Legal

Privacy Policy

Version 3.0  ·  Effective April 1, 2026  ·  Last Updated April 1, 2026
Previous versions available upon request at jacksonagreene@icloud.com

We built Arkzphere to help people connect in person — and that mission only works if you trust us with your information. This Privacy Policy explains, in plain language, exactly what data we collect, why we collect it, who we share it with, and the controls you have over it. We do not sell your personal information, and we do not intend to do so. We do not share your data with third parties except with service providers who help us operate the platform, each of whom is bound by strict data protection obligations. We do not track users across third-party apps or websites, and we do not use your data for advertising. While Arkzphere implements safety features and moderation systems, we cannot guarantee user behavior. Questions? Email jacksonagreene@icloud.com.

Contents
01 Information We Collect 11 State-Specific Rights 02 How We Use Your Information 12 California Privacy Rights 03 App Tracking & Advertising 13 Notice to European Users 04 Legal Bases for Processing 14 International Data Transfers 05 AI & Automated Systems 15 Data Retention 06 Biometric & Face Data 16 Children's Privacy 07 Location Data 17 Security 08 How We Share Information 18 Changes to This Policy 09 SMS & Communications 19 Contact Us 10 Your Rights & Choices
01

Information We Collect

We collect information in three ways: information you provide directly, information collected automatically when you use the app, and data derived from your use of our features. Some information is required; some is voluntary. We collect only the minimum data necessary to operate core features, ensure safety, and improve performance.

Information You Provide Directly

Information Collected Automatically

Aggregated and De-Identified Data

We may create anonymous, de-identified, or aggregated datasets from your personal information. Once de-identified so that it cannot reasonably identify you, this data is no longer personal information under this Policy and may be used for any lawful business purpose including analytics, product improvement, and investor reporting.

02

How We Use Your Information

03

App Tracking & Advertising

Arkzphere does not track users across third-party apps or websites. We do not use personal data for targeted advertising. We do not sell or share data for advertising purposes.

We do not participate in cross-app tracking as defined by Apple's App Tracking Transparency (ATT) framework. If we ever implement any form of cross-app tracking in the future, we will request your explicit permission through Apple's ATT prompt before doing so, and we will update this Privacy Policy accordingly.

04

Legal Bases for Processing

Where required by applicable law (including GDPR), we process your personal information based on: Contractual Necessity, Legitimate Interests, Legal Obligation, and Consent.

PurposeLegal BasisData Categories
Account creation, authentication, profile managementContractual NecessityAccount data, profile data, device data
Map, Scenes feed, nearby user discoveryContractual Necessity; Consent (location)Location, profile data, Scene content
Mutual match system and in-app messagingContractual NecessityProfile data, match decisions, messages
Date Request featureContractual NecessityMatch data, request content, timestamps
Ask Ark AI concierge and personalizationLegitimate Interests; Consent where requiredLocation, interests, usage behavior, profile data
Identity verification and liveness detectionContractual Necessity; Legal ObligationVerification images, face data, profile photo
Content moderation and platform safetyLegitimate Interests; Legal ObligationPhotos, videos, messages, usage data
Account notifications and communicationsContractual Necessity; Legitimate InterestsEmail, phone number, push token
Analytics, diagnostics, and app improvementLegitimate InterestsUsage data, crash logs, device data
Fraud prevention and abuse detectionLegitimate Interests; Legal ObligationAccount data, usage data, device data
Legal compliance and defense of claimsLegal Obligation; Legitimate InterestsAny relevant account or content data
Business transactions and investor due diligenceLegitimate InterestsAggregated or de-identified data
05

AI & Automated Systems

Ask Ark

Ask Ark is Arkzphere's AI-powered social concierge. It uses your location, profile data, expressed interests, and in-app behavior to surface personalized Scenes, nearby users, and events. Ask Ark is an assistive tool that provides guidance only — not authoritative direction. You should exercise your own independent judgment before acting on any suggestion. Ask Ark does not make decisions with significant legal or similarly meaningful effects based solely on automated processing.

Content Moderation

Photos and videos may be automatically analyzed to detect prohibited content per our Community Guidelines. Flagged content may be reviewed by trained human moderators under confidentiality obligations. We do not use your photos, videos, or personal content to train external or internal AI models.

No Consequential Automated Decision-Making

Arkzphere does not engage in automated decision-making or profiling that produces legal or similarly significant effects on users without human review. To the fullest extent permitted by applicable law, Arkzphere is not liable for losses or outcomes arising from reliance on AI-generated suggestions.

06

Biometric & Face Data

Important: The collection and processing of face data described in this section may constitute the collection of biometric information under applicable state laws, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and similar statutes. We process this data strictly for identity verification and platform safety — never for commercial purposes.

What We Collect and Why

At signup and when you change your profile photo, Arkzphere uses liveness detection to verify you are a real person, and photo-to-face matching to confirm your submitted photo corresponds to you. This may involve the collection and analysis of facial geometry data from images or video frames you submit.

How We Use and Store It

By submitting photos or video during verification, you consent to the collection and processing of face data as described. Users in jurisdictions with biometric privacy laws may contact jacksonagreene@icloud.com to exercise applicable rights.

07

Location Data

08

How We Share Your Information

We do not sell your personal information. We share personal information only in the circumstances described below.

Service Providers

Each provider is permitted to use your data only to perform services on our behalf and is bound by contractual data protection obligations. This list will be updated as new providers are added.

Arc Partners and Event Organizers

Arc Partners who host events through Arkzphere may independently collect and process personal information about attendees as separate data controllers. When you RSVP or attend an event, your RSVP status and public profile may be shared with the Arc Partner solely for event management. Arkzphere is not responsible for the data practices of Arc Partners acting as independent controllers.

Other Users

Your profile, Scenes, and public activity are visible to other registered users. Your exact location is never displayed to other users. Messages and Date Requests are visible only to the intended recipient.

Business Transactions

We may disclose or transfer personal information in connection with financing rounds, mergers, acquisitions, or other business transactions. We share only the minimum information necessary and require any successor entity to honor this Privacy Policy.

Legal Compliance

We may disclose personal information to law enforcement or courts when necessary to comply with applicable law, protect user safety, investigate fraud, or establish, exercise, or defend legal claims.

09

SMS & Communications Data

10

Your Rights & Choices

Depending on where you live, you may have some or all of the following rights. Contact jacksonagreene@icloud.com to exercise any right.

Access & Portability

Request a copy of your personal information in a structured, machine-readable format.

Correction

Update or correct inaccurate or incomplete personal information.

Deletion

Request deletion of your account and personal data, subject to legal retention obligations.

Restriction

Ask us to limit processing of your data in certain circumstances.

Objection

Object to processing based on legitimate interests.

Withdraw Consent

Withdraw consent at any time without affecting prior lawful processing.

Apple Requirement: You can delete your account directly inside the Arkzphere app at any time via Settings → Account → Delete Account.

We respond to verified requests within 45 days. To appeal a declined request, email us with the subject line "Privacy Request Appeal." Accounts inactive for 2 years will be automatically closed.

11

State-Specific Rights (United States)

Residents of the following states have additional privacy rights under applicable state law, including the right to appeal denied requests to their state attorney general:

Virginia · Colorado · Connecticut · Texas · Oregon · Montana · Indiana · Kentucky · Rhode Island · Maryland · Tennessee · Minnesota · Delaware · Iowa · Nebraska · New Hampshire · New Jersey

Contact jacksonagreene@icloud.com with your state of residence and the subject line "State Privacy Rights Appeal."

Washington and Nevada residents: certain health-related data collected through our verification features may be subject to additional protections under applicable consumer health data privacy laws.

12

California Privacy Rights

California residents have specific rights under the CCPA as amended by the CPRA, and the California "Shine the Light" law.

To submit a CCPA request, email jacksonagreene@icloud.com with the subject line "California Privacy Request."

13

Notice to European Users

This section applies to individuals in the European Economic Area (EEA), the United Kingdom, and Switzerland. Arkzphere, Inc. is the data controller responsible for your personal information.

We process personal data of European users on the legal bases set out in Section 04. EEA users can find their supervisory authority at edpb.europa.eu. UK users can contact the ICO at ico.org.uk.

We do not yet have an appointed EU/UK GDPR representative or Data Protection Officer. EU and UK users may contact us directly at jacksonagreene@icloud.com to exercise data rights.

14

International Data Transfers

Arkzphere is headquartered in the United States. If you access the app from outside the U.S., your personal information may be transferred to, stored in, and processed in the United States or other countries where our service providers operate.

Where required by applicable law including GDPR, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission. Contact jacksonagreene@icloud.com to request a copy of applicable transfer safeguards.

15

Data Retention

Active accounts
Retained for the duration of your account.
Post-deletion safety window
3 months after voluntary closure; 1 year after account ban.
Face & verification images
30 days from verification date, unless a legal hold applies.
Messages & Date Requests
Deleted on account closure, subject to the safety window and legal holds.
Transaction data
7 years — required for tax, accounting, and financial reporting compliance.
Consent records
5 years from the date of consent.
Support communications
5 years from the date of the communication.
Abuse / ban records
As long as necessary to prevent re-registration and protect user safety.
Inactive accounts
Automatically closed after 2 years of inactivity.
Backup systems
Residual copies purged within a limited period post-deletion.
16

Children's Privacy

Arkzphere is intended exclusively for users 18 years of age or older. We do not knowingly collect, solicit, or maintain personal information from any person under 18. If you believe a minor has created an account, contact jacksonagreene@icloud.com immediately. We use identity verification and liveness detection at signup in part to confirm that users are real adults.

17

Security

Arkzphere implements reasonable and appropriate administrative, technical, and physical safeguards to protect your personal information, including encryption of data in transit (TLS), secure cloud infrastructure, role-based access controls, and regular security monitoring. No security system is impenetrable. In the event of a data breach affecting your rights and freedoms, we will notify affected users and relevant authorities as required by applicable law.

18

Changes to This Policy

We may update this Privacy Policy at any time. For material changes, we will provide at least 30 days advance notice via in-app notification and/or email. Your continued use of Arkzphere after changes take effect constitutes acceptance. Previous versions are available upon request at jacksonagreene@icloud.com.

19

Contact Us

Arkzphere, Inc.
Privacy: jacksonagreene@icloud.com
Legal: jacksonagreene@icloud.com
New York, NY, United States

We aim to respond to all verified privacy requests within 45 days.