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Privacy Policy — Brown By Chris Brown

Privacy Policy for the BROWN platform, operated by EVEN Labs Inc. in collaboration with Chris Brown Entertainment and RCA Records.

BROWN Powered by EVEN — Privacy Policy

The Short Version

Hi. We're EVEN. We built this platform with Chris Brown to bring you closer to his music, his community, and his work. This Privacy Policy explains what we collect from you, why, and what you can request concerning your information. We tried to write something you'd actually read. The full legal version follows below.

A few things up front:

You have to be 18 years of age or older to make an account here. That's not a vibe thing. It's a legal thing tied to how we and Sony handle data.

We collect information that we need to run the platform. Your phone or email so you can sign in. Your purchase info so we can deliver what you bought. Your chat messages so the community works. Some basics about the devices you’re using so the site loads correctly.

We share information with the people who help us provide you with this community. . Stripe handles your payments, so they see your card information. Magic helps you sign in, so they see your phone or email. Stream powers the chat, so chat lives in their system. Sony Music gets account-level information because they're Chris Brown's label and they're a partner here. We've listed everyone in Section 5 below.

We don't sell your information. Full stop. We share it as we describe in this policy, and that's it.

We keep most information until you ask us to delete them, except for chat messages, which stay in the chat history because that conversation belongs to the community. If you delete your account, your name comes off your messages but the messages remain. If you posted something you regret, email us and we'll work on it.

You can opt out of marketing texts and emails any time. STOP works. Unsubscribe links work. Emailing us works. Authentication codes and order updates aren't marketing and will keep coming if you have an active account, because that's how the platform runs.

You have rights here. Specifically, you can ask us what information we have,, ask us to fix it if it's wrong, and ask us to delete it. How that works depends on where you live. The regional sections at the end of this policy spell out the specifics for your country or state.

We use cookies. We have a cookie banner if you're somewhere that requires one. You can manage them through that banner or your browser.

If you have a question or a complaint, email info@even.biz and we'll respond within 30 days, sooner if your local law requires it.

That's the gist. Everything below is the precise version. If you want to skip ahead, jump to the section that matches where you live.

Table of Contents

Main Policy

  1. Who We Are

  2. Who This Policy Applies To

  3. Information We Collect

  4. How We Use Your Information

  5. Who We Share Information With

  6. International Data Transfers

  7. How Long We Keep Your Information

  8. Your Rights and Choices

  9. Cookies and Tracking Technologies

  10. Marketing Communications

  11. Information Security

  12. Data Breaches

  13. Chat-Specific Disclosures

  14. Children's Privacy

  15. Gifts and Recipients

  16. Tour Information and External Links

  17. Changes to This Policy

  18. Contact Us

Regional Addenda

  • A. United States (with state-specific sections for California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, Virginia)

  • B. Canada (PIPEDA and Quebec Law 25)

  • C. United Kingdom, European Economic Area, and Switzerland

  • D. Brazil (LGPD)

  • E. Australia (Privacy Act 1988)

  • F. Philippines (Data Privacy Act)

  • G. South Africa (POPIA)

MAIN POLICY

1. Who We Are

EVEN Labs Inc. ("EVEN," "we," "us," or "our") is a Delaware corporation with its principal place of business at 313 N Plankinton Ave., Milwaukee, WI 53203, USA.

We operate the BROWN platform at brown.live (the "Platform") in collaboration with Chris Brown Entertainment and RCA Records, a label of Sony Music Entertainment ("Sony"). The Platform allows fans to access exclusive content, purchase digital and physical music releases, participate in fan community chat, view tour information, and engage with artist content.

For purposes of data protection law, EVEN is the controller of the personal information collected through the Platform, except where this Policy specifies otherwise. Sony is a separate controller for the personal information shared with Sony as described in Section 5.

Contact for privacy matters: info@even.biz Mail: EVEN Labs Inc., Attn: Privacy, 313 N Plankinton Ave., Milwaukee, WI 53203, USA

2. Who This Policy Applies To

This Policy applies to anyone who accesses or uses the Platform. This includes:

  • Visitors who browse the Platform without creating an account

  • Members who create an account using a phone number or email address

  • Purchasers who buy a digital or physical release through the Platform

  • Recipients of gifts purchased on the Platform

You must be at least 18 years old to create a Member account or make a purchase. We do not knowingly collect personal information from individuals under 18. If you believe a minor has created an account, contact us at support@even.biz and we will delete the account and associated data.

3. Information We Collect

We collect information in three ways: information you give us directly, information collected automatically when you use the Platform, and information we receive from third parties.

3.1 Information You Give Us Directly

When you create an account (Member tier):

  • Phone number OR email address (one is required to authenticate)

  • The other contact method, if you choose to add it later

  • Profile photo (optional)

  • Display name or username (optional, auto-generated if not provided)

  • Country (auto-detected, editable)

When you make a purchase (Purchaser tier):

  • Billing name and address

  • Shipping address (for physical merchandise)

  • Payment card details (processed and stored by Stripe; EVEN does not retain full card numbers)

  • Purchase amount and currency

  • Order history

When you participate in chat:

  • Message content

  • Timestamps

  • Reactions and interactions

  • Reports you submit about other users' messages

When you gift a release:

  • Your name and email

  • Recipient's name and email

  • Optional gift message

When you contact support:

  • The content of your communications

  • Any attachments you provide

3.2 Information Collected Automatically

  • Device and connection data: IP address, device type, operating system, browser type and version, screen resolution, time zone, language preferences

  • Usage data: Pages viewed, features used, time spent on the Platform, click and tap patterns, referral source, UTM parameters, search queries within the Platform

  • Authentication data: Login timestamps, session identifiers, multi-factor authentication tokens

  • Performance data: Error reports, crash logs, latency measurements

  • Cookies and similar technologies: See Section 9 for details

3.3 Information from Third Parties

  • Magic (authentication provider): verification status of phone numbers and email addresses

  • Stripe (payment processor): transaction status, fraud signals, last four digits of payment card, card brand, billing region

  • Twilio (SMS delivery via Magic): delivery status of SMS authentication codes

  • Sony Music Entertainment / RCA Records: if Sony shares data about you with us (for example, in connection with cross-promotional campaigns), we will process it according to this Policy

3.4 Sensitive Information

We do not knowingly collect sensitive personal information (such as government ID numbers, biometric data, precise geolocation, health information, or information about racial or ethnic origin, religious beliefs, or sexual orientation) except where you voluntarily provide it (for example, in a chat message). We do not use any such voluntarily-provided information for marketing or profiling.

4. How We Use Your Information

We use your information for the following purposes:

4.1 To Provide the Platform

  • Authenticate your account and keep it secure

  • Process your purchases and deliver digital and physical releases

  • Operate the chat feature, including content moderation

  • Process gift purchases and notify recipients

  • Provide customer support

  • Send transactional communications (order confirmations, shipping updates, security alerts, account notices)

4.2 To Personalize Your Experience

  • Show you relevant content based on your interactions

  • Remember your preferences and settings

  • Surface chat threads and platform features relevant to your activity

4.3 To Communicate with You About Marketing

  • Send marketing emails about new releases, tours, and content (if you opted in)

  • Send marketing text messages (if you opted in by signing up via phone number)

  • Send notifications about new chat activity, drops, and platform features

You can opt out of marketing at any time. See Section 10 for details.

4.4 To Improve and Analyze the Platform

  • Understand how Members use the Platform

  • Diagnose technical problems

  • Develop new features

  • Measure the performance of marketing campaigns

We do not use automated decision-making that produces legal or similarly significant effects on you. We do not train artificial intelligence models on your personal information, and we do not allow third parties to train AI models on EVEN data.

4.5 To Comply with Law and Protect Rights

  • Detect and prevent fraud, abuse, and illegal activity

  • Respond to legal process, government requests, and regulatory inquiries

  • Enforce our Terms of Service and other agreements

  • Protect the rights, property, and safety of EVEN, our users, our partners, and the public

4.6 Legal Bases (for users in the UK, EU, Switzerland, and other GDPR-equivalent jurisdictions)

We rely on the following legal bases for processing your personal information:

  • Performance of a contract for processing necessary to provide the Platform and fulfill purchases

  • Legitimate interests for analytics, security, fraud prevention, and platform improvement

  • Consent for marketing communications and certain cookies

  • Legal obligation for compliance with tax, regulatory, and law enforcement requirements

You can withdraw consent at any time. See Section 10 and the regional addenda.

5. Who We Share Information With

We share personal information only as described below. We do not sell your personal information.

5.1 Sony Music Entertainment / RCA Records

EVEN operates the BROWN Platform in collaboration with Chris Brown Entertainment and RCA Records, a label of Sony Music Entertainment. We share certain personal information with Sony as a separate controller, including:

  • Account information (name, email, phone number, country, sign-up date)

  • Marketing preferences (whether you opted in to SMS or email marketing)

  • Aggregated and de-identified Platform usage data

  • Purchase records (release purchased, amount, currency, date)

Sony uses this information to administer artist relationships, provide marketing support to the artist, report sales data to chart bodies (such as Luminate and Billboard), and comply with its obligations to recording artists.

Sony's processing of your information is governed by Sony's Privacy Policy, available at https://www.sonymusic.com/privacy-policy/. Sony's Terms and Conditions are available at https://www.sonymusic.com/terms-and-conditions/. If you have questions about how Sony processes your data, contact Sony directly using the methods in Sony's policy.

We do not share chat message content with Sony though they can view it if you post publically.5.2 Service Providers (Sub-Processors)

We use the following service providers to operate the Platform. Each is contractually bound to process personal information only on our instructions and to maintain appropriate security.

Provider

Purpose

Categories of data processed

Location

Magic Labs, Inc.

Account authentication (passwordless sign-in)

Email, phone number, device fingerprint

United States

Twilio Inc. (via Magic)

SMS delivery for authentication and marketing

Phone number, message content, delivery metadata

United States

Stripe, Inc.

Payment processing, fraud prevention

Payment card details, billing information, transaction data

United States

PlanetScale

Database hosting (account data, profile photos, transactional records)

All Member-tier data

United States

Vercel Inc.

Application hosting, analytics, attribution tracking

IP, device, usage data

United States

Stream.io Inc.

Chat infrastructure

Chat messages, user IDs, IP addresses, message metadata

United States

PostHog Inc.

Product analytics

Usage events, device data, IP, anonymized identifiers

United States and EU (region-dependent)

Resend

Transactional and marketing email delivery

Email address, message content, delivery metadata

United States

Sentry

Error monitoring and performance

Device data, error context, anonymized identifiers

United States

Amazon Web Services

Cloud infrastructure (storage, compute)

All categories of data

United States

Intercom

Customer support

Contact information, support conversations

United States and Ireland

This list reflects our service providers as of the Last Updated date above. The list may change as we add, remove, or replace providers. We will update this section when changes occur.

5.3 Other Recipients

  • Law enforcement and government authorities when required by law, subpoena, court order, or to protect rights, safety, or property

  • Professional advisors (lawyers, auditors, accountants) \

  • Acquirers in the event of a merger, acquisition, financing, or sale of all or part of EVEN's business, subject to standard confidentiality and continuity protections

  • Other users of the Platform to the extent you choose to make information visible (for example, your display name in the chat)

5.4 What We Don't Do

  • We do not sell your personal information.

  • We do not share your personal information with advertising networks for cross-context behavioral advertising, except as you opt in through cookies and tracking technologies (see Section 9).

  • We do not share your chat message content with Sony or with third parties for marketing purposes.

6. International Data Transfers

EVEN is based in the United States, and our service providers are primarily located in the United States. If you access the Platform from outside the United States, your personal information will be transferred to, stored, and processed in the United States and other countries where our service providers operate.

For users in the United Kingdom, European Economic Area, and Switzerland, we rely on the following transfer mechanisms:

  • Standard Contractual Clauses approved by the European Commission for transfers to countries without an adequacy decision

  • UK International Data Transfer Addendum for transfers from the UK

  • Swiss Federal Data Protection Act safeguards for transfers from Switzerland

  • Adequacy decisions where they apply

For users in Brazil, Australia, the Philippines, and South Africa, see the regional addenda for specific transfer information.

You can request a copy of the safeguards we use by emailing info@even.biz.

7. How Long We Keep Your Information

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

  • Account information is retained for as long as your account is active unless you request deletion, and for a reasonable period after deletion to handle disputes, fraud claims, and legal obligations.

  • Purchase records are retained for at least seven years to comply with tax and accounting requirements.

  • Chat messages are retained indefinitely. If you delete your account, your messages remain visible in the chat history but your display name is replaced with a generic identifier (for example, "former user"). This is because chat is a shared social space and removing your messages would alter the conversation history that other users participated in. If you want a specific message removed, contact support@even.biz.

  • Marketing preferences and opt-out records are retained for at least five years to demonstrate compliance with marketing laws.

  • Consent records (including the exact disclosure text you accepted at sign-up) are retained for at least five years.

  • Support communications are retained for at least three years.

  • Analytics data is retained in identified form for up to twenty-six (26) months and in aggregated form indefinitely.

  • Backups containing your information may persist beyond these periods on a rolling basis as part of our disaster recovery practices, after which they are overwritten.

If you have a right to deletion under applicable law (see Section 8 and the regional addenda), we will delete or anonymize your personal information within the timeframes required by law, except where retention is required for legal, regulatory, or fraud-prevention purposes.

8. Your Rights and Choices

Depending on where you live, you have certain rights regarding your personal information. The rights below are available to all users where they don't conflict with applicable law. Additional or different rights may apply in your jurisdiction; see the regional addenda.

8.1 Universal Rights

  • Access: You can request a copy of the personal information we hold about you.

  • Correction: You can request that we correct inaccurate or incomplete information.

  • Deletion: You can request that we delete your personal information, subject to legal retention requirements and the chat-message rules in Section 7.

  • Marketing opt-out: You can opt out of marketing communications at any time (see Section 10).

  • Account closure: You can close your account at any time by emailing info@even.biz or using the in-account deletion tool.

8.2 How to Exercise Your Rights

Email info@even.biz with a description of your request. We will respond within 30 days, or sooner if required by your jurisdiction. We may need to verify your identity before processing certain requests.

If you are unsatisfied with our response, you may have the right to lodge a complaint with a data protection authority. See the regional addenda for the relevant authority in your jurisdiction.

8.3 No Discrimination

We will not discriminate against you for exercising your privacy rights. We will not deny you the Platform, charge different prices, or provide a different level of service because you exercised a right.

9. Cookies and Tracking Technologies

We and our service providers use cookies, web beacons, pixel tags, and similar technologies (collectively, "Cookies") to operate the Platform, analyze usage, and personalize your experience.

9.1 Categories of Cookies

  • Strictly necessary: Required for the Platform to function (authentication, session management, security). Cannot be disabled.

  • Functional: Remember your preferences and settings.

  • Analytics: Measure usage patterns and Platform performance.

  • Marketing: Track campaign effectiveness and tailor marketing communications.

9.2 How to Manage Cookies

When you first visit the Platform from a region where consent is required, you will see a cookie banner allowing you to accept, reject, or customize non-essential cookies. You can change your preferences at any time through the cookie settings link in the Platform footer.

You can also manage cookies through your browser settings. Note that disabling strictly necessary cookies may prevent the Platform from functioning correctly.

9.3 Do Not Track and Global Privacy Control

Some browsers offer a "Do Not Track" signal. Industry standards have not settled on a uniform interpretation of this signal, and we do not currently respond to it. We honor opt-out preferences expressed through the Global Privacy Control (GPC) signal where required by applicable law (including in California, Colorado, Connecticut, Oregon, and other states with universal opt-out mandates).

10. Marketing Communications

10.1 Email Marketing

If you receive marketing emails from us, you can unsubscribe by:

  • Clicking the unsubscribe link in any marketing email

  • Updating your preferences in your account settings

  • Emailing info@even.biz

We will honor opt-out requests within 10 business days.

10.2 SMS Marketing

If you opted into SMS marketing at sign-up, you can opt out by:

  • Replying STOP, QUIT, END, REVOKE, OPT-OUT, CANCEL, or UNSUBSCRIBE to any marketing text

  • Replying with any reasonable message indicating you want to stop

  • Updating your preferences in your account settings

  • Emailing info@even.biz

We will honor opt-out requests within 10 business days. After you opt out, you may receive one confirmation message and no further marketing texts.

Opting out of marketing does not affect transactional communications (authentication codes, order confirmations, account security notices), which are necessary for your account.

10.3 Frequency

Marketing SMS frequency is up to 10 messages per month. Marketing email frequency varies; you can adjust frequency or topic preferences in your account settings.

11. Information Security

We maintain administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction. Our practices include:

  • TLS encryption for data transmitted between your device and the Platform

  • Encryption at rest where supported by our infrastructure providers

  • Role-based access controls limiting employee access to personal information on a need-to-know basis

  • Multi-factor authentication on internal systems

  • Regular security review and vendor risk assessment

  • Logging and monitoring of access to systems containing personal information

  • Incident response procedures

EVEN is working toward SOC 2 Type II certification.

No system is completely secure. While we work to protect your information, we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately at info@even.biz.

12. Data Breaches

If we experience a data breach affecting your personal information, we will notify you and any required regulators in accordance with applicable law. Notification timing and content vary by jurisdiction and the nature of the breach. Specific obligations are described in the regional addenda.

13. Chat-Specific Disclosures

The Platform includes a community chat feature operated using Stream.io infrastructure. Specific disclosures for chat:

13.1 What We Collect in Chat

  • Message content

  • Timestamps and read receipts

  • Reactions

  • Reports you submit about other users

  • Moderation actions taken on your messages

13.2 Direct Messages

The chat does not support private direct messages between users. All chat content is posted in shared rooms or threads visible to other Members.

13.3 Moderation

Chat is actively moderated. We use a combination of:

  • Automated AI moderation to flag content for review against community standards (hate speech, harassment, spam, advertising, threats, sexual content, and similar policy violations)

  • Human moderation by EVEN staff or contracted moderators who review flagged content

  • User reporting allowing Members to flag content for review

Moderators can remove messages, restrict accounts, and ban users for violations of the community guidelines and Terms of Service.

13.4 Retention

Chat messages are retained indefinitely. If you delete your account, your messages remain in the chat history but your display name is replaced with a generic identifier. See Section 7.

13.5 Visibility

By posting in chat, you understand that your messages are visible to other Members and may be retained, screenshotted, or referenced by them. Do not share information in chat that you would not want to be public.

14. Children's Privacy

The Platform is intended for users 18 years of age and older. We do not knowingly collect personal information from individuals under 18 years of age

If you believe a person under 18 has created an account or provided personal information to us, contact us at info@even.biz. We will delete the account and any associated personal information without undue delay.

15. Gifts and Recipients

If you purchase a gift through the Platform, we collect the recipient's name and email to deliver the gift. The recipient must opt in (by accepting the gift and creating an account) before they can access the content.

We use recipient contact information solely to deliver the gift and notify the recipient. We do not use recipient contact information for marketing unless the recipient creates an account and opts in independently. If a recipient does not accept the gift within a reasonable time, we delete the recipient information after the offer expires, except where retention is required for fraud prevention or accounting.

16. Tour Information and External Links

The Platform includes a tour information section that links to ticketing partners (Ticketmaster and Live Nation) for the R&B Tour Starring Usher, Raymond and Chris Brown. When you click a tour link, you leave the Platform and visit the ticketing partner's site, which is governed by the partner's own privacy policy.

EVEN does not share your personal information with Ticketmaster or Live Nation in connection with these links. We may receive aggregated, de-identified data about referral traffic.

17. Changes to This Policy

We may update this Policy from time to time. The "Last Updated" date at the top reflects the most recent version. We will notify you of material changes by:

  • Posting the updated Policy on the Platform

  • Updating the Last Updated date

  • For material changes affecting your rights or our use of your information, providing additional notice by email, in-Platform notification, or other reasonable means in advance of the changes taking effect

Your continued use of the Platform after changes take effect constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you should close your account.

18. Contact Us

For questions about this Policy or to exercise your privacy rights:

Email: info@even.biz Mail: EVEN Labs Inc., Attn: Privacy, 313 N Plankinton Ave., Milwaukee, WI 53203, USA Support: support@even.biz

For UK and EU users, see the regional addenda for additional contacts and the relevant supervisory authorities.

REGIONAL ADDENDA

The regional addenda below apply in addition to the main Policy. Where a regional addendum conflicts with the main Policy, the regional addendum controls for users in that jurisdiction.

If you are unsure which addendum applies to you, contact us at info@even.biz.

ADDENDUM A: UNITED STATES

This Addendum applies to residents of the United States. State-specific sections below apply where indicated.

A.1 General US Provisions

A.1.1 Categories of Personal Information We Collect, Sell, or Share

Within the past twelve months, we have collected the categories of personal information described in Section 3 of the main Policy. We use these categories for the purposes described in Section 4 and disclose them to the recipients described in Section 5.

We do not sell personal information.

We do not share personal information for cross-context behavioral advertising except where you have opted in through cookie preferences (see Section 9).

We do not knowingly process the personal information of consumers under 16 years of age.

A.1.2 Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes other than those described in Section 4 and as permitted by applicable law.

A.1.3 Data Brokers

We are not a data broker and do not register as one.

A.2 California (CCPA / CPRA)

If you are a California resident, the following additional rights apply under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"). Definitions in the CCPA apply.

A.2.1 Your Rights

You have the right to:

  • Know what personal information we have collected about you, including the categories of information, sources, purposes, and recipients

  • Access a copy of the specific pieces of personal information we have collected

  • Delete personal information we have collected from you, subject to legal exceptions

  • Correct inaccurate personal information

  • Opt out of sale or sharing for cross-context behavioral advertising (we do not sell or share, but you can submit this preference)

  • Limit use of sensitive personal information to specified purposes

  • Non-discrimination for exercising your rights

A.2.2 How to Exercise California Rights

Submit a request by:

  • Emailing info@even.biz with the subject line "California Privacy Request"

  • Mailing EVEN Labs Inc., Attn: Privacy, 313 N Plankinton Ave., Milwaukee, WI 53203, USA

We will verify your identity before responding to access, deletion, or correction requests. Verification typically requires you to confirm two pieces of personal information we already hold.

We will respond within 45 days, with a possible 45-day extension. We may extend this once if reasonably necessary, with notice to you.

A.2.3 Authorized Agents

You may designate an authorized agent to make a request on your behalf. We will require written authorization signed by you and may verify the agent's identity.

A.2.4 Sensitive Personal Information

We collect the following categories of sensitive personal information as defined by the CCPA:

  • Account log-in information (in combination with credentials enabling access)

  • Precise geolocation (only if you opt in through device permissions; we do not collect by default)

We use this information only for the purposes permitted under CCPA Section 1798.121 (operating the Platform, security, and as you direct).

A.2.5 Notice at Collection

This Privacy Policy serves as our Notice at Collection for California consumers. The categories of personal information we collect, the purposes for collection, the retention period, and whether we sell or share information are described above.

A.2.6 Metrics

We will publish annual metrics on requests received and processed under the CCPA where required.

A.2.7 Shine the Light

Under California Civil Code Section 1798.83, California residents may request information about our disclosure of personal information to third parties for direct marketing purposes. We do not currently disclose personal information for third-party direct marketing purposes.

A.2.8 California Eraser Law

California Business and Professions Code Section 22581 allows California residents under 18 who are registered users of online services to remove content they post. Our Platform is not directed to and does not knowingly accept registrations from individuals under 18.

A.2.9 Complaints

You may file a complaint with the California Privacy Protection Agency at https://cppa.ca.gov/ or with the California Attorney General at https://oag.ca.gov/.

A.3 Colorado (CPA)

If you are a Colorado resident, you have the following rights under the Colorado Privacy Act:

  • Right of access to confirm processing and obtain a copy of your personal data

  • Right to correct inaccurate personal data

  • Right to delete personal data

  • Right to data portability in a portable, readable format

  • Right to opt out of targeted advertising, sale of personal data, and profiling in furtherance of decisions producing legal or similarly significant effects

To exercise these rights, email info@even.biz. We will respond within 45 days. You have the right to appeal a denial; appeal procedures will be described in any denial response.

We honor the Global Privacy Control as a universal opt-out mechanism for targeted advertising and sale of personal data.

You may file a complaint with the Colorado Attorney General at https://coag.gov/.

A.4 Connecticut (CTDPA)

If you are a Connecticut resident, you have the following rights under the Connecticut Data Privacy Act:

  • Right to access personal data we process about you

  • Right to correct inaccuracies

  • Right to delete personal data

  • Right to portability in a portable, readable format

  • Right to opt out of targeted advertising, sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects

To exercise these rights, email info@even.biz. We will respond within 45 days, with a 45-day extension if reasonably necessary. You have the right to appeal a denial.

We honor the Global Privacy Control for opt-out signals.

Effective July 1, 2026, Connecticut amendments expand the definition of sensitive data to include neural data and government-issued identification numbers, prohibit the sale of sensitive data without consent, and reduce the threshold for applicability. Where these provisions apply, we will treat the listed categories as sensitive data and obtain consent before processing for new purposes.

You may file a complaint with the Connecticut Attorney General at https://portal.ct.gov/AG.

A.5 Montana (MCDPA)

If you are a Montana resident, you have the following rights under the Montana Consumer Data Privacy Act:

  • Right to access personal data

  • Right to correct inaccuracies

  • Right to delete personal data

  • Right to portability

  • Right to opt out of targeted advertising, sale of personal data, and profiling in furtherance of decisions producing legal or similarly significant effects

The "solely automated" qualifier on profiling opt-outs was removed effective October 1, 2025. The opt-out applies to profiling whether or not the decision-making is solely automated.

To exercise these rights, email info@even.biz. We will respond within 45 days. You have the right to appeal a denial.

We honor the Global Privacy Control for opt-out signals.

You may file a complaint with the Montana Attorney General at https://dojmt.gov/.

A.6 Nevada

If you are a Nevada resident, Nevada Revised Statutes Chapter 603A gives you the right to opt out of the sale of certain personal information to third parties.

We do not sell personal information as defined under Nevada law. If you wish to formally exercise this right, email info@even.biz with the subject line "Nevada Opt-Out Request."

A.7 Oregon (OCPA)

If you are an Oregon resident, you have the following rights under the Oregon Consumer Privacy Act:

  • Right to know and access personal data, including the specific third parties to which we have disclosed your data

  • Right to correct inaccuracies

  • Right to delete personal data

  • Right to portability

  • Right to opt out of targeted advertising, sale of personal data, and profiling

We do not sell personal data of consumers under 16 years of age. We do not sell precise geolocation data relating to an individual's location within a 1,750-foot radius.

To exercise these rights, email info@even.biz. We will respond within 45 days.

We honor the Global Privacy Control for opt-out signals.

You may file a complaint with the Oregon Attorney General at https://www.doj.state.or.us/.

A.8 Texas (TDPSA)

If you are a Texas resident, you have the following rights under the Texas Data Privacy and Security Act:

  • Right to confirm processing and access personal data

  • Right to correct inaccuracies

  • Right to delete personal data

  • Right to portability

  • Right to opt out of targeted advertising, sale of personal data, and profiling

To exercise these rights, email info@even.biz. We will respond within 45 days.

We honor the Global Privacy Control for opt-out signals.

The Texas Data Privacy and Security Act applies to businesses that conduct business in Texas or target Texas residents and process personal data, regardless of revenue or volume thresholds. We comply with this lower-threshold standard.

You may file a complaint with the Texas Attorney General at https://www.texasattorneygeneral.gov/.

A.9 Utah (UCPA)

If you are a Utah resident, you have the following rights under the Utah Consumer Privacy Act:

  • Right to know and access personal data

  • Right to correct personal data (effective July 2026)

  • Right to delete personal data you provided to us

  • Right to portability

  • Right to opt out of sale of personal data and targeted advertising

To exercise these rights, email info@even.biz. We will respond within 45 days.

You may file a complaint with the Utah Division of Consumer Protection or the Utah Attorney General.

A.10 Virginia (VCDPA)

If you are a Virginia resident, you have the following rights under the Virginia Consumer Data Protection Act:

  • Right to access personal data

  • Right to correct inaccuracies

  • Right to delete personal data

  • Right to portability

  • Right to opt out of targeted advertising, sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects

To exercise these rights, email info@even.biz. We will respond within 45 days, with a 45-day extension if reasonably necessary. You have the right to appeal a denial.

You may file a complaint with the Virginia Attorney General at https://www.oag.state.va.us/.

ADDENDUM B: CANADA

B.1 PIPEDA (Federal)

This section applies to Canadian residents under the Personal Information Protection and Electronic Documents Act ("PIPEDA"), which applies to personal information collected, used, or disclosed in the course of commercial activity.

B.1.1 Your Rights

Under PIPEDA, you have the right to:

  • Access your personal information held by us

  • Challenge the accuracy and completeness of your personal information and have it amended as appropriate

  • Withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice

  • File a complaint with the Office of the Privacy Commissioner of Canada

B.1.2 Lawful Basis

We collect, use, and disclose personal information with your consent, except where we are permitted or required by law to do so without consent. We rely on implied consent for routine commercial activities and express consent for sensitive information and marketing communications.

B.1.3 Exercising Rights

Email info@even.biz. We will respond within 30 days, with a possible extension as permitted by law.

B.1.4 Complaints

You may file a complaint with the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/ or by mail at:

Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3 Canada Phone: 1-800-282-1376

B.2 Quebec (Law 25)

If you are a resident of Quebec, the Act to modernize legislative provisions as regards the protection of personal information (commonly known as "Law 25" or formerly Bill 64) applies in addition to PIPEDA.

B.2.1 Privacy Officer

EVEN's Privacy Officer is responsible for compliance with Law 25 and can be contacted at:

Email: info@even.biz (Attn: Privacy Officer) Mail: EVEN Labs Inc., Attn: Privacy Officer, 313 N Plankinton Ave., Milwaukee, WI 53203, USA

B.2.2 Your Rights

Under Law 25, Quebec residents have the right to:

  • Be informed about the collection, use, and disclosure of personal information

  • Access personal information we hold about you

  • Rectify inaccurate or incomplete personal information

  • Request de-indexation of personal information (the right to be forgotten)

  • Withdraw consent to processing

  • Data portability in a structured, commonly used, technological format (effective September 22, 2024)

  • Object to automated decision-making that produces legal or similarly significant effects

B.2.3 Consent

Consent under Law 25 must be free, clear, informed, granular, and specific to each purpose of data use. Consent for sensitive personal information must be express. We obtain express consent for marketing communications and for the use of cookies that are not strictly necessary.

B.2.4 Cross-Border Transfers

Law 25 requires that personal information transferred outside Quebec receive a level of protection equivalent to that provided in Quebec. Before transferring your personal information outside Quebec, we conduct an assessment, enter into appropriate contractual safeguards, and inform you of the transfer. By using the Platform, you acknowledge that your personal information will be transferred to and processed in the United States and other countries where our service providers operate, subject to appropriate safeguards.

B.2.5 Privacy Impact Assessments

We conduct privacy impact assessments where required by Law 25, including for transfers outside Quebec and for new technologies handling personal information.

B.2.6 Response Time

We will respond to requests within 30 days. If we deny your request, we will explain why and inform you of your right to seek review by the Commission d'accès à l'information.

B.2.7 Private Right of Action and Complaints

Law 25 provides individuals with a private right of action for violations resulting from intentional misconduct or gross fault.

You may file a complaint with the Commission d'accès à l'information du Québec at:

Website: https://www.cai.gouv.qc.ca/ Quebec address: Bureau 2.36, 525, boulevard René-Lévesque Est, Québec (Québec) G1R 5S9 Montreal address: Bureau 18.200, 500, boulevard René-Lévesque Ouest, Montréal (Québec) H2Z 1W7

ADDENDUM C: UNITED KINGDOM, EUROPEAN ECONOMIC AREA, AND SWITZERLAND

This Addendum applies to residents of the United Kingdom (UK), the European Economic Area (EEA), and Switzerland. It implements requirements under the UK General Data Protection Regulation ("UK GDPR"), the EU General Data Protection Regulation ("EU GDPR"), the UK Data Protection Act 2018, and the Swiss Federal Act on Data Protection ("FADP").

C.1 Controller and Representative

EVEN Labs Inc., 313 N Plankinton Ave., Milwaukee, WI 53203, USA, is the controller of your personal information.

EU Representative (Article 27 GDPR): [TO BE APPOINTED BEFORE EU LAUNCH]

UK Representative (Article 27 UK GDPR): [TO BE APPOINTED BEFORE UK LAUNCH]

Privacy contact: info@even.biz

C.2 Legal Bases for Processing

We rely on the following Article 6 GDPR legal bases:

Processing activity

Legal basis

Account creation, authentication, processing purchases, providing the Platform

Performance of a contract (Article 6(1)(b))

Marketing communications

Consent (Article 6(1)(a))

Cookies (other than strictly necessary)

Consent (Article 6(1)(a))

Security, fraud prevention, analytics

Legitimate interests (Article 6(1)(f))

Legal compliance, response to lawful requests

Legal obligation (Article 6(1)(c))

For sensitive data ("special category data") under Article 9 GDPR, we rely on explicit consent or another applicable Article 9 condition.

You may contact us at info@even.biz to obtain more information about our balancing assessments where we rely on legitimate interests.

C.3 Your Rights Under GDPR / UK GDPR / FADP

You have the following rights, subject to applicable conditions and exceptions:

  • Right of access (Article 15): obtain a copy of your personal data and information about how we process it

  • Right to rectification (Article 16): correct inaccurate or incomplete personal data

  • Right to erasure (Article 17, "right to be forgotten"): request deletion of your personal data in certain circumstances

  • Right to restriction of processing (Article 18): require us to limit processing in certain circumstances

  • Right to data portability (Article 20): receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller

  • Right to object (Article 21): object to processing based on legitimate interests, including profiling, and to marketing

  • Right not to be subject to automated decision-making (Article 22): we do not currently use automated decision-making producing legal or similarly significant effects

  • Right to withdraw consent (Article 7): where processing is based on consent, withdraw consent at any time without affecting the lawfulness of prior processing

To exercise these rights, email info@even.biz. We will respond within one month of receipt, with a possible two-month extension for complex requests, in which case we will inform you within the first month.

C.4 International Transfers

Your personal data is transferred to and processed in the United States and other countries that may not have laws providing the same level of protection as your country of residence.

We rely on the following transfer mechanisms:

  • EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) for transfers from the EEA

  • UK International Data Transfer Addendum to the EU SCCs, or the UK International Data Transfer Agreement, for transfers from the UK

  • Swiss adaptations to the EU SCCs for transfers from Switzerland under the FADP

  • Adequacy decisions where they apply

For transfers to the United States specifically, where applicable, we may also rely on participation in the EU-US Data Privacy Framework, the UK Extension to the Data Privacy Framework, or the Swiss-US Data Privacy Framework by our service providers that are certified under those frameworks.

You may request a copy of the safeguards applicable to your data by emailing info@even.biz.

C.5 Supervisory Authorities

You have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or place of an alleged infringement.

United Kingdom: Information Commissioner's Office (ICO) Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF https://ico.org.uk/

Switzerland: Federal Data Protection and Information Commissioner (FDPIC) Feldeggweg 1, 3003 Bern https://www.edoeb.admin.ch/

EEA Member States: A list of EEA supervisory authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. You may file a complaint with the supervisory authority of your country.

Examples of EEA supervisory authorities:

C.6 Data Breach Notification

We will notify the relevant supervisory authority within 72 hours of becoming aware of a personal data breach where required under Article 33 GDPR/UK GDPR. Where a breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.

C.7 Data Retention

In addition to the retention periods in Section 7 of the main Policy, we retain personal data only for as long as necessary for the purposes of processing, taking into account legal, regulatory, and operational requirements. You can request information about specific retention periods by emailing info@even.biz.

C.8 Switzerland-Specific Provisions

For Swiss residents, the FADP applies in addition to or instead of the EU GDPR depending on the specific circumstances. Your rights under the FADP are substantially similar to those under the EU GDPR. Complaints may be lodged with the Federal Data Protection and Information Commissioner (FDPIC) at the address above.

C.9 Cookies and Consent

We obtain consent for non-essential cookies through a cookie consent banner before any non-essential cookies are placed on your device. You can manage your cookie preferences at any time through the cookie settings link in the Platform footer. See Section 9 of the main Policy.

ADDENDUM D: BRAZIL (LGPD)

This Addendum applies to residents of Brazil under the Lei Geral de Proteção de Dados Pessoais ("LGPD," Federal Law No. 13.709/2018).

D.1 Controller and DPO

EVEN Labs Inc. is the controller of your personal data. Our Data Protection Officer ("Encarregado") for Brazil can be contacted at:

Email: info@even.biz (Attn: DPO Brazil) Mail: EVEN Labs Inc., Attn: DPO Brazil, 313 N Plankinton Ave., Milwaukee, WI 53203, USA

D.2 Your Rights Under LGPD

Under Article 18 of the LGPD, you have the right to:

  • Confirm the existence of processing of your personal data

  • Access your personal data

  • Correct incomplete, inaccurate, or outdated data

  • Anonymize, block, or delete unnecessary, excessive, or non-compliantly processed data

  • Portability of your data to another service or product provider

  • Delete personal data processed with your consent

  • Information about public and private entities with which we have shared your data

  • Information about the possibility of refusing consent and the consequences of refusal

  • Revoke consent at any time

To exercise these rights, email info@even.biz. We will respond within 15 days, in accordance with Article 19 of the LGPD.

D.3 Legal Bases (Hipóteses de Tratamento)

We process personal data based on the legal bases listed in Article 7 (or Article 11 for sensitive data) of the LGPD, including:

  • Consent (Article 7, I) for marketing communications and non-essential cookies

  • Performance of a contract (Article 7, V) for providing the Platform and processing purchases

  • Legitimate interests (Article 7, IX) for security, fraud prevention, and analytics

  • Compliance with legal or regulatory obligation (Article 7, II)

  • Protection of credit (Article 7, X) for fraud prevention

D.4 International Transfers

We transfer your personal data to the United States and other countries. Under Articles 33-36 of the LGPD, we rely on the following mechanisms:

  • Specific consent of the data subject for the transfer

  • Performance of a contract to which you are a party

  • Standard contractual clauses with the data importer

  • Other safeguards approved by the Autoridade Nacional de Proteção de Dados (ANPD)

D.5 Complaints

You may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD):

Website: https://www.gov.br/anpd/ Address: Esplanada dos Ministérios - Bloco C - 1° andar, Brasília - DF, 70046-900, Brazil

D.6 Children and Adolescents

The Platform is intended for users 18 years of age and older. The LGPD provides specific protections for the processing of personal data of children (under 12) and adolescents (12-18) under Article 14. We do not knowingly process the personal data of any individual under 18.

ADDENDUM E: AUSTRALIA

This Addendum applies to residents of Australia under the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs").

E.1 Open and Transparent Management (APP 1)

This Privacy Policy is our APP 1 privacy policy. We manage personal information openly and transparently in accordance with the APPs.

E.2 Anonymity and Pseudonymity (APP 2)

Where lawful and practicable, you may interact with us anonymously or pseudonymously (for example, by browsing the Platform without creating an account). To create a Member account or make a purchase, we require identifying information.

E.3 Collection of Personal Information (APPs 3-5)

We collect personal information for the purposes described in Section 4 of the main Policy. We collect directly from you wherever practicable. Where we collect from third parties (for example, our service providers), we do so as described in Section 3.3.

E.4 Use and Disclosure (APP 6)

We use and disclose your personal information only for the primary purpose of collection or for a related secondary purpose that you would reasonably expect, except as you consent or as permitted by law.

E.5 Direct Marketing (APP 7)

We may use your personal information for direct marketing only where you have consented or where you would reasonably expect us to do so. You can opt out at any time using the methods described in Section 10 of the main Policy.

E.6 Cross-Border Disclosure (APP 8)

We may disclose your personal information to recipients in the United States and other countries. We take reasonable steps to ensure that overseas recipients do not breach the APPs. By using the Platform, you acknowledge that your personal information will be transferred to and processed in the United States and other countries where our service providers operate.

Where we rely on your consent for cross-border disclosure under APP 8.2(b), you acknowledge that we will not be accountable under APP 8.1 for an act or practice of an overseas recipient that breaches the APPs.

E.7 Government Identifiers (APP 9)

We do not adopt, use, or disclose any government-related identifier (such as Tax File Numbers or Medicare numbers) as our own identifier of you.

E.8 Quality and Security (APPs 10-11)

We take reasonable steps to ensure that personal information is accurate, up-to-date, and complete (APP 10) and to protect personal information from misuse, interference, loss, unauthorized access, modification, or disclosure (APP 11). See Section 11 of the main Policy.

E.9 Access and Correction (APPs 12-13)

You have the right to request access to and correction of your personal information. Email info@even.biz to make a request. We will respond within a reasonable period (generally within 30 days). We may charge a reasonable fee for providing access where permitted; we do not charge for correction.

E.10 Notifiable Data Breaches

If we experience an eligible data breach as defined under the Notifiable Data Breaches scheme, we will notify the Office of the Australian Information Commissioner ("OAIC") and affected individuals as required by law.

E.11 Complaints

If you have a complaint, contact us first at info@even.biz. If you are not satisfied with our response, you may lodge a complaint with the OAIC:

Website: https://www.oaic.gov.au/ Phone: 1300 363 992 Mail: Office of the Australian Information Commissioner, GPO Box 5288, Sydney NSW 2001

ADDENDUM F: PHILIPPINES

This Addendum applies to residents of the Philippines under the Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

F.1 Data Protection Officer

Our Data Protection Officer ("DPO") for the Philippines can be contacted at:

Email: info@even.biz (Attn: DPO Philippines) Mail: EVEN Labs Inc., Attn: DPO Philippines, 313 N Plankinton Ave., Milwaukee, WI 53203, USA

F.2 Your Rights Under the DPA

Under Section 16 of the DPA, you have the following rights:

  • Right to be informed about the processing of your personal information

  • Right to access your personal information

  • Right to object to processing of your personal information

  • Right to erasure or blocking of your personal information from our system

  • Right to damages for inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal information

  • Right to data portability for personal information in an electronic or structured format

  • Right to file a complaint with the National Privacy Commission ("NPC")

To exercise these rights, email info@even.biz.

F.3 Lawful Bases

We process personal information based on the criteria for lawful processing in Sections 12 and 13 of the DPA, including consent, contract performance, legal obligation, vital interests, public authority, and legitimate interests.

We obtain consent for processing sensitive personal information and privileged information as required by Section 13.

F.4 Cross-Border Transfers

We transfer personal information outside the Philippines. We ensure that transferred personal information receives appropriate protection through contractual safeguards and other measures, in accordance with Section 21 of the DPA and NPC issuances.

F.5 Security

We implement reasonable and appropriate organizational, physical, and technical measures to protect personal information, in accordance with Section 20 of the DPA.

F.6 Breach Notification

If we experience a personal data breach that is likely to give rise to a real risk of serious harm to affected data subjects, we will notify the NPC and affected data subjects within 72 hours of becoming aware of the breach, in accordance with NPC rules.

F.7 Complaints

You may file a complaint with the National Privacy Commission:

Website: https://privacy.gov.ph/ Email: complaints@privacy.gov.ph Address: National Privacy Commission, 5th Floor, Philippine International Convention Center, Vicente Sotto St., Pasay City 1300

ADDENDUM G: SOUTH AFRICA (POPIA)

This Addendum applies to residents of South Africa under the Protection of Personal Information Act, 4 of 2013 ("POPIA").

G.1 Information Officer

EVEN's Information Officer for South Africa can be contacted at:

Email: info@even.biz (Attn: Information Officer) Mail: EVEN Labs Inc., Attn: Information Officer, 313 N Plankinton Ave., Milwaukee, WI 53203, USA

G.2 Conditions for Lawful Processing

We process personal information in accordance with the eight conditions for lawful processing under POPIA:

  1. Accountability (Section 8)

  2. Processing limitation (Sections 9-12): processing is lawful, reasonable, minimal, and based on consent or another lawful ground

  3. Purpose specification (Sections 13-14): collected for specific, explicitly defined, and lawful purposes

  4. Further processing limitation (Section 15): further processing is compatible with the original purpose

  5. Information quality (Section 16): we take reasonable steps to ensure information is complete, accurate, and updated

  6. Openness (Sections 17-18): we maintain documentation and provide notification of collection

  7. Security safeguards (Sections 19-22): we implement appropriate technical and organizational measures

  8. Data subject participation (Sections 23-25): we facilitate access, correction, and deletion

G.3 Your Rights Under POPIA

You have the right to:

  • Be notified that we are collecting your personal information

  • Access your personal information

  • Request correction, destruction, or deletion of inaccurate, irrelevant, excessive, out-of-date, incomplete, misleading, or unlawfully obtained information

  • Object to processing on reasonable grounds, including for direct marketing purposes (free of charge and through accessible channels)

  • Not be subject to a decision based solely on automated processing that produces legal effects

  • Submit a complaint to the Information Regulator

  • Institute civil proceedings for any violation

The 2025 amended POPIA regulations require that objections to processing be free of charge and submittable through multiple accessible channels including hand delivery, post, email, SMS, WhatsApp, or other expedient means.

G.4 Direct Marketing

We will not process your personal information for direct marketing without your consent or, in the case of existing customers, without giving you a reasonable opportunity to object. You have an unconditional right to object to direct marketing at any time, free of charge.

G.5 Cross-Border Transfers

We transfer personal information outside South Africa to the United States and other countries. We rely on the grounds in Section 72 of POPIA, including:

  • The recipient is subject to law, binding corporate rules, or a binding agreement providing an adequate level of protection

  • You have consented to the transfer

  • The transfer is necessary for the performance of a contract between you and us

  • The transfer is for your benefit

G.6 Security Compromise Notification

If we experience a security compromise (data breach), we will notify the Information Regulator and affected data subjects as soon as reasonably possible, through the Information Regulator's eServices Portal.

G.7 Complaints

You may file a complaint with the Information Regulator:

Website: https://inforegulator.org.za/ Email: complaints.IR@inforegulator.org.za Address: Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

END OF PRIVACY POLICY

This Privacy Policy was last updated on [DATE]. Previous versions are available on request by emailing info@even.biz.

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