an online account, interests, preferences, information about your participation in our promotions or surveys, and any other information you add to your account profile.
• Transactional Data: Information relating to or needed to complete your orders, including order numbers and transaction history.
• Communications Data: Based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Marketing Data: Your preferences for receiving our marketing communications and details about your engagement with them.
• Payment Data: Information needed to complete transactions, including payment card information or bank account number.

Other Information

We may also collect, generate, and/or receive Other Information from the Service as follows:

• Services Metadata. When you interact with the Service, metadata is generated that provides additional context about the way users utilize the Service.
• Log Data. Our platform automatically collects information when our Service is accessed and records it in log files. Such log files may include the Internet Protocol (IP) address, the address of the web page visited before using the Service, browser type and settings, the date and time Service were used, information about browser configuration and plugins, language preferences and cookie data.
• Device Information. We collect information about devices accessing the Service, including type of device, operating system, device settings, application IDs, unique device identifiers and crash data.
• Location Information. We may receive information that helps us approximate your location. We may use an IP address received from your browser or device to determine approximate location.
• Cookie Information. We use cookies and similar technologies to operate and administer our Service, gather and analyze usage, and improve your experience. For more details on cookies please visit https://www.allaboutcookies.org.

Third-Party Sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, and social media platforms.
• Data providers, such as information services and data licensors.
• Partners, such as marketing partners and customers.
• Service providers that provide services on our behalf or help us operate the Service.

Third-Party Login Services. If you use third-party services (such as Google or Microsoft) to log into or link to your Service account, we may receive information associated with your account on that third-party service based on your account settings. Our use and disclosure of information received from Google's APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

3. Use of Your Information

We process information about and/or related to you to run our business, provide the Service, personalize your experience on the Service, and improve the Service. Specifically, we use your information to:

• Provide, operate and maintain the Service;
• Improve and analyze the Service;
• Communicate with you;
• Comply with applicable laws, cooperate with investigations by law enforcement or other authorities;
• Protect our legal rights; and
• Act in any other way which we have communicated to you and to which you have consented.

AI Improvement. We may use your information to improve our products, offerings and overall performance of our Services, including through the utilization, training, and optimization of our proprietary artificial intelligence capabilities.

Aggregated and Anonymized Data. We may create aggregated, de-identified and/or anonymized data from your personal information. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this data and share it with third parties for our lawful business purposes.

4. Disclosure of Your Information

We disclose your information and information about you as described below:

Third Party Service Providers. We may share your information with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to you, us, and/or to the Service.

Sub-processors. Customer acknowledges that the Platform is hosted and made available by certain sub-processors of the Company. Refabric may remove, add or replace its sub-processors from time to time, at its sole discretion.

Payment Processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy at https://stripe.com/privacy. We do not retain your full payment information; we only retain a token of such payment information.

Legal Rights. Refabric may disclose your information if it believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process; (c) to protect or defend the rights or property of Refabric or users of the Service; and/or (d) to investigate or assist in preventing any violation of the law, this Privacy Policy, or our Terms of Use.

Business Transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments, financing, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). We may also disclose your personal information to an acquirer, successor, or assignee of Refabric as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership.

Other Disclosures. We may also disclose your information: to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.

5. Data Location and International Transfer

Data Location. We and our authorized Service Providers maintain, store and process personal data in the United States and other countries as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

International Data Transfer. By visiting the Service and providing us with information, you understand and acknowledge that your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of your information may be less stringent than the laws in your country. For data transfers from the EU, the UK, or Switzerland to countries that are not considered to offer an adequate level of data protection, we enter into Standard Contractual Clauses ("SCCs") with the relevant data exporters and importers.

6. Your Choices Regarding Information

Email Communications. We may periodically send you newsletters and/or emails that directly promote the use of our Service. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. Despite these preferences, we may send you occasional transactional service-related informational communications.

Cookies. If you decide at any time that you no longer wish to accept cookies from our Service, you can change your browser settings to stop accepting cookies or to prompt you before accepting a cookie. If you do not accept cookies, however, you may not be able to use all portions of the Service.

7. Data Access and Control

You can view, access, edit, or delete your information for certain aspects of the Service via your Settings page. Depending on applicable law where you reside, you may be able to assert certain rights related to your information.

If you are a user in the European Economic Area ("EEA"), United Kingdom ("UK") or Switzerland, you have certain rights under applicable law. These include the right to (i) request access and obtain a copy of your personal information; (ii) request rectification or erasure of your personal information; (iii) object to or restrict the processing of your personal information; and (iv) request portability of your personal information. Additionally, if we have collected and processed your personal information with your consent, you have the right to withdraw your consent at any time.

If you are a user in Türkiye, you have certain rights under Law No 6698 on the Protection of Personal Data ("LPPD"). These include the right to learn whether personal data is being processed, request information about processing, learn the purpose of processing, know third parties to whom data is transferred, request rectification, request deletion or destruction, object to processing by automatic means, and request compensation for damages.

8. Data Retention

We may continue to retain your information even after you request deletion of your data if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legal rights and other interests.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data and whether those purposes can be achieved through other means, as well as applicable legal requirements.

You may ask us to delete any personal data, including images you have uploaded to the Services, by sending us an email. We may delete any data or images from our systems without notice to you once we deem it no longer necessary for the purposes set forth in this Privacy Policy. We may also retain your data in an anonymized form.

9. Security

We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of our security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, may notify those individuals whose information may have been compromised.

10. Minors

We do not intentionally gather information from visitors who are under the age of 13. Our Terms of Use require all users to be at least 13 years old. If you possess the eligibility to utilize the Services according to your country's regulations yet lack the legal capacity to provide consent to our terms, it becomes necessary for your parent or guardian to accept our terms on your behalf. If a child under 13 submits identifiable information to us and we learn that the identifiable information is the information of a child under 13, we will attempt to delete the information as soon as possible.

11. Legal Bases for Processing (EEA, UK, Switzerland, Türkiye)

When you access or use the Service, we collect, use, share, and otherwise process your personal data for the purposes described in this Privacy Policy. We rely on a number of legal bases to use your information:

• We process your personal data with your consent, for example, to communicate with you and send you marketing emails.
• We process your personal data in order to fulfill our contract with you and to provide you with our Service.
• We process your personal data pursuant to legitimate interests, for example, to improve and analyze the Service and personalize your experience.
• We process your personal data in order to comply with legal obligations.

We will use appropriate safeguards for transferring your personal data out of the EEA, UK and Switzerland where required and only transfer such personal data under a legally valid transfer mechanism.

In accordance with the Turkish LPPD, your personal data can only be processed if at least one of the conditions stated in Articles 5 and 6 of the LPPD is met. Your personal data is processed based on operational necessity (Article 5(2)(f)) and contractual obligations (Article 5(2)(c)).

12. Other Sites and Services

The Service 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.

13. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on our website. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes. Your continued use of the Service will be considered acknowledgement of the modified Privacy Policy.

14. Disclaimer

Upon deletion of your account, your personal data will be expunged from our system and/or masked. It is crucial to acknowledge that photos uploaded while using the system may contain supplementary personal information. Should you desire the separate deletion of such data, please notify us accordingly. Please be advised that Refabric shall not assume responsibility for any failure to request the removal of such data.