Looktech (“Looktech,” “we,” “our,” or “us”) respects your privacy and is committed to being fair, accountable, and transparent about how we handle personal information. This Privacy Policy describes how we collect, use, and disclose personal information when you use our websites, applications, AI-powered glasses, and related services (collectively, the “Services”). It also explains your privacy rights and choices.This Privacy Policy does not apply to (i) data we process on behalf of business customers under separate agreements, or (ii) employment-related personal information. If you access our Services through a third party’s product or platform, that third party’s privacy policy may govern your use there.We provide conversational AI experiences through Memo AI, our assistant that can interact via text, voice, and other supported modes. “Content” means inputs you provide to the Services (for example text, files, images, or audio). “Output” means responses generated by the Services based on your Content.

Personal Data we collect

We collect personal data relating to you (“Personal Data”) as follows:

Personal Data You Provide

• Account Information. If you create an account, we collect information associated with your account, including your name, contact information, and account credentials (“Account Information”).
• User Content. We collect Personal Data you provide in the input to our Services (“Content”), including prompts and other content you upload or capture via the app or glasses, such as files, images, and audio, depending on the features you use.
• Communication Information. If you communicate with us (e.g., email, support tickets, or our pages on social platforms), we collect your name, contact information, and the contents of your messages (“Communication Information”).
• Orders, Shipping, and Prescription Information. To fulfill purchases and provide support, we collect shipping address, contact details, order and warranty/returns information, and—where you choose to provide it—prescription details (e.g., lens power, pupillary distance, astigmatism) solely to customize and deliver your eyewear order.
• Other Information You Provide. We collect other information you may provide to us, such as participation in events or surveys, or information used to help establish your identity or age (“Other Information You Provide”).

Personal Data We Receive from Your Use of the Services

• Log Data. Information your browser, app, or device automatically sends when you use the Services, such as IP address, browser/app type and settings, date and time of your request, and how you interact with the Services.
• Usage Data. Information about your use of the Services and device features (e.g., pairing, connectivity, voice interactions, media capture/import, find-my-glasses), including features used, actions taken, time zone, country/region, dates and times of access, user agent and version.
• Device Information. Information about the device(s) you use to access the Services, such as device name/model, operating system and version, app version, device identifiers, and where applicable your glasses hardware/firmware version.
• Location and Sensor Information. We may determine general location from IP address for security and product experience. Some features allow you to choose to provide more precise location from your device (e.g., GPS). Where you enable it, we may also process limited device or glasses sensor data (e.g., Bluetooth proximity, accelerometer/gyroscope) to support pairing, connectivity, geotagging, find-my-glasses, and safety. You can disable related permissions in your app settings.
• Cookies and Similar Technologies. We use cookies and similar technologies to operate and administer the Services and improve your experience. If you use the Services without creating an account, we may store some of the information described in this Policy with cookies or mobile SDKs to maintain your preferences across sessions.
• Wake-word. If you enable a wake-word (e.g., “Hey Memo”), detection runs on your device. Audio is not uploaded until activation is detected, and you can disable the wake-word at any time in app settings.

How We Use Personal Data

We use Personal Data only to operate, secure, and improve the Services:

• Provide and operate the Services. Create and manage accounts, authenticate users, deliver core features (including text and voice interactions with Memo AI and default audio playback), maintain continuity and history you choose to keep, process purchases, and fulfill orders and support.
• Personalize your experience. Apply your settings and preferences to tailor responses and features you enable. You can adjust personalization in settings.
• Support and troubleshooting. Diagnose issues, answer requests, and improve reliability and accessibility.
• Safety and integrity. Detect, prevent, and respond to fraud, abuse, spam, security incidents, and violations of our terms; protect users, the Services, and the public.
• Service improvement and research. Analyze usage patterns and quality signals to improve performance, features, and usability. Where feasible we use aggregated or de-identified data.
• Communications. Send service and transactional messages (e.g., changes to features or terms, purchase receipts, security alerts). Where applicable, you may control non-essential communications in settings.
• Legal and compliance. Meet legal, regulatory, tax, and auditing requirements; enforce terms; protect rights, privacy, safety, and property.

Model training stance. We do not allow any third party to use your Content to train their models. We do not use your Content to train Looktech models unless we later present a clear opt-in and you agree; you can withdraw such consent at any time.De-identified data. We may aggregate or de-identify data so it no longer reasonably identifies you and use it for the purposes above. We will keep such data in de-identified form, will not attempt to re-identify it, and will not disclose de-identified datasets externally in a form reasonably likely to be re-identified.No sale or targeted ads. We do not sell Personal Data or share it for cross-context behavioral advertising.

How We Disclose Personal Data

We disclose Personal Data only as described below and with safeguards.

• Service providers (processors). We share data with vendors that host, operate, secure, support, or analyze the Services; process payments and logistics; provide customer support; and enable quality and safety review. They act on our instructions, must protect the data, and may not use your Content to train their models. Where available, we set vendor retention/logging to the minimum necessary.
• Features you choose that connect to others. If you use options that let you share Content or Output outside Looktech (e.g., exporting a conversation, sharing a link, or connecting an account), those recipients and services receive the data you choose to send and their terms apply.
• Community and social channels. If you post or interact on our pages or forums hosted by third parties, the information you provide there is visible as configured on those platforms and governed by their policies.
• Affiliates. We may disclose Personal Data to our corporate affiliates for purposes consistent with this Policy (for example, hosting, security, support, or accounting).
• Legal, safety, and rights protection. We may disclose data when we believe it is necessary to: comply with law or legal process; respond to valid requests from authorities; enforce our terms and policies; detect, prevent, or address fraud, abuse, or security issues; protect users, the Services, our rights and property, or the public. Where legally permitted and feasible, we notify affected users.
• Corporate transactions. In connection with a merger, acquisition, financing, reorganization, insolvency, or sale of assets, Personal Data may be disclosed under confidentiality and transferred as part of the transaction. If required by law, we will provide notice of any material changes in how the data is handled.
• With your direction or consent. We disclose data to third parties when you ask us to.
• De-identified/aggregated insights. We may share insights derived from de-identified or aggregated data that do not reasonably identify you. We will not attempt to re-identify such data.

Data Retention and Deletion

We keep Personal Data only as long as needed to provide the Services or for other legitimate purposes such as safety and security, resolving disputes, or meeting legal obligations. How long we retain data depends on factors like:

• the purpose for which we collected it and whether we still need it to operate the feature,
• the amount, nature, and sensitivity of the data,
• the risk of harm from unauthorized use or disclosure,
• legal, regulatory, tax, accounting, or security requirements, and
• your settings and choices (for example, whether you keep or delete conversation history).

If you delete Content, conversations, or your account, we delete associated data from active systems within a reasonable period (typically within 30 days), unless we need to retain it for safety, compliance, or legal hold. Backups are removed on a rolling schedule and may persist for a limited period after active deletion. Short-lived technical artifacts used for reliability and safety are minimized by design and removed once no longer necessary.We may retain de-identified or aggregated data that does not reasonably identify you for the purposes described in this Policy.

Your Rights and Choices

Subject to applicable law, you may have the right to:

• Access your Personal Data and information about how we process it.
• Delete your Personal Data from our records.
• Correct/Update inaccurate Personal Data.
• Port your Personal Data in a portable format.
• Restrict or object to certain processing, including personalization you control in settings.
• Withdraw consent where processing relies on consent, without affecting prior lawful processing.
• Appeal a decision on a rights request.

How to exercise your rights. Contact us at customer@looktech.ai. We will verify your request to protect your account and data (for example, by asking you to log in or provide information that matches what we have on file). Where permitted, you may use an authorized agent; we may require proof of authorization and identity verification.

• History and personalization. You control whether to keep or delete conversation history and can adjust personalization settings.
• Voice activation. You can enable/disable wake-word detection in settings.
• Permissions. You can change location and sensor permissions in your device or app settings.
• Communications. You can manage non-essential communications in settings or by using unsubscribe links.

Security of Personal Data

We implement commercially reasonable technical, administrative, and organizational measures designed to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These measures include encrypted transmission (TLS/HTTPS), least-privilege and role-based access controls, credential and key management, monitoring and logging, regular reviews and testing, employee privacy/security training, and incident response procedures. No Internet or email transmission is ever fully secure, so you should take care with what you share and protect your account credentials.

Children Under 13

The Services are not directed to, or intended for, children under 13. We do not knowingly collect Personal Data from children under 13. If you believe a child under 13 provided Personal Data to us, contact customer@looktech.ai and we will take appropriate steps to remove it. Users under 18 should have permission from a parent or guardian to use the Services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version and effective date. If changes are material, we will provide a clearer notice (for example, in-app or via email) before they take effect. Your continued use of the Services after the effective date means you accept the updated Policy where permitted by law.

How to Contact Us

If you have questions, requests, or complaints about this Policy or our handling of Personal Data—or if you wish to exercise your privacy rights, contact:

Email:customer@looktech.ai

Postal: Looktech, 17800 Castleton St Ste 665, City of Industry, CA 91748, United States

Effective date: October 8, 2025