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Privacy Policy

Effective as of October 26, 2026

Last updated: October 26, 2026

Web Version 1.0

This Privacy Policy describes how Oceano HK Holding Limited (“Company”, “Builda”, “we”, “us”, or “our”) collects, uses, discloses, transfers and stores your Personal Data when you access the Builda website (the “Website”) and its related online features and services (collectively, the “Services”), as well as what choices you have about it. This Privacy Policy applies to the Website. If another version of Builda is offered through a different channel, its applicable privacy notice and account arrangements will be stated separately.

Builda’s Services allow users to convert artwork uploaded through the Website into AI-driven 2D/3D content, including 2D images and 3D previews of customized products. Users may select product forms and specifications, manage creations in My Builda, and order customized physical products produced from such content. Please carefully read and understand this Privacy Policy together with our Terms of Use to make choices that you deem appropriate before using the Services.

The Privacy Policy only applies to the Personal Data we collect.

The Privacy Policy will help you understand the following:

Index

1.Definitions

2.Collecting and Using Your Personal Data

3.How We Store Your Personal Data

4.How and When We Share Your Personal Data

5.Your Rights and Choices

6.Security

7.How We Transfer Your Personal Data Globally

8.Our Policy on Children’s Data

9.Other Sites and Services

10.How We Make Changes to This Policy

11.Contact Us

Annex 1 – Privacy Notice for U.S. State Residents

1. Definitions

“Collect” refers to the behaviour of gaining control over Personal Data, including voluntary provision by the data subject, automatic collection by interaction with the data subject or recording the behaviour of the data subject, and indirect acquisition by sharing, transferring and collecting public information.

“Controller” refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Children” is a term defined differently under different jurisdictions, e.g., it refers to an individual who is under the age of 13 pursuant to the Children’s Online Privacy Protection Act (“COPPA”), in the U.S.

“Delete” refers to the behaviour of removing Personal Data from the system involved in the implementation of daily business functions, so that it cannot be retrieved and accessed.

“Personal Data” refers to any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data may be contained in Inputs, Outputs and related metadata, including where processed within AI systems.

“Processing” refers to any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Publicly disclose” refers to the behaviour of releasing information to the society or to non-specific groups of people.

“Share” refers to the process of Personal Data controller providing Personal Data to other controllers, and both sides have independent control over Personal Data. The terms “sale” and “sharing”, where used in Annex 1, have the meanings given to them under the applicable U.S. state privacy law.

“Third Parties” refer to companies or persons who do not have a related relationship arising out of joint ownership or control with Builda (i.e., a non-Affiliated Company) or other non-related persons. Third parties can be financial or non-financial companies, or persons other than you and Builda;

“Transfer” refers to the process of transferring Personal Data control from one controller to another.

“You” or “your” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

“Inputs” refers to the supported 2D artwork and related project or product information you provide to the Services in order to generate content or order a customized product.

“Outputs” refers to the 2D images and 3D previews that the Services generate in response to your Inputs.

“Sensitive Personal Data” refers to categories of Personal Data that are afforded special protection under applicable law, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, precise geolocation, government identifiers, or financial account information.

2. Collecting and Using Your Personal Data

2.1 Personal Data that We Collect

Builda collects information for more efficient operations and provides you with the best product experience. We collect Personal Data in a few different ways including: (1) information directly provided by you; (2) data recorded by us about how you interact with our products; (3) data from Third Parties.

2.1.1 Information you provide to us

When you use Builda’s Services, you voluntarily share certain information.

  • Account and login information: you can create an account and sign in using an email verification code or your Google account, where offered. We use your email address as your account identifier and process the verification result, account identifier and login records. If the email associated with your Google sign-in is the same as the email you enter, we may recognize them as a single Website account after appropriate verification.
  • Basic information: such as your name, email address, country or region, and preferred language, as provided by you or generated through your use of the Website.
  • Profile data and saved settings: a username or display name, profile picture, and other optional information you choose to add through the account fields made available on the Website. You may also save a default shipping address and, where offered, a payment method; we process the saved address and the limited payment-method details or reference made available by the payment processor to support those choices.
  • Payment and Transaction data: when you order customized physical products or purchase any other paid Services we offer, you provide payment information to our third-party payment processor (such as Stripe). This typically includes your name, billing address, and payment card or payment account details. Our third-party payment processor receives and processes your payment information directly; we typically receive and may store limited billing information—such as card brand, the last four digits of your card, card expiration date, transaction identifier, payment and refund status, and transaction history—to provide customer support and manage your account. We do not directly store your full payment card number. We collect and store your purchase and order history and, if subscriptions, points, credits or recharge features are offered in the future, the related plan, balance and transaction records as described when those features are offered.
  • Order and delivery information: when you order a customized physical product from Builda, we collect the information needed to produce and deliver it, including the recipient’s name, shipping address, postal code, contact phone number, and country/region, together with your order details, selected product form and specifications, quantity, shipping option, and production, delivery and tracking status. At checkout you confirm an email address for production, shipping, delivery and refund updates; it may differ from your account email address. If you place an order on behalf of another person, you confirm that you have obtained their consent to provide their information to us.
  • Referral information / inviting friends: if we offer a referral feature and you invite a friend to the Services (for example, through a referral feature), we collect the information you provide about your friend, such as their email address. By providing this information, you confirm that you have your friend’s consent to share their details with us for this purpose. We use this information to send the invitation and, where applicable, to administer and track our referral program.
  • Your communications with us: if you contact us through the Services or social media (including through our third-party support channel, including Discord) for customer support, provide feedback, or otherwise communicate with us, we collect the content of these communications. Discord is a separate third-party service, and information you provide there is also subject to Discord’s privacy practices.
  • User-generated content data: the supported 2D artwork and related project or product information you provide (the “Inputs”), the AI-driven 2D images and 3D previews you generate (the “Outputs”), and other content you upload or submit through the Services, including your generation history, project or series names, selected product forms and specifications, links between creations and orders, and associated metadata. Metadata includes information on how, when, where and by whom content was collected, and how that content has been formatted or edited. My Builda displays your ordered and unordered creations and associated orders within your account. We do not actively solicit or intend to collect Sensitive Personal Data as part of your Inputs. You should avoid including such information and must have any necessary rights or permissions before submitting another person’s Personal Data.
  • Marketing data: such as your preferences for receiving our marketing communications and details about your engagement with them. We record your marketing-email preference and changes to it. Marketing messages are sent to your account email subject to your choices and applicable law; necessary account and order messages may still be sent. If you use a promotion code, we process the code, eligibility, discount, use limits and associated order information to apply the offer and prevent misuse.
  • Creator and artist information (where applicable): if, in the future, you take part in any creator or artist program we make available, or you enter into a separate agreement with us, we may collect additional information from you in connection with that program or agreement—for example, information needed to set up and administer your participation and, where you are eligible to receive payments, to process payments to you and comply with applicable tax and legal requirements. The specific information we collect for these purposes will be as described in the applicable program terms or separate agreement.

Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

2.1.2 Technical information when you use and interface with our Services

When you use a website or other internet service, certain internet and electronic network activity information gets created and logged automatically via event tracking and other technical methods, which is adopted for device performance detecting, user behavior analysis and subsequent product optimization. This is also true when you use Builda. Here are some of the types of information we collect:

  • Device information: we collect information about the device you use to access our Services, including the type of device, operating system, network service provider, settings, and unique device identifiers.
  • Log data: when you use our Services, our servers record information, including information that your browser automatically sends whenever you visit a website. This log data includes, for example, your Internet Protocol (IP) address, activity on the Website and on websites that incorporate Builda features, browser type and settings, and the date and time of when you accessed the Services.
  • Cookies and similar technologies: some of our automatic data collection is facilitated by cookies and similar technologies. We will also store a record of your preferences in respect of the use of these technologies in connection with the Services.
  • Usage data and inferences: when you use our Services, we use your activity—such as the pages, product forms and previews you view, generation and checkout steps, orders, and selections or preferences you enter—along with other information you provide and, where applicable, information from our partners and advertisers, to understand your use of the Services and make inferences about your preferences. We may infer an approximate location from your IP address to suggest a language or currency and support Website operations; the current workflow does not request precise GPS location.
  • User Choices: We will keep a record of choices you’ve selected in your settings.

2.1.3 Third Parties (such as our partners and advertisers) share information with us

We also receive information about you and your activity outside Builda from our affiliates, advertisers, partners and other third parties we work with. For example:

  • Google sign-in: when you register or log in using Google, Google provides information you authorize, such as your email address, name, profile picture and account identifier, to facilitate your account creation or login with us. The information received depends on the permissions you grant and Google’s applicable terms and policies.
  • Payment processors: our third-party payment processor (such as Stripe), may provide us with information related to your payment status or transaction confirmations, refund and dispute status, and limited payment-method details.
  • Technical service partners: We sometimes receive information about you from technical service partners. Production and logistics partners may also provide production, shipping, delivery and tracking information for your orders.
  • Advertisers or other partners: Where we use advertising or measurement tools, online advertisers or third parties may share information with us about you to measure, report on or improve the performance of ads on Builda, or to help us better understand what kinds of ads to show you on Builda. This may include information about how you interacted with our advertisements or referral links before or around the time you first visit the Website or create an account, which we and our attribution and measurement partners use to attribute visits, conversions and referrals to their advertising, campaign or referral source and to measure the performance of our marketing and user-acquisition campaigns.

2.2 How We Use your Personal Data

We process your Personal Data for purposes described in the Privacy Policy on the legal bases applicable to the processing, including consent where required and our legitimate interests. We also process your Personal Data pursuant to legal obligations imposed on us or to perform contracts between Builda and you such as the Terms of Use. Builda will strictly comply with the Privacy Policy and its updates to use your Personal Data. If your Personal Data is used for other purposes that are not stipulated in the Privacy Policy, we will additionally obtain your specific consent or other legal basis. Examples of our processing activities are as follows:

2.2.1 Service Delivery and Maintenance

We’re committed to showing you content that’s relevant, interesting and personal to you. To do that, we may use your Personal Data to:

  • Identify you when you use our Services;
  • Manage your registration as a user of the Services (via email verification or Google sign-in, where offered). The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user;
  • Provide the AI 2D/3D content-generation features and give you access to and management of your generation history (Inputs and Outputs), including ordered and unordered creations and associated orders in My Builda, with project naming and deletion where offered;
  • Process your orders, payments and promotion codes, calculate estimated and final prices, and produce, fulfill and ship customized physical products to you; and, if we offer subscriptions, points, credits or recharges in the future, administer those features in accordance with the terms and notices provided when they are offered;
  • Establish and maintain your user profile on the Service;
  • Provide, operate, maintain and improve the Services and our business;
  • Personalize the Services, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Services;
  • Administer promotions, discounts and any referral or creator programs we make available, subject to any additional terms or notices applicable to those programs;
  • Provide you with Service-related general information, announcements, news, updates, security alerts, and support and administrative messages, including verification codes to your account email and production, shipping, delivery and refund updates to the email confirmed for the relevant order;
  • Communicate with you about events, promotions and contests that may interest you or in which you participate, subject to the marketing-email choices described in Section 5;
  • Understand your needs and interests, and personalize your experience with the Services and our communications;
  • Provide customer support for our Services, and respond to and manage your requests, comments, questions and feedback.

2.2.2 Product & Services Improvement and Analytics

As part of our efforts to improve Services provided by Builda, we may use your Personal Data to analyze product usage condition so as to constantly create, develop, and analyze business operation efficiency, and include new features and functions. Specifically, we use the information we collect to:

  • Create aggregated, de-identified and/or anonymized data from Personal Data we collect. We make Personal Data into de-identified or anonymized data by taking measures so that it cannot reasonably be used to identify you or be linked to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with Third Parties for our lawful purposes of this Privacy Policy and our business, including to analyze and improve the Services and promote our business, and will not attempt to re-identify any such data; and
  • Analyze your usage of the Services so as to constantly create, develop and improve the Services, improve the rest of our business, include new features and functions, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Services, as well as user interactions with our emails, and to develop new products and services.
  • Based on our legitimate interests in operating, securing and improving the Services and our technology, and subject to applicable law, including consent where required, operate, develop, train and improve our own AI models, algorithms and related technology (including for labeling, classification, content moderation and model-training purposes) using data derived from your use of the Services, including Inputs and Outputs. We apply appropriate safeguards and, where feasible, endeavor to de-identify or aggregate such data before using it for these purposes. You can opt out of our use of your Inputs and Outputs to train and improve our models at any time by emailing us as described in Section 11, or through account settings where that option is offered, as further described in Section 5. Opting out applies to future training uses and does not, by itself, reverse training already completed. It does not limit any deletion or other rights you may have under applicable law.

2.2.3 Compliance and protection

We use your information in our efforts to keep our users and the public safe, and to protect legal interests. To do so, we may use your personal information to:

  • Review your activity and messages on our Services to detect spam or activity that poses a risk to users, our Services or the public. This can include working with law enforcement to keep Builda safe;
  • Analyze users’ log data and device information to identify and investigate suspicious behavior or violations of our policies or terms;
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • Access user information in relation to a legal claim, litigation, or regulatory proceeding;
  • Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • Enforce the terms and conditions that govern the service; and
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

2.2.4 Limits on Use of Your Google User Data

Notwithstanding anything else in this Privacy Policy, our use of information received through Google sign-in will adhere to the Google API Services User Data Policy, including the Limited Use requirements where applicable to the scopes accessed. We request information needed to authenticate you and create, secure and operate your account, rather than access to your Google emails, files or other unrelated content. The following restrictions apply where required by Google:

  • We will only use Google user data to perform the specific services that you request from us (for example, to authenticate you and create or access your Builda account), and we will not transfer the Google data to others unless doing so is necessary to perform such services, comply with applicable law, for security purposes, or as part of a merger, acquisition or sale of assets after obtaining any consent required by Google.
  • We will not allow humans to read the Google data unless doing so is necessary to perform the services or tasks that you’ve requested of our specialists or guides, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized. We will not use Google user data for advertising or to train general-purpose AI models where prohibited by Google’s applicable requirements.

2.3 How We Use Cookies and Similar Technologies

Using cookies can help you personalize your online experience. You can accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser's settings to reject cookies if you want. Information collected through cookies may be Personal Data when it identifies or can be linked to you, your browser, device or account. We provide notices and choices required by applicable law. We may use the Cookies and similar technologies described above for the following purposes:

  • Technical operation. To allow the technical operation of the Services, such as by remembering your selections and preferences as you navigate the site, your language or currency, checkout selections, and whether you are logged in when you visit account-restricted areas of the Service.
  • Functionality. To enhance the performance and functionality of our services.
  • Analytics. To help us understand user activity on the Services, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. Where we use advertising cookies, pixels or similar technologies, we may also use them for campaign attribution, audience measurement and the advertising purposes described in Section 4, subject to applicable choices and opt-out rights.

You can choose to enable or disable cookies in your Internet browser. Most Internet browsers also allow you to choose whether you want to disable all cookies or only third-party cookies. By default, most Internet browsers accept cookies, but this can be changed. For more information, please see the help menu in your Internet browser or the documentation that came with your device.

The following link provides instructions on how to manage cookies in the relevant browser:

If you use other browsers, please refer to the documentation provided by the browser manufacturer.

Please note that if you refuse to use, or clear existing cookies, you may need to change your user settings personally for each visit, and we may not be able to provide a better and quality experience to you or parts of our services may not function correctly.

3. How We Store Your Personal Data

We will strictly abide by our internal retention policy to store your Personal Data. We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, except a longer period required by applicable laws and regulations or your explicit consent. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will either remove the Personal Data exceeding the above retention period upon expiration from our systems or depersonalize it so that we can't use it to identify you.

Retention periods vary depending on the type of data and the purpose for which it is used. We keep your account and profile data for as long as your account remains active, and your Inputs, Outputs and generation history for as long as needed to provide the Services to you, including unordered 3D previews displayed in My Builda, unless you delete the relevant project or close your account earlier. Where you place orders for physical products or make payments, we retain the related order, transaction and tax records for the period required by applicable accounting, tax, anti-fraud and consumer-protection laws, even after your account is closed. Deleting a project or creation does not necessarily delete records associated with an accepted order. We may also retain certain data for a limited period as necessary to resolve disputes, enforce our agreements, or comply with our legal obligations. Where Personal Data is retained for model-training purposes, the necessity-based retention criteria above and your choices under Sections 2.2.2 and 5 also apply.

4. How and When We Share Your Personal Data

We may share your Personal Data with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection:

  • Service Providers, Third Party Vendors, Consultants, and other Business Partners: We may share your Personal Data with these parties in order to provide services on our behalf, monitor and analyze the use of our Services, or help us operate the Services or our business. These may include:
  1. Cloud hosting and storage providers (including providers located outside your country) that host and store data for the Services;
  2. Third-party payment processors that process your payments and transactions (currently Stripe) and, where you pay by card, the relevant card networks and your card-issuing bank, as needed to authorize and complete your transaction;
  3. Third-party AI model, tool and infrastructure providers that support or are integrated into the generation features. For example, when you use the Services to generate certain 2D images or 3D previews, your Inputs and related information may be processed by these third-party AI models, tools or providers in order to produce the Outputs you request. Where these providers process Personal Data on our behalf, we require them to process it for the agreed purposes and under contractual restrictions consistent with applicable law.
  4. Manufacturing, production, fulfillment and logistics partners (which may be located overseas) that produce and ship your customized physical products, together with international couriers and delivery partners;
  5. Customer support providers, including our third-party support channel;
  6. Email delivery and marketing service providers that help us send communications and administer our marketing.
  • Third Parties designated by you. We may share your Personal Data with Third Parties where you have instructed us or provided your consent to do so. For example, when you decide to link your Builda account to third party services, or when you choose to communicate with us through Discord or another external service, you direct disclosure of certain information to those services.
  • Business Partners and Professional advisors. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or Services, or whose products or Services may be of interest to you. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
  • Advertising Platforms and Marketing Partners: Where we use these tools, we may share limited Personal Data (such as device identifiers, hashed email addresses, or information about actions you take on our Services, like account registration) with advertising and marketing platforms (for example, Google and Meta) and with attribution, measurement and analytics providers to help us reach individuals who might be interested in our Services, to attribute Website visits, conversions and referrals to their advertising, campaign or referral source, to measure and improve the performance of our advertising and of our referral and user-acquisition campaigns, to personalize the content, recommendations and ads you see, and to create custom audiences. You may have choices regarding this type of sharing through your settings on those third-party platforms, through our cookie controls (if applicable) or through the opt-out methods described in Section 5 and Annex 1. Any such processing is subject to applicable law and the choices you make.
  • Affiliates: We may share Personal Data with our corporate parent, subsidiaries and other affiliated companies for purposes consistent with this Privacy Policy and for legitimate business operations. For example, certain features or parts of the Services may be provided or supported by our affiliates; in those cases, we require them to protect your Personal Data in accordance with data protection standards consistent with this Privacy Policy.
  • Law Enforcement Agencies, Government Agencies, Researchers, or Other Parties in Compliance with Laws, Rules, or Regulations. For example, we may get requests for account information from law enforcement authorities like the police or courts. We only disclose information in response to such requests if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Builda; or to detect, prevent, or otherwise address fraud, security or technical issues. We may also share information if we believe it is necessary to prevent imminent and serious bodily harm to a person in emergency situations.
  • Business Transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Builda, financing of Builda, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Builda as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
  • Aggregated or De-identified Data: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with Third Parties for research, marketing, analytics or other purposes.
  • Other users and the public. Your My Builda creations, profile and order history are not currently made publicly visible through a community or ratings feature. If we feature your artwork, preview or product in a public showcase, we will obtain any authorization required by applicable law. If public features are offered in the future and you choose to publish content, the applicable terms and notices will describe the disclosure. Once information is made public at your direction, it may be seen, collected, cached, copied, screen captured or stored by others, including search engines, and we are not responsible for their use except as required by applicable law. You should not make public any information you wish to keep private.

We make commercially reasonable efforts to verify that the parties with whom the Website shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

5. Your Rights and Choices

We offer you certain choices to control your data. Depending on where you live, these choices may also be privacy rights under local law. The rights below apply to the extent provided by applicable law and subject to the relevant conditions and exceptions. To exercise a right, use any relevant account controls we make available or contact us using the email addresses in Section 11. We may request information reasonably needed to verify your identity before acting, where permitted or required by law.

  • Right to Know: We publish the Privacy Policy to inform you of how we handle your Personal Data. We are committed to the transparency of the use of your Personal Data.
  • Access Right: You are entitled to exercise your access right to access your Personal Data.
  • Opt-out of Communications: You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, through Email Preferences where available, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
  • Opt-out of AI model training: you may opt out of our use of your Inputs and Outputs to train and improve our own AI models at any time by emailing us as described in Section 11, or through account settings where that option is offered. Opting out applies to future training uses and does not, by itself, reverse training already completed. It does not limit any deletion or other rights you may have under applicable law. This choice does not prevent processing needed to generate the content you request, fulfill your orders or maintain security. It is separate from your marketing-email preferences and the sale, sharing or targeted-advertising choices described in Annex 1.
  • Right of Rectification: If you find there is a mistake with your Personal Data we process, you are entitled to ask us to make rectifications. When your identity is confirmed, we will rectify accordingly.
  • Right to Delete: you may make a request to us to delete your Personal Data under the following circumstances:
  1. Our processing of your Personal Data violates the applicable laws or regulations;
  2. We collect or use your Personal Data without your prior consent where consent is required by applicable law;
  3. Our processing of your Personal Data violates the agreement with you;
  4. You stop using our products or services;
  5. We no longer provide you with products or services;
  6. Other circumstances stipulated by the laws and regulations.
  • Delete your content or close your account: you may delete a project or series through My Builda where that function is offered, or request closure of your account by contacting us. Deletion or account closure may remove active creations, including unordered previews, but does not require deletion of order, transaction, tax, security or other records that we may retain as described in Section 3 and permitted by applicable law.
  • Right to Restrict Processing: You are entitled to request Builda to restrict processing of your Personal Data under the following circumstances:
  1. You contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of the Personal Data;
  2. The processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of their use instead;
  3. We no longer need your Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  4. You have objected to processing, pending the verification whether the legitimate grounds of us override those of you.

This means we can store your Personal Data but will restrict other processing as required by applicable law, subject to any permitted exceptions.

  • Right of Data Portability: To the extent permitted by laws and regulations, you are entitled to obtain your Personal Data in a structured, commonly used, and machine readable format. For instance, if you decide to change the service provider, this right enables you to reliably and safely move, copy or easily transfer your Personal Data between IT systems without affecting its use.
  • Right of Refusal: To the extent permitted by the applicable laws and regulations, you have right to refuse our processing for these purposes.
  • Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
  • Linked third-party platforms. If you choose to connect to the Service through a third-party platform like Google, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
  • Right to Withdraw Consent: If you agree to our processing of your Personal Data but later change your mind, you can withdraw your consent at any time and we will stop processing based on that consent where required by law. Withdrawal does not affect the lawfulness of earlier processing or processing permitted on another legal basis.
  • Right to Refuse Automated Decision: Where applicable law provides such a right, you may object to or opt out of automated decisions or profiling. If these decisions will significantly affect your legitimate rights, you can refuse to be subject to automated decisions. We will respond to your request and take appropriate measures when necessary.
  • Right to Complaint: You are entitled to file a complaint with the data protection authority of your country about our processing of your Personal Data.

6. Security

The security of your Personal Data is important to us. We have taken safeguarding measures in accordance with industry standards to protect the Personal Data you provided and prevent data from unauthorized access, public disclosure, use, modification, damage or loss.

With regard to the security control of data access and use, we have implemented a strict data authorization control mechanism, adopted multiple identity authentication technology, and monitored the processing of your personal information to prevent illegal access and unauthorized use of data. We also monitor the entire lifecycle of data to protect your personal information from unauthorized access, public disclosure, use, modification, and intentional or accidental damage or loss, etc. We employ encryption for data in transit and at rest where appropriate, and we conduct regular security assessments and updates to our security practices, in accordance with industry standards and applicable laws.

The security of your Personal Data also depends on you. Your account is accessed through email verification or Google sign-in, where offered, and you are responsible for maintaining the security of your email and any linked Google account and for any activities that occur under your account. We recommend that you access the Services only in secure environments, use strong authentication, and sign out after use. If you believe the security of your account or Personal Data has been compromised, please contact us immediately using an email address in Section 11.

However, please be aware, even if we undertake reasonable measures to protect your data, there is no website, internet transmission, computer system or wireless connection that is completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In case of Personal Data security incident where it is likely to result in a high risk to the rights and freedoms of you, we shall communicate the Personal Data breach to you in accordance with the requirements of laws and regulations such as basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc.

We will inform you in a timely manner by email, mail, telephone, notices on the Website, etc., regarding the relevant situations of the incident. When it is difficult to notify each Personal Data subject individually, we will issue a notice in a reasonable and effective manner. In the meantime, we will take the initiative to report on the handling of Personal Data security incident in accordance with regulatory department’s requirements.

7. How We Transfer Your Personal Data Globally

Builda is a worldwide service, and cross-border transfer and storage of your Personal Data is an inevitable part of providing the Services. We may transfer and store your Personal Data outside your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction, for the purposes described in this Privacy Policy. Your Personal Data may be stored and processed in countries other than the one in which you are located, including countries where our group companies, our service providers, and our production and logistics partners operate. Where applicable law requires consent, contractual safeguards or another transfer mechanism, we will comply with those requirements.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Our Policy on Children’s Data

Our services are not designed to target children, and therefore, we do not intentionally collect any data pertaining to children. We do not knowingly gather personally identifiable information from any children as defined by applicable laws. The Website is not directed to children under thirteen (13).

If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us immediately. We take the privacy and protection of children's data very seriously. Should we become aware that we have inadvertently collected Personal Data from any child without obtaining verifiable parental consent, we will promptly take all necessary steps to remove such information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

9. Other Sites and Services

The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use. This includes external services such as Google sign-in, Stripe and the official Discord community or support channels linked from the Website.

10. How We Make Changes to This Policy

We may change this Privacy Policy from time to time and if we do, we’ll post any changes on this page and update the “Last updated” date at the top of this Privacy Policy. If the changes are significant, we may provide a more prominent notice, such as by sending you an email. We will provide any additional notice or obtain consent required by applicable law before a change takes effect.

You are advised to review this Privacy Policy periodically for any changes. If you continue to use Builda after those changes are in effect, the new policy applies to you.

11. Contact Us

If you have any concerns or doubts over our Privacy Policy or our practices, please contact us via the following channels: The data controller responsible for your Personal Data is Oceano HK Holding Limited.

  1. using the official Discord community or support link displayed on the Website for general assistance; or
  2. sending an email to legal@mathmagical.com or support@builda.work for privacy questions, rights requests or other assistance.

We normally aim to review and process your request within thirty (30) days of receipt, subject to any necessary identity verification, and will in all cases respond within the period required by applicable law. If an extension or refusal is permitted, we will notify you and explain the reasons within the applicable deadline.

Annex 1 – Privacy Notice for U.S. State Residents

This Annex provides additional privacy disclosures and rights and supplements the rest of this Privacy Policy. It applies to residents of U.S. states with comprehensive privacy laws to the extent the relevant law applies to our processing. If there is any conflict between this Annex and the rest of this Privacy Policy with respect to such residents, this Annex controls.

  • Part 1 applies to residents of California.
  • Part 2 applies to residents of other U.S. states with applicable comprehensive privacy laws.

Part 1 – California Residents

This Statement applies to California residents to the extent the California Consumer Privacy Act of 2018, as amended (“CCPA”), applies to our processing. Terms defined in the CCPA have the same meaning here. The categories below summarize the Personal Data collected and disclosed through the Website as described in Sections 2 and 4. The categories of sources, processing purposes, recipients and retention periods are described in Sections 2, 3 and 4; the same descriptions apply to the preceding twelve (12) months to the extent the Website has operated during that period.

  1. INFORMATION WE COLLECT
Category of Personal Data under the CCPACollected?Disclosed?
A. Identifiers such as name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.YesYes
B. Customer-record information, such as name, billing and delivery contact details, and limited payment information.YesYes
C. Characteristics of protected classifications under California or federal law, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Not routinely requested; may be included in content or communications you choose to provideWhere applicable under Section 4
D. Commercial information, such as transaction information, purchase history, financial details, and payment information.YesYes
E. Biometric information used for identification, such as fingerprints and voiceprints.NoNo
F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.YesYes
G. Approximate location inferred from IP address, for example to suggest a language or currency. The current workflow does not request precise GPS location.YesYes, as described in Section 4
H. Visual information, such as artwork and optional profile images you upload, generated 2D images and 3D previews, and any images you include in communications with us.Yes, where provided or generatedYes
I. Professional or employment-related information, such as job title as well as employment record and working experience.NoNo
J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student profiles.NoNo
K. Inferences drawn from any of the Personal Data listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.YesYes
  1. YOUR ADDITIONAL RIGHTS AND CHOICES

The CCPA provides California residents with specific rights regarding their Personal Data, subject to applicable conditions and exceptions. These include rights to know and access, correct and delete Personal Data, opt out of sale or sharing, limit certain uses and disclosures of sensitive Personal Data, and be free from unlawful discrimination. You may submit requests using the email addresses in Section 11. Where permitted by law, an authorized agent may act on your behalf; we may require proof of authority and identity verification as applicable. You also have the following rights and choices:

  • Right to Know Information Regarding Participation in Data Sharing for Financial Incentives: If we offer a program that constitutes a financial incentive under the CCPA, we will provide the required notice and obtain your opt-in consent before enrollment. Participation is voluntary and you may withdraw as described in that notice.
  • Right to Opt Out of Sale or Sharing of Personal Data and Targeted Advertising: You have the right to opt out of the “sale” or “sharing” of your Personal Data and of the use of your Personal Data for cross-context behavioral (targeted) advertising. While we do not sell your Personal Data for monetary consideration, our sharing of certain identifiers and activity data with advertising platforms for the purposes described in this Privacy Policy may be considered a “sale” or “sharing” under applicable law. You may exercise this right through any applicable cookie and advertising controls or by emailing legal@mathmagical.com or support@builda.work, and we will process a recognized opt-out preference signal, such as Global Privacy Control, as required by applicable law and treat it as a valid request to opt out for that browser or device, and for an account where required. You do not need to create an account or verify your identity to submit an opt-out request, although we may request information necessary to apply it. We do not knowingly sell or share Personal Data of consumers under sixteen (16) without the affirmative authorization required by the CCPA. Your right to opt out does not apply to our sharing of Personal Data with service providers who are contractually obligated to use it only on our behalf.
  • Right to Limit Use and Disclosure of Sensitive Personal Data: Where the CCPA provides this right, you may request that we limit the use and disclosure of your Sensitive Personal Data by emailing us as described in Section 11 or through any applicable privacy controls we make available.
  • Right to be Free from Discrimination: You may always exercise all rights and we will not unlawfully discriminate against you for exercising your rights under the CCPA.
  • “Shine the Light” Law: Residents of the State of California also have the right to request information regarding Third Parties to whom Builda has disclosed certain categories of Personal Data during the preceding year for the Third Parties' direct marketing purposes. If you are a California resident and you wish to make such a request, please send us an email at legal@mathmagical.com.

Part 2 – Residents of Other U.S. States with Applicable Privacy Laws

This Statement applies to residents of other U.S. states with applicable comprehensive privacy laws. Terms defined in the relevant state law have the same meaning here, and each right applies only to the extent, and subject to the conditions and exceptions, provided by the law of your state of residence.

  • Right to Access and Know: you may request to confirm whether we are processing your Personal Data and to access that data.
  • Right to Correct: you may request that we correct inaccuracies in your Personal Data, taking into account its nature and the purposes of processing where provided by applicable law.
  • Right to Delete: you may request that we delete Personal Data that you provided or that we obtained about you, subject to certain exceptions.
  • Right to Data Portability: you may request a copy of the Personal Data you previously provided in a portable and, to the extent technically feasible, readily usable format.
  • Right to Opt-Out: you may opt out of the processing of your Personal Data for (i) targeted advertising, (ii) the sale of Personal Data, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Right to Appeal: if we decline to act on your request and applicable law provides an appeal right, you may appeal our decision by contacting us at legal@mathmagical.com or support@builda.work within a reasonable time after our decision.

To exercise any of these rights, please use any relevant account controls we make available or email legal@mathmagical.com or support@builda.work. We will not discriminate against you for exercising your rights. We may need to verify your identity before responding, and we will respond within the time period required by applicable law.

Questions about this policy? support@builda.work