PRIVACY POLICY

Last updated: May 24, 2026

This Privacy Policy governs the processing of personal data of users of the E-DOLLS platform hereinafter, the “Platform”, in accordance with Regulation EU 2016/679, the General Data Protection Regulation GDPR, and other applicable regulations.

This Policy forms an integral part of the Terms and Conditions of Use of the Platform and shall be interpreted consistently therewith.

1. DATA CONTROLLER

The controller of the personal data collected through the Platform is AI Analytics S.L., a company operating the E-DOLLS platform and brand, in its capacity as owner and operator of the digital service.

AI Analytics S.L. acts as the data controller, in accordance with the GDPR, with respect to the personal data necessary for the provision, security and administration of the services offered through E-DOLLS.

2. PERSONAL DATA COLLECTED

AI Analytics S.L. may collect the following categories of personal data through E-DOLLS:

a) Account and identification data

• Email address.
• Username.
• Profile information voluntarily provided by the user, such as name, country, date of birth, profile picture or other optional information.
• Encrypted access credentials.

b) Technical and usage data

• IP address.
• Device and browser information.
• Approximate geolocation data derived from IP.
• Access, activity, security and diagnostic logs within the Platform.

c) Visual and creative content

• Images uploaded by the user for editing, reference or processing.
• Images generated or edited through the Platform.
• Prompts, parameters or instructions entered by the user.
• Gallery items, where the user chooses to store generated or edited outputs.

d) Payment and subscription data

• Information related to subscriptions, credits, invoices, account transactions and billing status.

Payments are processed through secure external payment providers. AI Analytics S.L. does not directly store full banking data or complete card information.

3. PURPOSE AND LEGAL BASIS OF PROCESSING

Personal data is processed for the following purposes:

• Provide access to the Platform, editorial areas and artificial intelligence tools.
• Manage accounts, subscriptions, credits and user access.
• Store the user’s private gallery and service history where applicable.
• Operate image editing, generation and processing features through external APIs.
• Ensure security, availability and proper operation of the service.
• Prevent fraud, misuse, unauthorized access or technical abuse.
• Comply with legal, accounting, tax and cooperation obligations.

The legal basis for processing is:

• The performance of the service contract.
• The user’s consent, where required.
• The fulfillment of legal obligations.
• The legitimate interest of AI Analytics S.L. in Platform security, service operation, fraud prevention and technical optimization.

4. IMAGE PROCESSING AND AUTOMATED PROCESSES

E-DOLLS operates as a fashion magazine, artistic photography platform and software-as-a-service service providing image editing, generation and processing tools based on artificial intelligence technologies and external APIs.

Images uploaded for reference or temporary processing are used only for the requested service operation and may be automatically deleted once the corresponding process is completed, unless the user chooses to save the result in the private gallery or a different retention period is required for security or legal reasons.

Images generated or edited as a final result may be retained for a maximum of six (6) months to allow access to the user’s private gallery, unless deleted earlier by the user or where a longer retention period is legally required.

AI Analytics S.L. does not use user images for commercial, promotional or public purposes without the user’s authorization.

The user acknowledges that certain data processing operations and content generation may involve automated processes based on artificial intelligence systems, without direct human intervention in each individual output, in accordance with Article 22 of the GDPR where applicable.

5. EXTERNAL PROVIDERS

For Platform operation, AI Analytics S.L. uses external providers for:

• Artificial intelligence systems and APIs.
• Payment processing and subscription management.
• Infrastructure, hosting, storage and security services.
• Email, technical support and operational communications, where applicable.

These providers only access the data necessary to perform their services and are subject to confidentiality, security and data protection obligations.

In the event of international data transfers outside the European Economic Area, appropriate safeguards shall be applied pursuant to Articles 44 et seq. of the GDPR.

6. DATA RETENTION

Personal data shall be retained for the duration of the contractual relationship with the user and for the periods required by applicable law.

Generated or edited images stored in the private gallery are retained for a maximum of six (6) months unless deleted earlier by the user or required for legal, security or dispute-resolution purposes.

Technical data, security logs and transaction records may be retained for the time necessary to ensure system security, prevent fraud, resolve incidents and comply with legal, tax and accounting obligations.

7. USER RIGHTS

Users may exercise the rights recognized under the GDPR, including access, rectification, erasure, restriction, objection and portability, through the contact channels made available on the Platform.

AI Analytics S.L. shall address such requests within the legally established time limits.

8. DATA DISCLOSURE AND LEGAL COOPERATION

AI Analytics S.L. does not sell personal data to third parties.

Without prejudice to the Terms and Conditions of Use, strictly necessary information may be provided when subject to a valid legal request by competent authorities or where disclosure is required to protect the legal rights, security or integrity of the Platform.

9. COOKIES AND TRACKING TECHNOLOGIES

The Platform uses technical and personalization cookies, as well as internal logging and technical analytics systems, necessary to ensure proper operation, security and continuous improvement of the service.

Cookies allow, among other functions:

• Maintain the user session.
• Remember basic preferences.
• Ensure Platform stability and security.

Additionally, E-DOLLS performs internal analytics based on technical and usage data, which may include IP address, device information, and connection and activity logs, for the purposes of:

• Ensuring system security.
• Preventing fraud or misuse.
• Analyzing technical performance.
• Improving service quality and reliability.

Such analytics are carried out without individual profiling, without cross-site tracking, and without third-party advertising cookies.

Processing is based on the legitimate interest of AI Analytics S.L. in Platform security, operation and optimization, and, where applicable, on the performance of the service contract.

In accordance with applicable regulations, the use of technical and personalization cookies does not require prior user consent. Users may configure their browser to block or delete cookies, noting that this may affect Platform functionality.

10. MODIFICATIONS

AI Analytics S.L. may update this Policy as necessary due to legal, technical or operational changes.

Continued use of the Platform implies acceptance of the current version.