Privacy Policy

Overview

Effective: January 1, 2026

This Privacy Policy (the "Privacy Policy") serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use the website (the "Site"), services, software, content, AI Functions, and all other products and services (all of the foregoing collectively, the "Services") owned, controlled or offered, directly or indirectly, by Flagship AI, Inc. dba Alta Daily (together with its subsidiaries and affiliates, "Alta", "we," "our" or "us"). The Privacy Policy is incorporated by reference into our Terms of Service, currently available at Terms & Conditions (the "Terms of Service"). Any terms used herein and not defined will have the meanings given to them in the Terms of Service. By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Service, that you are a resident of the United States, and that you are over 13 years of age. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

If you have any questions or suggestions concerning our privacy practices, please email us at legal@altadaily.com.

1. Information We Collect

Information You Provide To Us

When you use the Services or otherwise communicate with us, we collect information that you provide to us directly. For example, we collect information in the following circumstances: you (i) visit the Site, (ii) register for the Services or create an account or profile or accept the creation of an account or profile on your behalf (an "Account"), (iii) access the Services through social networking sites or third party services, (iv) subscribe to newsletters; (v) purchase a product or service on the Site; (vi) invite your friends to join the Services, "share" the Services on social networking sites or perform other similar actions; (vii) request technical support; (viii) otherwise use our online Services where personal information is required for such use and/or participation, and (ix) when you contact us via the Site or when you otherwise communicate with us. You can choose not to provide information that is requested of you by us; however, this may limit your ability to use or access the Services.

The information you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute personal information:

Information you provide in connection with creating an Account and using the Services (including name, phone number, email address, location, age, height, and body shape) and any other information you decide to provide;
Information you provide in connection with signing into your Alta account using Google or Apple, such as Google or Apple profile information (such as name and email address). Alta may access certain data from your Google or Apple account through the Google or Apple API Services, based on the permissions you grant.
Information you provide via email, through the "Contact" section on the Site or by using the contact details listed on various parts of the Site, including your name, phone number, and email address, reason for inquiry, and any other information you decide to provide;
Information you provide in order to subscribe to our newsletters and updates, including your email address and phone number, the topic for which you wish to receive updates, or any other information you decide to provide us with. You may always unsubscribe from these emails by following the included instructions;
Information you provide that is included in User Content (as defined in the Terms of Service) you upload or provide for use with the AI Functions (as defined below), and, since we have no direct relationship with any person other than you, you are responsible for making sure that you have the appropriate permission and legal basis for us to collect and process User Content;
Transaction and limited (non-PCI) payment data;
Information you provide by forwarding your emails to Alta to access and process shopping receipts; and
Any other information you may want to share with us, such as personal information related to recruitment / job applications.

Automatically Collected Information

Most of the data we collect in and through the Site and the Services is technical in nature and is collected and processed automatically through so-called application programming interfaces, software development kits, cookies and similar software-based technologies. Alone or in combination with other data, such automatically collected data may constitute personal information. The data we may collect by automated means may include, without limitation:

Device data: including, but not limited to, data on device advertising ID's and similar hardware qualifiers.
Usage data: including, but not limited to, search terms entered and pages viewed.
Network and internet information: including, but not limited to, URLs, Internet Protocol addresses, bounce rates, use of spoofing, active (TCP/IP) ports, number of sessions initiated, click streams, location information and network/Wi-Fi access points.
Information we collect on the use of the Site via cookies: please see the "How We Use Cookies and Other Technologies" section below for more information.

Information You Share on Third Party Websites or through Social Media Services

The Services may include links to third party websites and social media services where you will be able to purchase products, post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services.

How We Use Cookies and Other Technologies

Some of the features on the Site and the Services require the use of "cookies" - small text files that are stored on your device's hard drive – along with pixel tags, web beacons, clear GIFS and similar technologies as noted below ("Technologies"). We use cookies to automatically collect personal information through your use of the Services and to authenticate logins, measure which pages are being accessed and which features are most frequently used, among other uses. This enables us to continuously improve the Site to meet the needs of our visitors.

We and our service providers may also use "pixel tags," "web beacons," "clear GIFs," or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of users, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.

2. Use of Collected Information

We use the personal information for the following purposes: (i) to further our legitimate interests in providing the Services, (ii) to administer your use of the Services and any Accounts you may have with us, (iii) to personalize your experience, (iv) to provide to you Service announcements or inform you of new releases and features, (v) to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as newsletters, marketing or promotional materials, (vi) to perform tasks on behalf of and according to instructions of a third party, such as third party-service providers, (vii) to enforce our Terms of Service, (viii) to resolve any disputes between users of the Site or between such users and us, (ix) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (x) to further our legitimate interest in protecting our rights, property, or safety and the rights, property and safety of the Services, our users or the public, and (xi) to contact you to obtain feedback from you regarding the Site and the Services.

In addition to the purposes described above, we use personal information to (i) to further our legitimate interests in monitoring and analyzing the use of the Services and for the technical administration of the Site, (ii) improve the Site and the Services, (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and (iv) verify that users of the Services meet the criteria required to process their requests.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases may include performance of a contract, legitimate interest, consent, and/or compliance with legal obligations.

2A. AI Functions and Use of Your Personal Information for Personalization

Our Services include AI-powered features ("AI Functions") designed to provide you with personalized styling recommendations and other customized experiences. In order to deliver these features, our AI Functions process personal information you provide — including your style preferences, feedback, body measurements, uploaded photographs, and other User Content — to learn your personal preferences and improve the accuracy and relevance of recommendations made specifically to you.

When you interact with the AI Functions (for example, by rating recommendations, providing feedback, saving or dismissing suggestions, or otherwise engaging with the personalized features), that feedback is used to train and refine your personal AI model so that it can better understand and serve your individual style. This training is specific to your Account and is used to improve your personal experience with the Services. This includes the right for authorized Alta personnel to manually review feedback and annotate data for improved algorithmic accuracy, provide manual styling support when asked, and audit flagged content for prohibited and NSFW materials.

We may also use aggregated and/or de-identified data derived from user interactions with the AI Functions to improve the overall quality, accuracy, and functionality of the Services generally. Such data does not identify you personally and cannot reasonably be used to re-identify you.

You may discontinue providing feedback to the AI Functions at any time.

3. Third Parties We Share Personal Information With

We may disclose personal information to the following categories of third parties:

Service providers, such as web hosting and data storage service providers, AI and machine learning service providers, marketing service providers, and communications service providers that help us deliver and develop the Services;
Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Site and/or the Services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.
Third-party advertising partners may set Technologies on our Services to collect personal information regarding your activities and your device (e.g., IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this personal information (and similar information collected from other services) to tailor and deliver personalized ads to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising," "personalized advertising," or "targeted advertising." Some of the advertising Technologies we may use include:
- Meta Pixel. For more information about Meta's use of your personal information, please visit Meta's Privacy Policy.
Alta users, who may share personal information or interact with other users of the Services.

4. Links to Other Websites

We frequently make content or services from other websites available to you from links located on the Site. We may present links in a format that enables us to keep track of whether these links have been followed. In addition, you may opt to link your Account to your social media account or other accounts, such as Google or Apple, in accordance with your Account settings (which you may change at any time) and respective policies of these third parties. This Privacy Policy applies only to the Site and the Services. We do not exercise control over third party services or other websites that provide information, or links from within the Site or the Services. Your interactions with these third-party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on your computer's browser, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information that you submit, and the collection and use of such information and access of any third-party websites are subject to such third party's privacy policy. We encourage you to read the privacy policies and other terms of such third parties before using their services.

5. Do Not Track Signals and Similar Mechanisms

Some web browsers transmit "do-not-track" signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

6. SMS/Text Messaging

When you register for an Account and provide your phone number, you may receive SMS or text messages from Alta for the purpose of two-factor authentication ("2FA") and Account security verification. Message and data rates may apply. Message frequency varies based on your Account activity.

You may opt out of receiving SMS messages at any time by replying "STOP" to any message you receive from us. However, please be aware that if you opt out of SMS messages, you will no longer receive 2FA verification codes via text message, which may prevent you from logging into your Account or completing certain security-sensitive actions, which would make it difficult to authenticate your Account.

Phone numbers collected for SMS/2FA purposes are not shared with or sold to third parties or affiliates for marketing purposes.

7. Children's Personal Information

The Services are not directed to children under 13 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

8. Managing Your Privacy

We keep your data on your behalf and for your benefit. You can correct or terminate and delete your Account information by following the instructions on the Services (please see the Delete Account button in your Profile Settings), which you may also access for further assistance and questions regarding the Privacy Policy or for a copy of your Account data. Once data is permanently deleted, it cannot be recovered.

9. Your Rights

In accordance with applicable law, you may have the right to:

Request Access to or Portability of Your Personal Information;
Request Correction of Your Personal Information;
Request Deletion of Your Personal Information;
Request Restriction of or Object to Our Processing of Your Personal Information; and
Withdraw Your Consent to Our Processing of Your Personal Information. Please note that your withdrawal will take effect only for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of the rights described above, please contact us at legal@altadaily.com. We will process such requests in accordance with applicable laws.

If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe that our processing of your personal information violates applicable law.

10. International Transfers of Personal Information

Alta is based in the United States. As a result, personal information that we collect in and through the Services and on the Site may be transferred, processed and stored anywhere in the world, including but not limited to the United States and countries other than the country in which the personal information was initially collected and which may have data protection laws that are different from the laws where you live.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

11. Data Retention

We keep personal information related to your Account for as long as it is needed to fulfill the purposes for which it was collected, to provide our services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements; the amount, nature, and sensitivity of the personal information; certain risk factors; the purposes for which we process your personal information; and whether we can achieve those purposes through other means.

12. Changes to the Privacy Policy

We may update this Privacy Policy from time to time in our sole discretion. If we do, we'll let you know by posting the updated Privacy Policy on our website, and we may also send other communications.

13. Contact Us

If you have any concerns or questions about this Privacy Policy, please contact us at legal@altadaily.com.