Privacy Policy

Last Updated on Sept 10, 2026

This privacy policy (the "Policy") describes the treatment of information provided or collected on the Company's website (the "Website") or the Fringle mobile app (collectively, the "Product"). The purpose of this Policy is to describe how the Product collects, shares and secures information provided by you. Therefore, before you provide RISENTECH, LLC (the "Company", "We", or "us") with any personal information, you should read through this Policy in its entirety and understand its terms. We may update the Policy from time to time, so please check in occasionally. Ultimately, our goal is to provide a Company Policy that is transparent in how we handle your information.

INFORMATION WE COLLECT HOW WE COLLECT YOUR INFORMATION FACE DATA AND IDENTITY VERIFICATION WHAT WE DO WITH YOUR INFORMATION SHARING YOUR INFORMATION YOUR CONTROLS AND CHOICES SECURITY MEASURES HOW WE COMMUNICATE WITH YOU CHILDREN CHANGES TO THIS POLICY NOTICE TO CALIFORNIA RESIDENTS CALIFORNIA DO NOT TRACK DISCLOSURES

1. INFORMATION WE COLLECT:

When using the Product, you may choose to provide the Company with information about yourself which is "personally identifiable information." The term "personally identifiable information" means information that is collected in connection with your name such as your address, e-mail, phone number, location, photos, videos, directory of your contacts, billing and credit or debit card information, live selfie images and the biometric facial data derived from them for identity verification purposes ("Face Data," as further described in Section 3 below), and any other information that you provide to us (collectively, "Personal Information"). Your use of the Product may also entail you providing information that is not Personal Information, meaning that such information is not connected to your name and is, therefore, anonymous information and which does not identify and cannot reasonably be used to identify an individual Product user. It is your choice whether to provide us with Personal Information and the provision of such Personal Information is not required when visiting the Product, provided that certain features of the Product, such as the identity verification feature described in Section 3, will not be available to you without it. Therefore, if you provide us with Personal Information, such as by asking to be put on our mailing list or subscribe to our website, we may contact you from time to time.

Some examples of the types of information We collect are:

Information you provide us when you use our Product or when you link your profile on a third-party site or platform with your registration account.

Location information when you visit our Product, including location information either provided by a mobile device interacting with our Product (including through beacon technologies) or associated with your IP address, where We are permitted by law to process this information.

Usage, viewing and technical data, including your device identifier or IP address, when you visit our Product or open emails We may send you.

Face Data collected through our optional identity verification feature, as described in Section 3 below.

2. HOW WE COLLECT YOUR INFORMATION AND COOKIES:

We collect Personal Information from you when you use our Product. Please keep in mind that when you provide any information to us on a third-party site or platform (e.g., Facebook), that any information you provide may be separately collected by the third-party site or platform. The Personal Information We collect is covered by this Policy and the information the third-party site or platform collects is subject to the third-party site or platform's privacy practices and, therefore, you should familiarize yourself with any applicable third-party privacy policy as needed.

We collect information through technology such as cookies (which are information stored on your computer by your browser to save your preferences while you are visiting a particular site) and web beacons (small pieces of data that are embedded in images on the pages of websites) when you visit our Product. This tracking data is used for many purposes including, for example, to provide useful features to simplify your experience when you return to our Product; deliver relevant content based on your preferences, usage patterns and location; monitor and evaluate the use and operation of our Product; and to analyze traffic on our Product and the sites of third parties. We may associate this tracking data with your registration account or the like, in which case We will treat it as Personal Information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online. For more information about cookies and web beacons, please visit: www.allaboutcookies.org.

If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser's help file directions. In addition, you can always opt-out of receiving certain ads or communications.

As you enter our Website or access our Product, we capture and retain the IP address of the device you are using, such as a personal computer or a mobile device.

3. FACE DATA AND IDENTITY VERIFICATION:

The Product offers an optional identity verification feature designed to help confirm that users are who they say they are and to promote a trustworthy community of members. This section describes, specifically, how We collect, use, disclose, retain, secure, and delete Face Data, and how you may exercise control over it.

Collection. If you choose to participate in identity verification, you will be prompted to capture a live, in-app selfie (a "Verification Selfie"). We do not permit upload of a pre-existing photo for this purpose; the Verification Selfie must be captured live through the Product at the time of the verification request. The Verification Selfie, and any facial geometry or image data derived from it (collectively, "Face Data"), is transmitted to and stored on Our secured backend systems.

Use. Face Data is used solely for the following purposes: (i) to allow a trained member of Our administrative staff to manually compare your Verification Selfie against the profile photograph(s) you have submitted to your account, in order to confirm that the same individual appears in both; (ii) to determine whether to approve or reject your verification request; and (iii) to administer the "Verified" badge feature described below. If your Verification Selfie is approved, your profile will display a verification badge visible to other users. If your Verification Selfie is rejected, You will receive an in-app notification and will be given the opportunity to submit a new Verification Selfie. We do not use Face Data for advertising or marketing purposes, and We do not use Face Data to conduct automated facial recognition, to identify you against any external database, or for any purpose other than the manual, human-reviewed identity verification described above.

Access. Access to Face Data is limited to a small number of authorized administrative personnel who require such access to perform manual identity verification review. These personnel may not access Face Data for any other purpose, and are subject to confidentiality and data-handling obligations consistent with this Policy.

Disclosure and Sharing. We do not sell, rent, license, or otherwise disclose your Face Data to any third party, data broker, or affiliate for any purpose, including marketing purposes. We do not currently use any third-party vendor or service provider to process, store, or review Face Data; all collection, storage, and manual review of Face Data occurs on Our own systems and by Our own personnel. If We engage a third-party service provider to process Face Data on Our behalf in the future, We will update this Policy in advance and will require any such third party, by written agreement, to provide protections for your Face Data that are at least as protective as those described in this Policy.

Retention. We retain your Face Data for only as long as your Product account remains active, and only for so long as reasonably necessary to fulfill the identity-verification purposes described above.

Deletion and Your Right to Withdraw Consent. Providing a Verification Selfie is entirely optional and is never a condition of using the core features of the Product. You may decline to participate in identity verification, and you may withdraw your consent to Our collection or use of your Face Data, at any time, by (i) contacting Us at info@fringleapp.com and requesting deletion of your Face Data, or (ii) deleting your Product account. Upon deletion of your account, all Face Data associated with that account — including all Verification Selfies, whether approved, rejected, or pending review — is permanently deleted from Our systems, along with the rest of your account data. If you withdraw consent without deleting your account, We will delete your existing Face Data, your verification badge (if any) will be removed, and you will need to resubmit a new Verification Selfie should you wish to become verified again in the future.

4. WHAT WE DO WITH YOUR INFORMATION:

The Company may use any information, including Personal Information, provided by you on the Product for the following purposes:

Present our website and its contents to you.

Provide you with any information, products, or services that you request from us.

To fulfill any other purpose for which you provide it, including verifying your identity as described in Section 3 above.

For any other purposes with your consent.

Consistent with local law and choices and controls that may be available to you:

Send you offers and promotions for our products and services or third-party products and services.

Personalize content and experiences.

Provide you with advertising based on your activity on our Product and on third-party sites and applications.

· The Company or Product may collect aggregated statistical information for purposes of improving our services. This data does not contain Personal Information, such as name or email address. An example might be location data, mouse movements or links clicked that might be used to improve our user experience.

Optimize or improve our products, services and operations.

Detect, investigate and prevent activities that may violate our policies or be illegal.

For the avoidance of doubt, Face Data is used exclusively for the identity-verification purposes described in Section 3 above and is never used for advertising, marketing, personalization, or any other purpose described in this Section 4.

5. SHARING YOUR INFORMATION:

Personal Information about our customers is important to us and we are not in the business of selling this Personal Information to others. We share customer Personal Information only as set forth below and with subsidiaries that the Company controls or a parent company and that are either subject to this Policy or that follow practices that are at least as restrictive as those described in this Policy.

Internal Process/Employees: Company allows a very limited number of employees to have access to your Personal Information. These employees are trained on our security practices and are deeply committed to maintaining your privacy. They are authorized to access your account information, including Face Data where applicable, on an "as-needed" basis to provide technical or billing support, to perform identity verification review, or at your request.

Business Transactions and Partner Companies. Company will never disclose or sell your Personal Information, including your Face Data, to any third parties, including partners. We will never use client or user information, including Face Data, for any purposes other than to provide the contracted services or to keep you apprised of promotions. You are free to unsubscribe from promotional emails at any time.

Exceptions to Sharing Information: Exceptions to sharing your Personal Information include when the customer provides direct permission, or when it is required with the law or with legal processes.

Law Enforcement. We may report to law enforcement agencies any activities that We reasonably believe to be unlawful, or that We reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, We reserve the right to release your information to law enforcement agencies if We determine, in our sole judgment, that either you have violated our policies, or the release of your information may protect the rights, property, or safety of the Company or another person.

Legal Process. We may share your information with others as required by, or permitted by, law. This may include sharing your information with government entities, or third parties in response to subpoenas, court orders, other legal process, or as We believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that We determine in our sole discretion might be brought against us.

Blogs and other Online Postings. We may decide to allow users to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information you submit may be available generally to the public. Information that you provide in these areas may be read, collected, and used by others who access them. Face Data is never posted publicly and is never made visible to other users; only the resulting verification badge, if earned, is visible on your profile.

6. YOUR CONTROLS AND CHOICES:

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your Personal Information. In accordance with local law, your controls and choices may include:

You may correct, update and delete your registration account.

You may change your choices for subscriptions, newsletters and alerts.

You may choose whether to receive offers from us and promotions for our services.

You may choose whether We share your Personal Information with other companies so they can send you offers and promotions about their products and services.

You may choose whether to receive targeted advertising from many ad networks, data exchanges, marketing analytics and other service providers.

You may request access to the Personal Information We hold about you and that We amend or delete such information.

You may decline to submit a Verification Selfie, and may withdraw consent to Our collection or use of your Face Data and request its deletion at any time, as described in Section 3 above.

You may set your browser to refuse all or some browser cookies, or to alter you when cookies are being sent.

You may exercise your controls and choices, or request access to your Personal Information, by contacting us via email at info@fringleapp.com, by updating your user profile, or by following instructions provided in communications sent to you. Please be aware that if you do not allow us to collect Personal Information from you, We may not be able to deliver certain products to you and some of our services may not be able to take account of your interests and preferences; for example, declining to submit a Verification Selfie will mean you are not able to obtain a verification badge. If you have questions regarding the specific Personal Information about you that We process or retain, please contact us at info@fringleapp.com.

7. SECURITY MEASURES:

The security, integrity and confidentiality of your Personal Information, including your Face Data, is extremely important to us. We take all reasonable and appropriate measures, including administrative, technical, and physical safeguards, to secure your Personal Information once We receive it, and to help prevent it from being disclosed to individuals who are not described in this Policy. Access to Face Data is restricted to authorized personnel as described in Section 3 above. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and, therefore, we cannot guarantee that Personal Information will remain secure in all circumstances.

8. HOW WE COMMUNICATE WITH YOU:

If you have any questions about our Policy, you can contact us at info@fringleapp.com. If We need, or are required, to contact you concerning any event that involves your Personal Information, including a rejected Verification Selfie, We may do so by email, telephone, mail, or in-app notification.

9. CHILDREN:

The Company is committed to protecting the online privacy of children and making the internet safe. We do not provide products and services to children, or knowingly collect or solicit Personal Information, including Face Data, from children under 18 years of age. Any communication We get that is identified as being from a child under 18 will not be kept by the Company. We encourage parents or guardians of children under 18 to regularly check and monitor their children's use of email and other activities online. Further, You affirm that you are at least 18 years of age.

10. CHANGES TO THIS POLICY:

Your use of our Product, including any dispute concerning privacy, is subject to this privacy policy and the applicable Product Terms and Conditions. BY USING OUR PRODUCT, YOU ARE ACCEPTING THE PRACTICES SET OUT IN THIS PRIVACY POLICY AND THE APPLICABLE PRODUCT TERMS AND CONDITIONS. We reserve the right to modify this Policy at any time by posting the changes on this page. Please check the effective date at the top of this page to determine if the Policy has been modified since you last reviewed it. Your continued use of any portion of our Product following posting of the updated Policy will constitute your acceptance of the changes.

11. NOTICE TO CALIFORNIA RESIDENTS:

If you are a California resident, California Civil Code Section 1798.83 permits you to request a notice regarding the disclosure of your Personal Information by the Company to partners for the partners' direct marketing purpose. If you are a California resident and would like a copy of this notice, please contact us at info@fringleapp.com. To the extent the California Consumer Privacy Act or other applicable law classifies Face Data as sensitive personal information or biometric information, We limit Our use of such information to the identity-verification purposes described in Section 3 above, and California residents may exercise their rights to know, delete, and limit the use of such information by contacting Us at info@fringleapp.com.

12. CALIFORNIA DO NOT TRACK NOTICE DISCLOSURES:

We do not track our users and visitors over time and across third party websites to provide targeted advertising. Consequently, we do not respond to Do Not Track (DNT) signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.