California Privacy Notice (CCPA/CPRA)

This California Privacy Notice (the "Notice") is issued in compliance with the California Consumer Privacy Act (CCPA) and its amendment through the California Privacy Rights Act (CPRA), and applies exclusively to residents of the State of California, USA ("California Consumers").

This Notice supplements the IcloneU general Privacy Policy available at https://icloneu.ai/PrivacyPolicy. In case of conflict between this Notice and the general Privacy Policy regarding California Consumers, this Notice shall prevail.

1. Personal Information We Collect

In the last 12 months, IcloneU has collected the following categories of personal information from California Consumers:

Data shared with Stripe (payment processing) and OpenAI (AI response generation) is done exclusively to provide the contracted service and does not constitute a "sale" or "sharing" of data under CCPA/CPRA.

2. Purposes of Processing

We use collected personal information exclusively for the following purposes:

• Providing the IcloneU Services contracted by the user.
• Managing the account, billing and technical support.
• Training the user's Digital Clone with the content of their library.
• Complying with applicable legal and regulatory obligations.
• Detecting and preventing fraud, abuse or illegal activities.
• Improving the platform through analysis of aggregated and anonymized behavioral patterns.
• Sending service-related communications (updates, maintenance, security).
• Sending marketing communications, only with the user's prior express consent.

3. Your Rights as a California Consumer

As a California resident, you have the following rights under CCPA/CPRA:

3.1 Right to know

You have the right to request that IcloneU inform you about:

• The categories of personal information we have collected about you.
• The categories of sources from which the personal information was collected.
• The business or commercial purpose for collecting, selling or sharing personal information.
• The categories of third parties to whom we disclose personal information.
• The specific personal information we have collected about you.

3.2 Right to delete

You have the right to request that we delete the personal information we have collected about you, subject to certain legal exceptions, such as when the information is necessary to complete the transaction for which it was collected, detect security incidents, or comply with legal obligations.

3.3 Right to correct

You have the right to request that we correct inaccurate personal information we hold about you.

3.4 Right to opt out of selling or sharing

You have the right to direct us not to sell or share your personal information with third parties. As stated in Section 1, IcloneU does not sell or share personal data with third parties for advertising purposes, so this right is fully guaranteed by default.

3.5 Right to limit use of sensitive personal information

You have the right to request that we limit the use and disclosure of your sensitive personal information (such as financial data) to uses necessary to provide the services you reasonably expect. IcloneU uses financial information only to process payments through Stripe.

3.6 Right to data portability

You have the right to receive the personal information you have provided to us in a portable, usable format and, where technically feasible, transmissible to another service provider.

3.7 Right to non-discrimination

We will not discriminate against you for exercising any of your rights under CCPA/CPRA. This means we will not deny you goods or services, charge you different prices, provide you with a different level or quality of service, or suggest that you will receive a different price or service for exercising your rights.

4. How to Exercise Your Rights

To exercise any of the rights described in Section 3, you may:

• Send an email to: wecare@icloneu.ai with the subject "CCPA Rights Request"
• Call: [US Toll-Free Phone]

To protect your privacy, we will verify your identity before processing your request. We will ask you to provide sufficient information to reasonably verify that you are the consumer about whom we collected personal information or an authorized representative.

We will respond to your request within 45 calendar days of receipt. If we need more time, we will notify you and may extend the period to 90 days in total, informing you of the reason for the extension.

You may submit a verifiable request on behalf of a consumer if you are their authorized legal representative or are registered with the California Attorney General to act on behalf of the consumer.

5. Information About Minors

IcloneU does not knowingly collect personal information from children under 16 years of age without the express consent of the minor (between 13 and 16 years old) or their parent or legal guardian (under 13 years old). If we detect that we have collected information from a minor without the required consent, we will delete it immediately.

IcloneU does not sell or share personal information of children under 16 years of age.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, unless the law requires or permits a longer retention period. Upon termination of the business relationship, we retain data for an additional period of up to 12 months to comply with legal obligations, resolve disputes and enforce our agreements, after which it is securely deleted.

7. Changes to this Notice

We may update this Notice periodically. When we do, we will post the updated version at https://icloneu.ai/CCPA and update the effective date. For material changes, we will notify you by email at least 30 days in advance.

8. Contact and Complaints

For any queries related to this Notice or to exercise your rights:

• Email: wecare@icloneu.ai
• Legal matters: legal@icloneu.ai
• Website: https://icloneu.ai/CCPA

If you believe we have not adequately responded to your request, you may file a complaint with the California Privacy Protection Agency (CPPA) at www.cppa.ca.gov.