Privacy Policy

Rhubaia Ventures Inc. ("Rhubaia", "we", "us", or "our") operates the Rhubaia mobile application (the "App") available on iOS and Android platforms. This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our mobile application.

By downloading, installing, accessing, or using the Rhubaia mobile application, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our App.

When we use the term "personal information," we are referring to information that identifies or can reasonably be linked to you or another person. Personal information does not include information that is collected anonymously or that has been de-identified, so that it cannot identify or be reasonably linked to you.

1.1 Information You Provide to Us

When you use our App, we may collect the following information that you provide directly:

• Contact Details: Name, address, billing address, shipping address, phone number, and email address.
• Account Information: Username, password, security questions, preferences, and settings when you create an account or update your profile.
• Financial Information: Credit card, debit card, and financial account numbers, payment card information, financial account information, transaction details, form of payment, payment confirmation and other payment details (processed through secure third-party payment processors).
• Transaction Information: Items you view, put in your cart, add to your wishlist, or purchase, return, exchange or cancel and your past transactions.
• Virtual Closet Data: Photos of your clothing items, wardrobe organization data, style preferences, size information, and clothing tags you create.
• AI Try-On Data: Photos of yourself that you upload for virtual try-on features, including full-body photos used for avatar generation and clothing modifications.
• Communications with Us: Messages, feedback, reviews, customer support inquiries, and any other information you include in communications with us.

1.2 Information We Collect Automatically

When you use our App, we automatically collect certain information about your device and usage:

• Device Information: Information about your device, operating system (iOS/Android), device identifiers (such as device ID, advertising ID), IP address, mobile carrier, device language settings, browser or network connection, and other unique identifiers.
• Usage Information: Information regarding your interaction with the App, including how and when you interact with or navigate the App, features you use, pages/screens you view, time spent in the App, click patterns, and navigation paths.
• Performance Data: App crashes, errors, performance metrics, and technical logs to help us improve the App's functionality.
• Location Information: With your permission, we may collect your precise or approximate location to provide location-based services (such as finding nearby stores or shipping estimates).

We may also collect information through the use of cookies and similar technologies, as well as through analytics tools integrated into the App.

1.3 Camera and Photo Library Access

Our App requires access to your device's camera and photo library to enable core features:

• Virtual Closet: To photograph and add clothing items to your digital wardrobe.
• AI Try-On: To capture or select photos of yourself for virtual try-on experiences and avatar generation.

We only access photos that you explicitly select or capture through the App. We do not access your entire photo library without your explicit permission. You can revoke camera and photo library permissions at any time through your device settings, though this may limit certain App functionality.

1.4 Personal Information Sources

We may collect personal information from the following sources:

• Directly from you: Including when you create an account, visit or use the App, communicate with us, or otherwise provide us with your personal information.
• Automatically through the App: Including from your device when you use our App, and through the use of cookies and similar technologies.
• From our service providers: Including when we engage them to enable certain technology and when they collect or process your personal information on our behalf.
• From our partners or other third parties: Including when you interact with integrated third-party services or when third parties provide us with information about you.

Depending on how you interact with us or which features of the App you use, we may use personal information for the following purposes:

• Provide, Tailor, and Improve the Services: We use your personal information to provide you with the App and its services, including to perform our contract with you, to process your payments, to fulfill your orders, to remember your preferences and items you are interested in, to send notifications to you related to your account, to process purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, to facilitate any returns and exchanges, to enable you to post reviews, and to create a customized experience for you, such as recommending products related to your purchases. This includes virtual closet management, AI-powered try-on features, personalized styling recommendations, and product recommendations. This may include using your personal information to better tailor and improve the App.
• AI and Machine Learning: To power our AI try-on features using third-party AI services (such as Uwear.ai API, Banuba, or Vue.ai), generate avatars, and provide personalized styling recommendations.
• Marketing and Advertising: We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail (with your consent), and to show you online advertisements for products or services, including based on items you previously have purchased or added to your cart and other activity in the App.
• Security and Fraud Prevention: We use your personal information to authenticate your account, to provide a secure payment and shopping experience, detect, investigate or take action regarding possible fraudulent, illegal, unsafe, or malicious activity, protect public safety, and to secure our services. If you choose to use the App and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password or other access details with anyone else.
• Communicating with You: We use your personal information to provide you with customer support, to be responsive to you, to provide effective services to you and to maintain our business relationship with you. This includes sending you transactional messages (order confirmations, shipping updates), responding to your inquiries, sending push notifications (with your consent), and providing customer support.
• Analytics: To analyze App usage patterns, understand user behavior, measure App performance, and improve user experience.
• Legal Reasons: We use your personal information to comply with applicable law or respond to valid legal process, including requests from law enforcement or government agencies, to investigate or participate in civil discovery, potential or actual litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our terms or policies.

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

• With Service Providers: We share information with Shopify, vendors and other third parties who perform services on our behalf, including:
  • IT management and cloud hosting providers (Microsoft Azure, Supabase)
  • Payment processing (Stripe, QuickBooks, Shopify Payments)
  • Data analytics (Google Analytics, Crashlytics, Sentry)
  • Customer support platforms
  • Cloud storage, fulfillment and shipping
  • AI/ML service providers (Uwear.ai, Banuba, Vue.ai) for virtual try-on features
  • Push notification services (Firebase Cloud Messaging, OneSignal)
  • Email service providers (Azure Communication Services, SES)
• With Business and Marketing Partners: We may share information with business and marketing partners to provide marketing services and advertise to you. For example, we use Shopify to support personalized advertising with third-party services based on your online activity with different merchants and websites. Our business and marketing partners will use your information in accordance with their own privacy notices. Depending on where you reside, you may have a right to direct us not to share information about you to show you targeted advertisements and marketing based on your online activity with different merchants and websites.
• When You Direct or Consent: When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations.
• With Our Affiliates: We may share information with our affiliates or otherwise within our corporate group.
• Business Transfers: In connection with a business transaction such as a merger or bankruptcy, your information may be transferred to the acquiring entity.
• Legal Requirements: To comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service or policies, and to protect or defend the App, our rights, and the rights of our users or others.

We do not sell your personal information to third parties for their marketing purposes.

Our App integrates with Shopify for e-commerce functionality, including product catalog and checkout. Shopify collects and processes personal information about your access to and use of the App in order to provide and improve the services for you. Information you submit through the App will be transmitted to and shared with Shopify as well as third parties that may be located in countries other than where you reside, in order to provide and improve the services for you.

In addition, to help protect, grow, and improve our business, we use certain Shopify enhanced features that incorporate data and information obtained from your interactions with our App, along with other merchants and with Shopify. To provide these enhanced features, Shopify may make use of personal information collected about your interactions with our App, along with other merchants, and with Shopify. In these circumstances, Shopify is responsible for the processing of your personal information, including for responding to your requests to exercise your rights over use of your personal information for these purposes.

To learn more about how Shopify uses your personal information and any rights you may have, you can visit the Shopify Consumer Privacy Policy. Depending on where you live, you may exercise certain rights with respect to your personal information at the Shopify Privacy Portal.

Your information is stored on secure servers operated by our service providers, primarily Microsoft Azure and Supabase. We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit using TLS 1.3
• Encryption of data at rest using AES-256
• OAuth 2.0 authentication for secure access
• Regular security assessments and monitoring
• Access controls and role-based permissions

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

We retain your personal information for as long as necessary to provide you with our services, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account Information: Retained while your account is active and for a reasonable period after account closure to comply with legal obligations.
• Transaction Data: Retained as required by law (typically 7 years for financial records) and for order fulfillment purposes.
• Photos and Virtual Closet Data: Retained until you delete them through the App or request deletion of your account.
• Logs and Analytics: Retained for up to 180 days as required by our security monitoring and compliance requirements.

You may request deletion of your personal information at any time by contacting us at support@rhubaia.com.

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

• Right to Access / Know: You may have a right to request access to personal information that we hold about you.
• Right to Delete: You may have a right to request that we delete personal information we maintain about you, subject to legal and contractual obligations.
• Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
• Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Right to Opt out of Sale or Sharing for Targeted Advertising: Depending on where you reside, you may have a right to opt out of the "sale" or "share" of your personal information or to opt out of the processing of your personal information for purposes considered to be "targeted advertising", as defined in applicable privacy laws. We do not sell your personal information. Please note that if you visit our website with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out for the device and browser that you use. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.
• Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made. You can also manage push notification preferences through your device settings or within the App.

If you reside in the UK or European Economic Area, and subject to exceptions and limitations provided by local law, you may exercise the following rights in addition to the rights outlined above:

• Objection to Processing and Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information for certain purposes.
• Withdrawal of Consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent. If you withdraw your consent, this will not affect the lawfulness of any processing based on your consent before its withdrawal.

You may exercise any of these rights by contacting us using the contact details provided below. To learn more about how Shopify uses your personal information and any rights you may have, including rights related to data processed by Shopify, you can visit https://privacy.shopify.com/en.

We will not discriminate against you for exercising any of these rights. We may need to verify your identity before we can process your requests, as permitted or required under applicable law. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

App Permissions: You can manage App permissions (camera, photo library, location, notifications) through your device settings at any time. Note that disabling certain permissions may limit App functionality.

Our App is not intended to be used by children, and we do not knowingly collect any personal information about children under the age of majority in your jurisdiction. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we "share" or "sell" (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

Our App integrates with third-party services that have their own privacy policies. We encourage you to review their privacy policies:

• Shopify: Shopify Privacy Policy
• Stripe: Stripe Privacy Policy
• Uwear.ai: Please review Uwear.ai's privacy policy for information about how they process your photos for AI try-on features.
• Google Services: Google Privacy Policy
• Apple: Apple Privacy Policy

The App may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites.

Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the App and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed in the App.

We are not responsible for the privacy practices of third-party services. Your interactions with these services are governed by their respective privacy policies.

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country.

If you are located in the European Economic Area (EEA) or United Kingdom, we rely on recognized transfer mechanisms such as Standard Contractual Clauses to ensure adequate protection of your personal information when transferred outside the EEA/UK.

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information we collect, use, and disclose
• Right to delete personal information (subject to exceptions)
• Right to opt-out of the "sale" of personal information (we do not sell personal information)
• Right to non-discrimination for exercising your privacy rights

To exercise your California privacy rights, please contact us at support@rhubaia.com.

If you are located in the European Economic Area (EEA) or United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR):

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

To exercise your GDPR rights, please contact us at support@rhubaia.com.

If you have complaints about how we process your personal information, please contact us using the contact details provided below. Depending on where you live, you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.

For the EEA, you can find a list of the responsible data protection supervisory authorities here.

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy in the App and on our website, update the "Last updated" date and provide notice as required by applicable law.

The version of this Privacy Policy in force at the time you use the App will generally apply to your use of the App, unless we are required by applicable law to apply a different version or we expressly agree otherwise with you.

Your continued use of the App after such changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.