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Privacy Policy

Effective April 7, 2026

Jurisdiction: State of Delaware, United States

Please Read Carefully

Black Halo, LLC ("Company," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy ("Policy") describes how we collect, use, disclose, and safeguard information obtained in connection with your access to and use of the My Persona platform (the "Platform"). By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the practices described in this Policy.

This Policy is incorporated by reference into the Company's Terms of Service Agreement and Acceptable Use Policy. Capitalized terms not defined herein shall have the meanings ascribed to them in the Terms of Service.

1. Information We Collect

We collect information in the following categories, which may vary based on how you interact with the Platform:

1.1 Information You Provide Directly

You may provide personal information to us when you register for an account, use features of the Platform, or communicate with us. This includes, without limitation:

  • Account registration information, including your full name, email address, username, and password.
  • Profile and creator information, including bios, profile images, and content preferences.
  • Payment information, including credit or debit card details, billing address, and linked financial account information, which is collected and processed exclusively by our third-party payment processors (e.g., Stripe, Inc.).
  • Communications you submit to the Company or other Users through the Platform, including support requests, messages, and comments.
  • Identity verification documents or additional information required for compliance or payout processing purposes.

1.2 Information Collected Automatically

When you access or use the Platform, certain information is collected automatically through technical means, including:

  • Device and browser information, including device type, operating system, browser type and version, and unique device identifiers.
  • Internet Protocol (IP) addresses and approximate geolocation data derived therefrom.
  • Usage and behavioral data, including pages visited, features used, links clicked, content viewed, and session duration.
  • Cookies, pixel tags, web beacons, and similar tracking technologies. Please see Section 5 for additional information regarding our use of these technologies.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including:

  • Payment processors and financial institutions in connection with transaction verification and fraud prevention.
  • Identity verification services engaged by the Company for compliance purposes.
  • Analytics providers that assist us in understanding Platform usage and user behavior.

2. How We Use Your Information

We use the information we collect for the following purposes, in each case as necessary to fulfill a legitimate business purpose or legal obligation:

  • To provide, operate, maintain, and improve the Platform and its features and functionality.
  • To process payments, facilitate creator payouts, and manage financial transactions.
  • To create and maintain your account and verify your identity where required.
  • To detect, investigate, and prevent fraud, abuse, policy violations, and other illegal or unauthorized activity.
  • To enforce our Terms of Service, Acceptable Use Policy, and other applicable agreements and policies.
  • To communicate with you regarding your account, transactions, support inquiries, and Platform updates.
  • To send promotional or marketing communications, where you have consented to receive such communications or where otherwise permitted by applicable law.
  • To analyze usage patterns and trends to improve Platform performance and user experience.
  • To comply with applicable legal and regulatory obligations, including requirements imposed by payment processors.

We do not sell, rent, or trade your personal information to third parties for their own marketing or commercial purposes.

3. Disclosure of Your Information

We may disclose your personal information to third parties only in the circumstances described below:

3.1 Service Providers and Vendors

We engage trusted third-party service providers to assist in operating the Platform and delivering our services. These providers are permitted to access your information only as necessary to perform services on our behalf and are contractually obligated to maintain its confidentiality and security. Such providers include:

  • Payment processors (including Stripe, Inc.) for transaction processing and fraud prevention.
  • Cloud hosting and infrastructure providers for Platform operation and data storage.
  • Analytics and performance monitoring services for usage analysis and Platform optimization.
  • Customer support and communications platforms for account and service management.
  • Identity verification and compliance services as required by law or our payment processors.

3.2 Legal and Regulatory Compliance

We may disclose your information where required or permitted by applicable law, including:

  • In response to a valid subpoena, court order, regulatory inquiry, or other legal process.
  • To comply with applicable laws and regulations, including financial reporting and anti-money laundering requirements.
  • To protect the rights, property, safety, or security of the Company, its Users, or the public.
  • To report suspected unlawful activity to appropriate law enforcement or regulatory authorities.

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or similar corporate transaction, your information may be transferred to the acquiring or successor entity as part of that transaction. We will provide notice of any such transfer and any material changes to this Policy that may result therefrom.

3.4 With Your Consent

We may disclose your information to additional third parties with your express prior consent, which you may withdraw at any time by contacting us at the address provided in Section 12.

4. Payment Information

All payment card information and banking details are collected, processed, and stored exclusively by our third-party payment processors, including Stripe, Inc. The Company does not receive, store, or retain full credit card numbers, bank account numbers, or other sensitive financial credentials.

All payment data transmitted through or in connection with the Platform is subject to the security standards, privacy practices, and terms and conditions of the applicable payment processor. We encourage you to review Stripe's privacy policy and security documentation for information regarding how your payment data is handled.

The Company may retain certain limited transaction metadata — such as transaction amounts, dates, and confirmation identifiers — as necessary for accounting, compliance, and dispute resolution purposes.

5. Cookies and Tracking Technologies

The Platform uses cookies, pixel tags, web beacons, and similar tracking technologies to enhance your experience and collect usage information. These technologies may be used to:

  • Maintain and authenticate your session and account preferences.
  • Analyze traffic patterns, usage behavior, and Platform performance.
  • Deliver relevant content and, where applicable, targeted communications.
  • Support fraud prevention and security monitoring.

You may configure your browser settings to refuse cookies or to alert you when cookies are being set. However, disabling cookies may affect the functionality of certain features of the Platform. Some third-party analytics and advertising partners may also set cookies when you visit the Platform; such cookies are governed by those parties' privacy policies.

6. Your Rights and Choices

Subject to applicable law, you may have the following rights with respect to your personal information:

  • Access and Correction: You may access and update your account information directly through your account settings. You may also contact us to request correction of inaccurate or incomplete information.
  • Deletion: You may request deletion of your account and associated personal information, subject to our data retention obligations described in Section 7.
  • Opt-Out of Marketing Communications: You may opt out of receiving promotional emails from us by following the unsubscribe instructions included in such communications or by contacting us directly. Opting out of marketing communications does not affect transactional or account-related communications.
  • Cookie Management: You may manage cookie preferences through your browser settings, as described in Section 5.
  • California Residents: If you are a California resident, you may have additional rights under the California Consumer Privacy Act ("CCPA"), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale of personal information. As noted in Section 2, we do not sell personal information.

To exercise any of the above rights, please submit a request to us at the contact information provided in Section 12. We will respond to verifiable requests within the timeframe required by applicable law.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:

  • Providing the services you have requested and maintaining your account.
  • Complying with applicable legal, regulatory, tax, and accounting obligations.
  • Resolving disputes, enforcing agreements, and protecting the Company's legal rights.
  • Detecting and preventing fraud or other prohibited activity.

Upon termination or deactivation of your account, we may retain certain information as required by law or for legitimate business purposes, including transaction records and compliance documentation. Personal information that is no longer required will be securely deleted or anonymized in accordance with our data management practices.

Accounts that have been inactive for an extended period may be subject to deactivation or deletion in accordance with our data management policies, with reasonable prior notice where required by applicable law.

8. Security

The Company implements commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include, without limitation, encryption of data in transit, access controls, and routine security assessments.

NOTWITHSTANDING THE FOREGOING, NO SECURITY SYSTEM IS IMPENETRABLE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR INFORMATION. THE COMPANY SHALL NOT BE RESPONSIBLE FOR ANY UNAUTHORIZED ACCESS TO OR DISCLOSURE OF YOUR INFORMATION THAT IS BEYOND OUR REASONABLE CONTROL. You are responsible for maintaining the confidentiality of your account credentials and for promptly notifying us of any suspected unauthorized access to your account.

9. Minors

The Platform is intended exclusively for individuals who are at least eighteen (18) years of age. The Company does not knowingly collect, solicit, or retain personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal information from a minor, we will take prompt steps to delete such information from our records.

If you have reason to believe that a minor has provided personal information to the Company through the Platform, please contact us immediately at the information provided in Section 12. Parents or legal guardians who believe their child has submitted information to the Platform are encouraged to contact us to request deletion of that information.

10. International Data Transfers

My Persona, LLC is headquartered in the United States. If you access the Platform from a location outside of the United States, please be aware that your personal information may be transferred to, stored in, and processed in the United States or other jurisdictions in which our service providers operate.

These jurisdictions may have data protection laws that differ from, and may be less protective than, those in your country of residence. By using the Platform, you acknowledge and consent to the transfer of your personal information to the United States and other applicable jurisdictions for the purposes described in this Policy.

Where required by applicable law, we will implement appropriate safeguards to ensure that international transfers of personal information are conducted in compliance with relevant data protection requirements.

11. Changes to This Privacy Policy

The Company reserves the right to modify or update this Policy at any time in its sole discretion. When material changes are made, we will post the revised Policy with an updated Effective Date and, where required by applicable law, provide you with additional notice. Your continued use of the Platform following the posting of any updated Policy constitutes your acceptance of the revised terms.

We encourage you to review this Policy periodically to remain informed about our data practices and your rights.

12. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

My Persona

8 The Green, Suite A, Dover, DE 19901

allie@mypersonaapp.com

By using the Platform, you acknowledge that you have read, understood, and agree to this Privacy Policy.

© My Persona — All Rights Reserved. 2026