Privacy Policy for SmileBloom Platform

Last Updated: July 9, 2026

This Privacy Policy explains how SmileBloom AI LLC, a Delaware limited liability company, with place of business at 100 Illinois St. Suite 200 Saint Charles, IL 60174, United States of America (collectively, “Company,” “we,” “us,” or “our”), collects, uses, shares, and safeguards personal information in connection with your access to and use of SmileBloom Platform, our mobile applications, websites, products, services, and features (collectively, the “Services”). By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please discontinue use of the Services.

Scope and Applicability

This Privacy Policy applies to personal information processed by us in the course of operating the Services. It also applies to personal information we collect from individuals who do not have accounts but interact with the Services (for example, by viewing content, receiving invitations, or contacting us). This Privacy Policy does not apply to information processed by third parties acting independently of us or to information collected in the context of employment or job applications, which may be governed by separate notices.

Information We Collect

When you accept our Terms of Service and Privacy Policy, we record the date and time of acceptance, your IP address, and device/browser information, and retain this record as evidence of your agreement."

We collect information you provide when you create or update an account or profile, such as name, username, handle, display name, email address, phone number, date of birth or age range, profile photo, biography, gender, language, interests, and any other information you choose to include in your profile.

Content You Create and Provide. We collect content you post, upload, or otherwise provide through the Services, including text, images, videos, audio, live streams, Stories, captions, comments, messages, drafts, hashtags, tags, mentions, and metadata associated with such content (such as the date, time, and device or app version used to create or upload content).

Direct Messages and Communications. We process messages, chats, comments, and other communications between users, and between you and us, including their content, recipients, timestamps, attachments, reactions, and delivery/read status, as necessary to operate messaging and community features and to enforce our Terms.

Contacts and Address Book. With your permission, we may collect information from your device’s contacts to help you find and connect with people you know. We will only access your contacts with your consent, and you can withdraw access in your device settings at any time.

Usage and Engagement Data. We collect information about your activity on the Services, such as the accounts and content you view, create, like, save, share, follow, report, or otherwise engage with; the features you use; the time, frequency, and duration of your activities; and inferred interests and preferences based on your interactions.

Device, Log, and Network Data. We automatically collect technical information from and about the devices you use to access the Services, such as IP address, device identifiers, advertising identifiers, operating system, browser type, device settings, mobile carrier, app version, language settings, crash logs, diagnostic data, and cookie or similar tracking technology identifiers.

Location Information. Depending on your device settings and permissions, we may collect approximated location based on IP address and, with your consent, precise geolocation to enable location-based features and tagging. You may disable precise location sharing through your device settings.

Cookies and Similar Technologies. We use cookies, web beacons, SDKs, pixels, local storage, and similar technologies to operate the Services, remember your preferences, measure performance, analyze usage, and personalize content and advertisements. For more details, see the Cookies and Tracking section.

Information from Third Parties. We may receive information about you from other users (for example, when they tag you), our service providers, advertising and analytics partners, anti-abuse and anti-fraud providers, and if you choose to connect or log in via third-party accounts (such as Apple, Google, or social logins), identifiers and profile information from those providers.

Payment and Transaction Information. If you make purchases, subscribe to paid features, purchase virtual goods, receive or send tips, or participate in monetization programs, we collect information necessary to process payments, such as name, contact details, payment instrument type (tokenized), transaction amount, currency, timestamps, and limited billing information. We use payment processors who handle your full payment card details.

Sensitive Categories of Data. We generally do not require sensitive personal information. If you choose to provide sensitive information in your profile or content (for example, information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexual orientation), you direct us to process it as part of the Services. You can delete such information at any time.

How We Use Information

Provide and Improve the Services. We use information to operate, maintain, and improve the Services; create and manage accounts; provide social features and messaging; moderate content; personalize feeds and recommendations; provide customer support; and develop new features.

Safety, Security, and Integrity. We use information to detect, prevent, and respond to spam, abuse, fraud, illegal content or activity, intellectual property violations, and security incidents; to protect users and our Services; and to enforce our Terms and other policies.

Personalization and Recommendations. We use your activity, connections, and device data to personalize your experience, including recommended content, accounts, topics, and ads, and to rank, organize, and surface content in feeds and search results.

Advertising and Marketing. We use information to deliver, measure, and improve advertising on and off the Services, including interest-based ads and promotions; to measure campaign performance; and to send you marketing communications where permitted by law and your preferences. You can opt out of marketing emails by using the unsubscribe link in the message or through your account settings.

Analytics and Research. We use information to understand how the Services are used, to analyze trends, to monitor performance, and to conduct research, including to train and evaluate models for content ranking, recommendations, safety, and quality.

Legal Compliance. We use information as required by applicable laws, regulations, legal processes, or enforceable governmental requests, and to establish, exercise, or defend legal claims.

Legal Bases for Processing (EEA/UK/Switzerland)

For individuals in the European Economic Area, the United Kingdom, and Switzerland, we process personal data under the following legal bases, as applicable: to perform our contract with you (providing the Services); with your consent (for example, for precise location, certain cookies, or marketing); for our legitimate interests (for example, to ensure the safety and integrity of the Services, personalize your experience, and conduct analytics, provided those interests are not overridden by your rights); and to comply with legal obligations.

How We Share Information

With Other Users. Your profile information, posts, comments, likes, followers, following, and other activity may be viewable by others based on your settings and the nature of the content or feature you use. Direct messages are shared with intended recipients; we do not disclose their contents except as necessary to operate the Services, comply with law, or with your consent.

With Service Providers. We share information with vendors and service providers who perform services on our behalf, such as hosting, analytics, advertising, content moderation, security, payment processing, customer support, email delivery, and professional services. These parties are bound by contractual obligations to protect personal information and process it only as instructed.

For Advertising and Measurement. We may share limited information with advertising, marketing, and measurement partners to deliver and evaluate ads and to understand ad performance. Where required, we obtain your consent before sharing data for targeted advertising.

For Safety, Legal, and Compliance. We share information with law enforcement, regulators, government authorities, or other third parties if we believe disclosure is reasonably necessary to comply with law or legal process; to protect our, your, or others’ rights, property, or safety; to investigate or prevent suspected wrongdoing; or to enforce our Terms or policies.

Corporate Transactions. We may disclose or transfer information in connection with any merger, sale, financing, acquisition, reorganization, bankruptcy, or similar event. In such cases, we will take steps to ensure the confidentiality and continued protection of personal information.

With Your Consent or at Your Direction. We share information consistent with your instructions, settings, or when you otherwise consent to or direct us to do so.

International Data Transfers

We operate globally. Your information may be transferred to, stored in, and processed in countries other than where you live, including the United States, where data protection laws may be different from those in your jurisdiction. Where required, we implement appropriate safeguards for cross-border transfers, such as Standard Contractual Clauses, and take steps to ensure an adequate level of protection.

Retention

We retain personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, protect our rights, and enforce our agreements. Retention periods vary by data category and are determined based on criteria such as the nature of the information, the purpose of processing, and legal or operational retention needs. We may anonymize or aggregate data so that it no longer identifies you and retain that information indefinitely.

Your Choices

Account Settings. You can access and update certain personal information through your account settings, including profile details, privacy preferences, and communications choices.

Device and Browser Controls. You can manage cookies, advertising identifiers, and permissions such as camera, microphone, contacts, notifications, and location via your device and browser settings.

Marketing Communications. You can opt out of marketing emails by following the unsubscribe link or changing your preferences in settings. We may still send you transactional or service-related communications.

Cookies and Tracking

We and our partners use cookies and similar technologies to recognize you, remember your preferences, keep you signed in, monitor the performance of the Services, personalize content and ads, and analyze traffic. You can control cookies through your browser settings and, where applicable, through our consent management tool. If you disable cookies, some features of the Services may not function properly. For mobile apps, you can control targeted advertising via your device settings, such as “Limit Ad Tracking” or “Opt out of Ads Personalization,” and manage permissions for app tracking where available.

Interest-Based Advertising and Your Choices

We may work with advertising partners to display interest-based ads on and off the Services. To opt out of certain interest-based advertising, adjust your preferences in your account settings, use device-level controls, or visit applicable industry opt-out mechanisms where available. Opting out will not stop you from seeing ads, but the ads may be less relevant.

Do Not Track and Global Privacy Control

Your browser may offer a Do Not Track (DNT) signal. Because there is currently no common understanding of how to interpret DNT signals, we do not respond to them. Where required by law, we honor recognized opt-out preference signals, such as Global Privacy Control, for applicable processing.

User Rights

Depending on your location, you may have rights regarding your personal information, such as the right to request access, correction, deletion, portability, or restriction of processing, to object to processing, or to withdraw consent. You may also have the right to lodge a complaint with a supervisory authority. To exercise your rights, please contact us as described in the Contact Us section. We will verify your request consistent with applicable law and respond within the time period required by law.

California Privacy Notice

This section supplements the Privacy Policy for California residents and describes how we collect, use, and disclose personal information subject to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

Categories of Personal Information. In the preceding 12 months, we may have collected identifiers (such as name, email, IP address), customer records, commercial information, internet or other network activity, geolocation data, audio/visual content, inferences, and, if you choose to provide it, sensitive personal information. We collect these categories from you, your devices, other users, service providers, and partners for the purposes described in this Privacy Policy.

Disclosures for Business Purposes. We disclose personal information to service providers for business purposes, such as hosting, security, analytics, customer support, and payment processing.

Sales/Sharing for Cross-Context Behavioral Advertising. We may sell or share personal information for cross-context behavioral advertising, as those terms are defined by the CCPA/CPRA. You can opt out of sales or sharing through your privacy settings or applicable preference signals.

Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA/CPRA and its regulations or as otherwise disclosed to you with your consent.

Rights of California Residents. Subject to certain exceptions, you have the right to request access, deletion, correction, to opt out of sales or sharing, and to limit the use and disclosure of sensitive personal information. We will not discriminate against you for exercising your rights.

Children’s Privacy

The Services are not intended for children under 13, and we do not knowingly collect personal information from children under 13. If we learn that a child under 13 has provided personal information, we will take steps to delete such information. If you believe a child has provided us personal information in violation of this policy, please contact us. For teens, additional features and controls may be available, and parental consent may be required for certain jurisdictions. Minimum age requirements may vary by region based on local law.

User-Generated Content and Public Information

Content you post may be public depending on your settings and the nature of the feature you use. Public content may be indexed by search engines and accessible by others on and off the Services. You should not post personal information you do not wish to be publicly available. Copies of content may persist in backup copies, cached versions, or may be re-shared by others. Removing a post does not guarantee complete removal from the internet.

Community Safety and Moderation

We use automated systems and human review to moderate content and detect, prevent, and address violations of our Terms and policies. We may remove or restrict content or features, suspend or terminate accounts, and notify law enforcement as appropriate. We also allow users to report content or behavior that may violate our policies.

Automated Decision-Making and Profiling

We may use automated systems, including machine learning models, to help provide and personalize the Services, to recommend content, to detect spam and abuse, to rank and organize feeds and search results, to recommend ads, and to support content moderation. Where required, we will provide information about the logic involved and the significance and consequences of such processing, as well as your rights to request human review.

Third-Party Links and Services

The Services may contain links to or integrations with third-party websites, apps, services, and social media platforms. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing them your information.

Security

We implement technical, organizational, and administrative measures designed to protect personal information against unauthorized access, destruction, loss, alteration, and misuse. No security measures are perfect or impenetrable, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for all activities under your account.

Data of Non-Users

We may process information about non-users that is provided by our users, such as when a user uploads contacts or shares content that includes a non-user. If you believe we hold information about you and you do not use the Services, you may contact us to request access or deletion where applicable.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we do, we will revise the “Last Updated” date and take additional steps as required by law, which may include notifying you through the Services or by other means. Your continued use of the Services after an update signifies your acceptance of the updated Privacy Policy.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact us at:

SmileBloom AI LLC

Attn: Privacy Office

100 Illinois St. Suite 200

Saint Charles, IL 60174, United States of America

Email: privacy@smilebloom.ai

Jurisdiction-Specific Disclosures

EEA/UK Representative and DPO. If required, we will appoint an EU/UK representative and/or a Data Protection Officer. Details will be provided here when applicable.

Brazil (LGPD). Individuals in Brazil have rights under the LGPD, including confirmation of processing, access, correction, anonymization, portability, deletion, and information about sharing. Our legal bases include performance of contract, compliance with legal obligations, and legitimate interests. You may contact us to exercise these rights.

Canada (PIPEDA and provincial laws). Individuals in Canada have rights to access and correct personal information and to file complaints with the Office of the Privacy Commissioner of Canada or their provincial authority.

Australia. Individuals in Australia may contact us to access or correct personal information and may lodge complaints with the Office of the Australian Information Commissioner. Where consent is required, we will obtain it expressly or impliedly as permitted by law.

India. We process personal data in accordance with applicable Indian data protection requirements. Where consent is required, we will obtain it and provide mechanisms to withdraw consent.

Additional Platform-Specific Features

Live and Audio Rooms. If you participate in live or audio rooms, your participation, including your profile, voice, video, and interactions, may be publicly visible and recorded by us or other participants. We may use automated and human moderation for safety and integrity.

Creator Monetization and Payouts. If you participate in creator programs, we collect additional information required for tax reporting and identity verification, such as government-issued identifiers, date of birth, and financial account details, and we may share limited information with payment and tax vendors to process payouts and comply with legal obligations.

Third-Party Logins and Integrations. If you choose to connect third-party accounts or services, we will receive information from those services according to your settings with them and their privacy policies. You may disconnect integrations at any time in your settings.

Virtual Goods and In-App Purchases. Purchases of virtual goods are generally non-refundable except as required by law or as otherwise disclosed. We may display purchase history and balances in your account.

Your Responsibilities

You are responsible for the content you post and for complying with our Terms and community guidelines. Do not post personal information of others without their consent. Respect intellectual property and legal rights of others. Use available privacy controls and report concerns to us.

Effective Date

This Privacy Policy is effective as of the date stated at the top. It supersedes all prior versions. If there is any conflict between this Privacy Policy and any supplemental terms, the supplemental terms will control to the extent of the conflict for the subject matter they address.

Last updated: July 11, 2026