California Privacy Notice

Last Updated: December 20, 2025

This California Privacy Notice (“Notice”) applies solely to individuals who reside in the State of California (“consumers” or “you”) and supplements the information contained in our Privacy Policy. This Notice describes how we collect, use, disclose, and retain personal information of California residents and the rights that may be available under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”).

1. Personal Information We Collect

We may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.

In the preceding 12 months, we may have collected the following categories of personal information:

Identifiers, such as name, email address, phone number, account credentials, IP address, and other similar identifiers.
Personal information described in California Civil Code section 1798.80(e), such as contact information and information you submit in connection with our services.
Internet or other electronic network activity information, such as browsing activity, app usage, interactions with our website or service, device information, and similar usage data.
Commercial information, such as information about your interest in products or services, treatment preferences, or transaction-related interactions.
Professional or employment-related information, such as information relating to providers, practices, or other business contacts where relevant to our services.
Sensitive personal information, such as account login information, precise information contained in user-submitted photos or videos, and other information that may be considered sensitive under California law, depending on the context in which it is collected and used.
Inferences, such as information derived from your interactions with our services in order to personalize features, recommendations, or user experience.

2. Sources of Personal Information

We may collect personal information from the following categories of sources:

Directly from you
Automatically from your device, browser, or interactions with our website or services
From service providers that support our operations
From healthcare providers, aesthetic providers, or business partners where you direct or authorize such sharing
From publicly available or legally obtained sources, where relevant

3. Purposes for Collecting, Using, and Disclosing Personal Information

We may collect, use, and disclose personal information for the following business or commercial purposes:

To provide, operate, maintain, and support our services
To process facial photos, videos, and related inputs in order to generate analysis outputs, recommendations, and related service features
To communicate with you, including customer service and service-related communications
To personalize and improve our services, features, performance, and user experience
To conduct analytics, quality assurance, debugging, troubleshooting, and internal research
To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity
To comply with legal obligations, enforce our terms, and protect our rights and the rights of others
To create, use, and retain de-identified and aggregated information for analytics, product development, service improvement, and model improvement, where permitted by applicable law

4. Disclosure of Personal Information

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

Service providers and contractors that help us host, operate, secure, support, analyze, or improve our services
Infrastructure, cloud, database, communications, analytics, and form-processing providers
Professional advisors, such as legal, accounting, and compliance advisors
Governmental entities, regulators, law enforcement, or other third parties where required by law or to protect rights and safety
Healthcare providers, aesthetic providers, or business partners where necessary to provide the services you request or where you direct us to do so

5. Sale or Sharing of Personal Information

We do not sell or share personal information as those terms are defined under California law.

6. Sensitive Personal Information

We may collect sensitive personal information as described above. We use sensitive personal information only for purposes permitted by California law, including providing the requested services, maintaining security, preventing fraud, performing services on our behalf, and other permitted operational purposes. Because we use sensitive personal information only for purposes permitted by California law, we do not offer a separate right to limit the use or disclosure of sensitive personal information at this time.

7. Retention of Personal Information

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, provide the requested services, maintain appropriate business and security records, comply with legal obligations, resolve disputes, and enforce our agreements.

The criteria we use to determine retention periods include:

The nature and sensitivity of the information
The purpose for which the information was collected and whether that purpose remains ongoing
Operational and business needs
Legal, regulatory, tax, accounting, security, fraud-prevention, and compliance obligations
Whether deletion, anonymization, or de-identification is feasible and appropriate

We may retain de-identified and aggregated information for longer periods or indefinitely where permitted by applicable law.

8. Rights of California Residents

Subject to applicable law and verification, California residents may have the following rights:

Right to Know/Access: Request information about the categories of personal information we collected, the categories of sources, the business or commercial purposes for collection, the categories of third parties to whom we disclosed personal information, and the specific pieces of personal information we collected about you.
Right to Delete: Request deletion of personal information we collected from you, subject to certain exceptions.
Right to Correct: Request correction of inaccurate personal information that we maintain about you.
Right to Opt Out of Sale or Sharing: Request to opt out of the sale or sharing of your personal information, if applicable.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your rights under California law.

9. Exercising Your Rights

To exercise your California privacy rights, please contact us using one of the methods below:

Email: info@ponce.ai
Phone: 628-230-6521

You may designate an authorized agent to make a request on your behalf, subject to our verification of the agent’s authority and your identity as required by law.

We may need to verify your identity before processing your request. We will respond to verifiable consumer requests in accordance with applicable law. If reasonably necessary, we may extend the response period as permitted by law. Requests to know/access may be limited as permitted by law.

10. Changes to This Notice

We may update this Notice from time to time in our discretion. When we make changes, we will post the updated Notice on our website and revise the “Last Updated” date above.

11. Contact Us

If you have any questions or comments about this Notice or our privacy practices, please contact us at:

Ponce AI, Inc.
2443 Fillmore St. #380-7054
San Francisco, CA 94115
Email: info@ponce.ai
Phone: 628-230-6521