Last Updated: December 12th, 2022 Versa, Inc. and its affiliate or controlled companies ("Versa", "us”, "our" or "we") are dedicated to protecting the privacy rights of our users ("users" or "you"). This Privacy Policy (the "Policy") is meant to help inform you of your choice and our practices in regard to the manner we collect, store, use, and manage the information that you provide or we collect in connection with our website:www.versa-ai.com or any of our mobile applications available on mobile app stores (including Apple App Store and Google Play) and mobile platforms (including iOS and Android) (collectively, the "Services"). Please note that the scope of this Policy is limited to information collected or received by Versa when you are using our Services. If you have any questions regarding this Privacy Policy or any privacy-related matters, please contact us via: contact@versa-ai.com, or via postal mail at R19, 3rd Floor, Building No.1, Yuyuan Rd 1107, Changning District, Shanghai, China. SUMMARY What information do we collect about you? We collect and process information about you when you register for an account, upload content to the Platform (where such features are available), interact with the Services, or in accordance with our request. We may also collect information about you through automated means when you access our Platform or use the Services. These include technical and behavioural information about your use of the Services. We may still collect information about you if you interact with the Platform without creating an account. How will we use the information about you? We use your information to provide the Platform and Services to you and to improve, develop and administer it. We use your information to, among other things, ensure your safety. We may also use your information to serve and measure personalized advertising and promote the Platform. Who do we share your information with? We may share your information with third party service providers who help us to deliver the Platform, send notifications to you, or conduct analysis, or with any member of our corporate group to improve the Platform, allow you to access other services provided by such member of our corporate group, or for internal business purposes. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order. How long do we retain your information? We retain your information for as long as it is necessary to provide you with the Services and fulfil our contractual obligations and rights in relation to the information involved. Where we do not need your information in order to provide the Services to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your information if we believe it is or will be necessary for the establishment, exercise or defence of legal claims. How will we notify you of any changes to the Policy? We may amend or update this Privacy Policy from time to time. We will use commercially reasonable efforts to notify you of any material changes to these Terms by a notice provided through the Platform or by other means. You should review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices. The "Last Updated" date at the top of this policy reflects the effective date of such policy changes. Your continued access to or use of the Platform or the Services after the date of the updated Policy constitutes your acceptance of the updated Policy and how we may collect, use, process, disclose or transfer your information pursuant to such updated Policy. If you do not accept the updated Policy, you must stop accessing the Platform or using the Services. 1. The types of information we collect We collect and use the following information about you: Information you choose to provide. · Registration.: You give us information when you register on the Platform, including your date of birth and gender (where applicable), your email address and the corresponding password you set for your Cooclip account, your accounts on other social network services (where applicable),and other information you disclose in your user profile. · User Content: Where such features ares provided in your region, we process the content and personal data you upload, generate, or access through the Platform, including the photographs, images and videos you upload, video templates you generate or view on the Platform, comments you make and other actions you take on the Platform, such as liking content ("User Content"). We may collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content, in order to recommend audio options and provide other personalized recommendations to you. We may collect information about the images and audio that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this information to enable special video effects, for content moderation, and for other non-personally-identifying operations. To improve your experience, you are not required to make an account to create and upload your content on the Platform when using our website. However, if you do not subsequently create an account, then we will delete this content from our server within a certain period of time. · Other information. Information we collect automatically. We may collect the following information about you: · Technical information we collect about you: We automatically collect certain information from you when you access the Platform or use the Services. Such information includes your IP address, unique device identifiers (device ID), advertising identifiers, network type and connections, mobile or device model, Android ID, device manufacturer, mobile phone area, application version number, operating system, CPU and GPU information, device resolution, system language and region, battery information, and information regarding your use of the Platform (such as, where applicable, the list of likes you received, your stickers and filters). This allows us to provide you with personalized content that will be of interest to you. · Location: We collect information about your approximate location, including location information based on your SIM card and/or IP address. We may use such information to provide you with personalized content. · Usage Information: We collect information regarding your use of the Services, e.g., video editing acts, problems encountered, and, where applicable, how you interact with content we show to you, the ads you view, videos you watch, the content you like, the users you follow and how you engage with mutual followers. · If you use the auto caption function, we will collect the transcribed text and the edited text in order to develop and improve this function. Information we obtain from other sources. We may receive information about you from other sources, including through third-party services providers or partners. For example, if you access third-party services through the Platform or Services or share information about your experience on the Services with others, we may collect information from these third-party services. If you choose to register to use the Platform using your social media network account details (e.g. Facebook) or account details with other third parties (e.g. Apple), we may collect information from these services, including your username, public profile, your liked songs on that social network (where applicable), and information about your use of that service. 2. Cookies "Cookies" are small files which, when placed on your device, enable us to collect certain information, including personal data, from you in order to provide certain features and functionality. We and our service providers and business partners use Cookies to collect data and recognize you and your device(s) on the Platform and elsewhere across your different devices. We do this to measure the traffic and functionality of our website. By accessing or using the Platform and Services, you consent to our use of Cookies. You may be able to control some of the information we collect by adjusting your browser settings to refuse or disable Cookies. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your choice to disable cookies is specific to the particular browser or device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you. Without this information, we are not able to provide you with all the requested services. 3. How we use your information We will use the information we collect about you in the following ways: · verify your age and identity; · administer and provide you with the Platform and Services, including to enable you to create, edit, modify and share User Content and interact with other users, and to allow you to participate in interactive features of the Platform, when you choose to do so; · communicate with you, including to notify you about changes to the Platform and Services; · provide you with user support; · provide you with tailored or personalized information or content that may be of interest to you; · enforce our terms, conditions and policies; · respond to, handle, and process queries, requests, applications, complaints, and feedback from you; · improve and develop the Platform and to ensure tools on the Platform are presented in the most effective manner for you and your device; · administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; · detect abuse, fraud and illegal activity on the Platform and ensure your safety and security including reviewing user content, messages and associated metadata for breaches and inappropriate content; · provide users with personalized advertising, where such relevant feature is provided; · comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; · for any other purposes for which you have provided the information, with your consent or at your direction; transmit to third parties including our business partners, third party service providers and agents, and relevant governmental and/or regulatory authorities for the aforementioned purposes; and · any other incidental business purposes related to or in connection with the above. We will apply to you for the necessary permissions when you use the function of a specific product. If you do not agree to enable the permission, please click "Not allowed". Refusing the permission will only affect your use of the function of the specific product. We present to you the types of permissions that the product will likely collect and the purposes for which they will be used.

4. How we share your information This section sets out how we may share your information with third parties. Service Providers We may share the categories of personal information listed above with our service providers (whether in or outside your country) in order to provide you with the Platform and Services for the purposes as set out in this Policy, including with: · our service providers, suppliers and subcontractors who help us run the Platform (such as to send notifications to you); and · data analytics, crash analytics, and search engine providers that assist us in the improvement and optimization of the Platform (including providing you with tailored or personalised information or content). In order to ensure the realization and stability of Cooclip playmap related functions, we may access the SDK and application program interface provided by the partner to achieve relevant gurgoses

If you choose to register to use the Platform with your other social network account details or other third party platform account details or choose to link your Platform account with other social network accounts, these third-party services may be able to collect information about you, including information about your activity on the Platform, and they may notify your connections on the third-party services about your use of the Platform, in accordance with their privacy policies. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party, such as your app ID, access token, and the referring URL. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide. Where you opt to share User Content you created or uploaded on the Platform to other social media platforms, your User Content, username and accompanying text (if any) will be shared on such platforms. Advertising and analytics partners We may share information collected through your use of our Platform (such as mobile identifiers and your device’s IP address, and related information about your inferred location and use of the Platform) with our advertising partners. These partners help us deliver relevant advertising across our Platform and on other platforms. This information is typically collected through Cookies and similar tracking technologies. We may also share aggregate information about how those ads have performed to help those advertisers measure the effectiveness of their advertising campaigns. Law Enforcement We may share your information with law enforcement agencies, public authorities or other entities if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: · comply with legal obligations, processes or requests; enforce our Terms of Service and other agreements, policies, and standards, · including investigation of any potential violation thereof; · exercise or defend any legal claims; · detect, prevent or otherwise address security, fraud or technical issues; or · protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction). Sale or merger We may also disclose your information to third parties: · in the event that we sell any business or assets, in which case we may disclose your information to the prospective buyer of such business or assets; or · if we sell, buy, merge with, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, your user information may be among the transferred assets. We may share all of the information we collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy. Finally, we may share information with third parties with your consent or at your direction. Third-party content The Platform and Services may contain links to content maintained by third parties who we do not control. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Policy. 5. Where we store your information The information about you that we collect from you may be transferred to, and stored at, a destination inside or outside of your country, for the purposes as described in the Policy. We will take reasonable steps to secure your information and treat it in accordance with this Policy. Where we transfer any personal data out of the country where you live, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws, including by entering into data transfer agreements with the recipient to ensure your personal data is accorded an adequate level of protection. 6. Your choices and rights On some versions of the Platform, you can access and edit most of your profile information by signing into your account, and you may also be able to control how you use the Platform by visiting your in-app settings, including to decide whether you see certain types of interest-based advertising on the Platform. You may also be afforded rights in your country under applicable laws such as the ability to access your data, delete your data, and potentially others. If you have any questions on how to use the settings or want to know about any rights with regard to your personal data you may have in the country where you live, please contact us at capcut.scontact@versa-ai.com. 7. The security of your information We will take reasonable steps to secure your information and treat it in accordance with the Policy. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. We have put in place technical and organizational measures that we will amend and update from time to time to improve the overall security of our systems. 8. Data retention We retain your information for as long as it is necessary to serve the purpose(s) for which such information was collected, including to provide you with the Platform or the Services. Where we do not need your information in order to provide the Platform or the Services, we retain it only for so long as we have a legitimate business or legal purpose in keeping such information. However, there are occasions where we are likely to keep this information for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims. After you have terminated your use of our Platform or Services, we may store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we may also retain any information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements. 9. Information relating to children The Platform is not directed at or suitable for use by children under the age of 13 or equivalent minimum age in the relevant jurisdiction ("relevant age"). Users under the relevant age are not allowed to use the Platform. If we become aware that personal information has been collected from a person under the relevant age, we will delete the user’s information in accordance with applicable law. If you believe that we may have information about or collected from a child under the relevant age, please contact us at contact@versa-ai.com. 10. Complaints In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at contact@versa-ai.com and we will endeavour to deal with your request as soon as possible.This is without prejudice to your right to launch a claim with the relevant data protection authority or follow the dispute process provided in the Terms of Service.