Privacy Policy

This privacy notice for Doppel Inc. (“Company,” “we,” “us,” or “our”) describes how and why we might collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), such as when you:

• Visit our website at doppel.com or any website of ours that links to this privacy notice
• Use our products and services, including the Doppel iOS mobile application available through the Apple App Store
• Engage with us in other related ways, including sales, marketing, or events

For the purposes of this Privacy Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information does not include publicly available information, lawfully available information from federal, state, or local government records, or information that has been de-identified or aggregated in accordance with applicable law.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, contact us at [email protected].

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, use our deepfake demonstration tool, or otherwise contact us.

The personal information we collect may include:

• Identifiers, such as name, street address, email address, telephone number, online identifiers, IP address, and account identifiers.
• Account information, such as your login credentials, usernames and passwords, and other account registration and profile information.
• Geolocation information, such as an IP address that identifies your general location.
• Demographic information, such as your gender, age, and zip code.
• Commercial information, such as records of Services provided.
• Enterprise identifiers, such as internal user IDs, short identifiers, or similar identifiers provisioned by an organization or its administrators, which are used to associate accounts and support authentication, security, and abuse prevention.
• Content of Communications, including the content of your phone calls, texts, or emails, including your preferences for receiving communications from us.
• Photographs, images, audio recordings, video recordings and other media uploaded by customers for the purpose of utilizing the deepfake demonstration tool. This data category is only used when customers opt in to use the deepfake tool and is not required for standard platform use. We may also collect audiovisual information when you interact with our social media pages or voice recordings when you interact with the Services or contact customer support.
• Other information you provide to us, such as personal information you have posted in public forums, such as on social media pages or employment networking websites (e.g., LinkedIn).

Sensitive Personal Information

When necessary, with your consent or as otherwise permitted by applicable law, we may process sensitive information you provide to us such as:

• Driver’s license numbers or other government identifiers.
• Information provided in connection with potential third-party abuse (e.g., phishing emails).
• Biometric data, including facial geometry and voiceprint data derived from photographs and audio recordings you submit through our deepfake demonstration tool, processed for the purpose of generating synthetic media content. We collect this data only with your affirmative consent provided at the time of submission.

All personal information that you provide must be true, complete, and accurate.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services. While this information does not directly identify you, device and usage information such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information may indirectly identify you.

The information we collect includes, but is not limited to:

• Log and Usage Data (service-related diagnostic, usage, and performance information).
• Device Data (device and application identification numbers, hardware model, carrier/ISP, OS, system configuration).
• In connection with operating, securing, and protecting the Services, we may collect and process routing, addressing, and signaling information (such as device, network, or session identifiers) that is generated in the course of communications with the Services. This information is collected for service functionality, security, fraud prevention, abuse detection, diagnostics, and system integrity purposes, and not for the interception of communications content or for advertising or profiling purposes. By using the Services, you agree to the collection and use of such information as described in this notice.
• Cookies, pixels, beacons, tags, SDKs, and similar online tracking technologies. See the Section 2, “Cookies and Similar Online Tracking Technologies” below.

Additional Personal Information Collected from Job Applicants

• Professional or Employment information, such as your employer name, employee email, employee telephone number, employment history, job title, and regulatory licenses, registrations, or related statuses.
• Education information, including education history, education transcripts, level of education, and professional certifications or charters.
• Sensitive personal information, such as Social Security number, driver’s license, state identification card, or passport number; criminal history from a background check, and citizenship, immigration, or work authorization/employment eligibility status.
• Other personal information, including any other personal information provided during the job application process, such as details about the type of employment you are seeking; current or desired salary; criminal history provided in a background check; and information related to any assessments you may take as part of the applicant screening process or any information provided by professional references.

Inferences and Profiling

We may use any of the categories of personal information outlined above to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

2. COOKIES AND SIMILAR ONLINE TRACKING TECHNOLOGIES

We and our third-party service providers may use cookies, local storage, scripts, Software Development Kits, web beacons, pixels, and similar technologies in connection with our websites and, where applicable, our social media presence, to ensure that the Services operate correctly. These technologies are used to maintain functionality, enhance performance, and improve and personalize the user experience.

Such technologies may also be used to analyze how the Services are accessed and used, including to measure aggregate metrics such as visitor counts, traffic patterns, usage trends, and general demographic information. Where permitted by applicable law and subject to user choices, these technologies may support the delivery of customized content. We may also work with service providers that use cookies to collect information about your visits to the Services and to other websites you may visit, and to serve advertisements to you across the Internet based on that information.

How long these cookies stay on your device depends on what they need to do. For example, some cookies only work while you are visiting our Services and get deleted when you're done (session cookies). Others may stay on your device unless you choose to delete them (persistent cookies). Cookies may be placed by us (first party cookies) or by other businesses (third party cookies) when you visit our Services or other online properties.

The cookies used on our Services can be classified using the International Chamber of Commerce guide for cookie categories: Strictly Necessary, Performance, Functional, and Targeting. We may use the following cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas of our Services or areas requiring your acknowledgment or consent to proceed.
• Analytical/performance cookies: These cookies from third-party services allow us to recognize and count the number of visitors and to see how visitors move around our Services when they are using them. This helps us improve the way our Services work, for example, by ensuring that users find what they are looking for easily.
• Functionality cookies: These are used to recognize you when you return to our Services. These enable us to personalize our content for you, greet you by name or remember your preferences (for example, your choice of language or region).
• Advertising/Targeting cookies: These cookies record your visit to our Services, the pages you have visited, the links you have followed, and your interaction with our advertising and marketing. We may use this information to make our Services more relevant to your interests. We may also share this information with third parties for this purpose.

Your Cookie Choices

• Advertising cookie opt-out: In the United States, you may opt-out of companies participating in the Digital Advertising Alliance (“DAA”) program by opting out at https://optout.aboutads.info, https://youronlinechoices.eu/, and https://youradchoices.ca/en/tools. For information and to download DAA’s AppChoices tool, see https://youradchoices.com/appchoices. Note that opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your preferences and usage patterns.
• Google Analytics: To help facilitate the delivery of relevant content, we use Google Analytics and have implemented all Google Advertising Features, including Remarketing, Impression Reporting, and Demographics, and Interest Reporting. Google Analytics uses cookies to report on user interactions on our and others' websites. We use the data collected for optimizing marketing, refining advertising and/or programming strategies, and generally making advertising more effective. Google provides a complete privacy policy here: http://www.google.com/intl/en/analytics/privacyoverview.html and instructions on opting out of Google Analytics using a specific plug-in available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt-out is specific to Google activities and does not affect the activities of other advertising networks or analytics providers that we may use.
• Meta Pixels: We use the Meta Pixel to analyze user activity on our Services for remarketing and behavioral targeting. The Meta Pixel is triggered when you perform certain activities on the Services and aids us in displaying ads to users who have visited our Services, or users who share certain characteristics with visitors to our Services. Meta may track your activity over time and across websites. For more information about the personal information Meta collects and choices you may have to control this personal information collection, please visit Meta’s privacy policy at: www.facebook.com/privacy/policy.
• Browser Signals: Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature. No uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT browser signals. We honor opt-out preference signals, such as the Global Privacy Control (“GPC”), as another way to opt out of the “sale” of your personal information or its “sharing” for targeted advertising purposes. More information on the GPC is available here. GPC only works on your browser ID, so please note that if you have an account with us, we can’t tell based on your browser ID as it is not linked to your account unless you contact us regarding any opt-out requests relating to your account.
• Browser Settings: You may be able to block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Check your browser’s HELP menu to learn the correct way to change or update your cookies. You can also visit www.aboutcookies.org, which contains more information on how to do this on many different browsers. Please see your mobile phone’s manual or other instructions for information on how to do this on your phone’s browser. Please note that if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our Services. Further information on popular browsers and their cookie management links is below.

“Sale” and “Sharing” of Personal Information; Targeted Advertising

We do not sell personal information for monetary consideration. We work with third-party advertising and analytics partners and social media sites, and these partnerships may be considered a “sale” or “sharing” under the California Consumer Privacy Act and similar U.S. state privacy laws, even though no money changes hands. For example, when you visit or interact with our public-facing website or internal pages where third-party cookies are present, the information collected by cookies may be considered a “sale” or “sharing” of your personal information. For information about how you may control the collection of your personal information via these tools, see Section 9, “Your Privacy Rights and Choices” below.

Our Use of Heatmap Technology

We may use heatmap technology to understand how users interact with our websites. These tools capture information such as mouse movements, clicks, scrolling, and page interactions, and may record the content of your interactions on sensitive portions of the Services. Information collected through these tools may be shared with the technology providers for product improvement purposes, which may constitute “sharing” under the California Consumer Privacy Act. You may opt out by using the GPC signal or our “Do Not Sell or Share My Personal Information” link.

Disclaimer Regarding Video Content

Our Services may contain video content, audiovisual content, or content of a like nature (collectively, “Video Content”). In connection with our provision of Video Content, our Services may utilize online tracking technologies and code-based tools, including, but not limited to, Software Development Kits (“SDKs”), pixels, and advertising and analytics cookies (collectively, “cookies”) that track information about your activity and webpage-viewing history on the website. Cookies on or used by the Services may result in information about your activity on our Services being transmitted from your browser to us and third parties, which, in turn, may result in the display of targeted advertisements on third-party websites, platforms, and services, including advertisements for our content. In addition, whether cookies on the Services result in your browser’s transmission of information to third parties depends on a number of factors that may be outside of our knowledge or control, including what third-party services you use, what personal information you have provided to such third parties, and whether (and the extent to which) you have limited the use of cookies by the operators of those third-party websites, platforms, and services.

Disclaimer Regarding Chat Features

Doppel may incorporate third-party interactive chat features (“Chat Features”), which may use Artificial Intelligence, for customer support purposes. If you interact with these Chat Features, you are not communicating with a human representative of Doppel. Instead, you are communicating with software that generates responses to your inputs based on machine-learning algorithms. These Chat Features may collect the content of your communications, including any personal information you provide it. Any personal information you provide to these Chat Features will be used, shared, and stored in accordance with this Privacy Policy and any applicable Terms of Service. Please discontinue use of these Chat Features if you do not consent to the collection and use of such personal information by Doppel and third-party operators of these Chat Features.

3. HOW DO WE PROCESS YOUR INFORMATION?

We may process your personal information for a variety of reasons, including:

• Fraud detection, security monitoring, and abuse prevention.
• Detecting, preventing, and responding to security incidents.
• Debugging and error monitoring to improve reliability.
• Internal research, analytics, measurement, and product development.
• To deliver and analyze the performance of our advertising, marketing and promotional communications, where permitted by law and subject to your choices.
• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of Services to the user, including generating deepfake demonstration content at your request.
• To communicate with you about the Services we provide or respond to your inquiries.
• To save or protect an individual’s vital interests when necessary to prevent harm.
• To investigate and mitigate impersonation and abuse (for example, we may request identity verification and/or trademark information to submit takedown requests on your behalf).
• To evaluate your candidacy when you apply for a position with us.
• To create de-identified, statistical, or aggregate data.
• To comply with a legal or regulatory obligation.

We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers. We do not attempt to re-identify anonymized or aggregated data except where strictly necessary to operate, secure, and protect the Services (for example, to investigate fraud, impersonation, or abuse).

Google API Services User Data Compliance

Doppel's use and transfer of information received from Google Workspace APIs complies with the Google API Services User Data Policy, including the Limited Use requirements. Information received from Google Workspace APIs is used solely to provide, maintain, secure, and improve the functionality requested by the user. Doppel does not use Google Workspace API data to develop, improve, or train generalized artificial intelligence or machine learning models except as expressly permitted by the Google API Services User Data Policy. Doppel does not sell Google Workspace API data or use it for advertising purposes. Doppel uses Qwen3-4B model which is a self-hosted model; accordingly, Google user data is processed locally and is not shared with the model provider for training purposes.

Financial Incentives and Offers

We may offer various financial incentives or offers from time to time, primarily requesting your identifiers and contact information as part of an offer. The terms of the financial incentive, including the personal information requested in connection with the offer, will be provided at the time you sign up for the financial incentive. We have calculated the value of the financial incentive by using the expense related to the offer, and the value of your data is the value of the offer presented to you. You may withdraw from any of the financial incentives at any time following the instructions provided. For offers involving email, you may unsubscribe via the “unsubscribe” link in any marketing email you have received. For offers involving text messaging, you may text STOP. We will not discriminate against you for opting out.

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

If you are located in the European Economic Area or UK

We may rely on the following legal bases:

• Consent. You can withdraw your consent at any time.
• Performance of a Contract. To provide our Services or at your request prior to entering into a contract.
• Legal Obligations. To comply with law, cooperate with lawful requests, or exercise/defend legal rights.
• Vital Interests. To protect your vital interests or those of a third party.
• Public Interests. When necessary to protect the public interest.
• Legitimate Interests. To operate, improve, and secure our Services, unless overridden by your rights.

If you are located in Canada

We may process your information with your express or implied consent, and you can withdraw consent at any time. In some cases, we may process without consent where legally permitted (e.g., fraud prevention or certain business transactions).

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your personal information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work, including:

• Order fulfillment service providers.
• User account registration & authentication services.
• Advertising and marketing vendors, data analytics and measurement services, cloud computing services, chat vendors, and data storage service providers.
• Employees or contractors of Doppel, its affiliates, subsidiaries, and joint venture partners.
• Law enforcement, regulators, or government agencies, when necessary to comply with applicable law, legal process, or lawful requests.
• Our social media partners (such as LinkedIn) may have access to your personal information when you click on a social media icon on our Services and are redirected to that social media partner’s website.
• Professional contacts you have provided as references when you apply for a position with us.
• Your employer when you are acting on behalf of a business.
• Any other parties where we have received your direction or consent to the disclosure of your personal data. 

We may also share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.

All third parties with whom we share personal information must provide the same or equivalent

protection of user data as described in this notice and required by applicable law. We may also disclose personal information where required to comply with applicable law, lawful requests from public authorities, court orders, or to enforce our agreements.

For more information about how we may “sell” or “share” your personal information, as those terms are defined under applicable law, please see Section 2, “‘Sale’ and ‘Sharing’ of Personal Information; Targeted Advertising” above.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information only for as long as necessary for the purposes set out in this notice (including complying with legal, accounting, or reporting requirements), unless a longer retention period is required or permitted by law.

We may retain, use, and disclose aggregated or de-identified information for analytics, research, and product improvement purposes. Where we maintain de-identified information, we take reasonable measures to ensure that the information cannot be associated with a consumer or household, maintain the information in de-identified form, contractually prohibit recipients from attempting re-identification, and otherwise comply with applicable law.

To the extent Doppel receives or processes any personal information that is not expressly described in this notice or that is not necessary for the provision or operation of the Services, such personal

information will be processed solely to the extent permitted or required by applicable law and, where appropriate, will be deleted, anonymized, or otherwise disposed of in accordance with applicable legal, regulatory, and contractual obligations.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Our mobile application respects system-level permission controls and does not attempt to manipulate or bypass your privacy choices.

Blogs, Forums, Chat Rooms and Other Public Posting Areas

Please note that any information you include in a message you post to any blog, forum, chat room, or other public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. Please be extremely careful when disclosing any information in blogs, chat rooms, forums, and other public posting areas. We are not responsible for the use by others of the information that you disclose in blogs, chat rooms, forums, and other public posting areas.

International Data Transfers

The Services are hosted in the United States. In order to communicate with you about content, the information that we collect from you may be transferred to, stored, used, and processed by us in the United States or one of our service providers based in the United States or outside of the United States.

If you are visiting from the European Union (“EU”), Switzerland, Canada, or the United Kingdom (“UK”), or other regions with laws governing information collection and use that may differ from United States law, please note that you are transferring your personal information to the United States. The laws of some countries may not provide the same levels of protection of personal information as your home country. By using the Services, you agree to the collection, transfer, storage, use, and processing of your personal information for the purposes described in this Privacy Policy. When you provide personal information to us or our service providers or vendors, you consent to the processing of your information in the United States as the Services are operated in the United States. We will take reasonable steps to ensure that your personal information is treated securely in accordance with this Privacy Policy, and that all personal information you provide to us is stored on our secure servers or those of our service providers.

YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR PERSONAL INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR PERSONAL INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR PERSONAL INFORMATION WITH US, OR MAKE USE OF THE SERVICES.

TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THE FOREGOING WAIVER DOES NOT APPLY TO YOU.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

9. YOUR PRIVACY RIGHTS AND CHOICES

• Accessibility: Doppel is committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us at [email protected] or call.
• Email Opt-Outs: You may opt-out of commercial communications by contacting us by email at [email protected] or clicking the “unsubscribe” link in one of our marketing emails. We will process your requests as soon as possible, but please be aware that it may take us some time to respond to your request and, in some circumstances regarding opt-out requests, you may receive a few more messages until your request is processed.
• Text or SMS: In some circumstances, we might require you to opt-in to receive text messages from us. At any time, you may opt-out of receiving particular text messages from us by texting STOP in response to any text message.

For Individuals in the European Economic Area (“EEA”), the U.K., Switzerland, and Canada

In some regions (such as the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information, request rectification or erasure, restrict processing, request data portability, and object to processing.

You may also have the right to lodge a complaint with a data protection authority about our collection and use of your personal information.

Withdrawing your consent: If we rely on your consent, you have the right to withdraw it at any time. This will not affect the lawfulness of processing before withdrawal.

Opting out of marketing: You can unsubscribe from marketing emails using the unsubscribe link, or contact us. We may still send you service-related messages.

You can make a request by contacting us using the details in Section 11 of this Privacy Policy.

Additional Rights for Residents of California, Nebraska, and Texas

Depending on your state of residence, you may have some or all of the following rights regarding your personal information, subject to exceptions under applicable law:

• You have the right to know and right to access information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or shared your personal information.
• You have the right to request the deletion of your personal information, subject to certain exceptions.
• You have the right to opt out of the “sale” or “sharing” of your personal information to third parties. This includes opting out of targeted advertising.
• You have the right to correct your personal information if inaccurate.
• You have the right to obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance.
• You have the right to limit the use and disclosure of your sensitive personal information if we use such information to infer characteristics about you.
• You have the right to request the categories of third parties, and, for residents of some states, the specific third parties, to whom we have disclosed your personal information.
• You have the right to not be discriminated against or retaliated against for exercising these rights. We will not deny you goods or services, charge you different prices, provide a different level or quality of goods or services, or suggest that you will receive a different price or level of goods or services because you exercised a privacy right.
• You have the right to opt out of profiling where Automated Decision-Making Technology (“ADMT”) is used to make decisions about you that have a legal or similarly significant effect.
• You have the right to request information about our use of ADMT. Upon submission of a verifiable request, we will provide you with: (a) a plain-language explanation of the specific purpose for which we used ADMT; (b) how the ADMT processes personal information to make the significant decision, including the categories of personal information that affect the output; (c) the type of output generated by the ADMT and how that output is used to make the significant decision; and (d) the outcome of the decision, including any plans for future use of the output in significant decisions concerning you.

How to Submit a Request: To exercise any of the rights described above, you (or your authorized agent) may submit a request using any of the following methods:

• Email: [email protected]

You may only make a verifiable request for access or data portability twice within a twelve (12)-month period.

Authorized Agent: You may, under certain circumstances, authorize another individual or a business, called an Authorized Agent, to make a verifiable consumer privacy request on your behalf. If you wish to have an Authorized Agent make a verifiable consumer privacy request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

Verification of Requests: To protect your privacy, we take reasonable steps to verify your identity before responding to a request to know, delete, correct, obtain a copy, or limit the use of Sensitive personal information. The verification steps we use depend on the nature of the personal information involved and the risk of harm from unauthorized disclosure. We may ask you to provide information that matches personal information we already maintain, or to authenticate through your account. We will not use personal information provided for verification for any other purpose except where required by law.

Response Timelines: We will respond to verifiable consumer requests within 45 days of receipt. We may extend this period by an additional 45 days where reasonably necessary, in which case we will inform you of the extension and the reason for the delay within the initial 45-day period. We are not obligated to respond to requests to know or requests to delete from the same consumer more than twice in a 12-month period.

Appeal of Denied Requests: If we deny a request you submit (in whole or in part), we will provide you with a detailed explanation of the basis for the denial. You may appeal our decision by contacting us at [email protected] with the subject line “Privacy Rights Appeal”. Please include: (a) your original request, (b) the denial response, and (c) the reasons you believe the denial was in error. We will respond to your appeal within 45 days of receipt.

Texas: We may collect biometric data through our deepfake demonstration tool as described in Section 11 of this Privacy Policy. We do not sell biometric data.

10. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Effective Date” and will be effective as soon as it is accessible.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, or to exercise your privacy rights, you may email us at [email protected] or send an inquiry by mail to:

Doppel Inc.

440 North Barranca Avenue, #5110

Covina, CA 91723

United States