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    Echo Club Privacy Policy

    Effective Date: June 9, 2026

    1. Scope

    Unblocked Brands, Inc. ("Unblocked," "we," "our," or "us") operates the Echo Club platform (the "Platform"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Platform and related services.

    The Platform is intended for individuals in the United States who are at least 18 years old.

    2. Information we collect

    2.1 Information you provide. We collect information you provide directly, including:

    • Account and contact information, such as your email address, name, and username.
    • Profile information you choose to provide, such as your general location, date of birth, gender, interests, and profile photo.
    • A confirmation that you are at least 18 years old, which we record when you sign up.
    • Social media information, such as the usernames or handles of social media accounts you connect or verify with the Platform.
    • Creator Content you submit through the Platform, such as videos, images, links to content you have published on social media platforms, and other materials you upload.
    • Photos and images of yourself, and voice recordings, that you upload for avatar features, which we use, with your permission (confirmed at upload), to create and operate a digital avatar or replica of your likeness and a simulation of your voice as described in our Terms of Service.
    • Payment-related information needed to deliver earnings you withdraw, such as your chosen payout method and the details required to send payment, and, where required, identity or tax information collected before a payment is made.
    • Sweepstakes and contest entries, including entry information and prize fulfillment details.
    • Communications, such as messages you send through in-app support and correspondence with us.
    • Referral information, such as referral codes you use or share.

    2.2 Information from connected accounts. When you connect or verify a social media account, we collect publicly available information about that account, such as your public profile information, follower counts, and content performance metrics. We use this data to verify eligibility and track Mission performance. When you sign in through a third-party authentication provider, we receive information needed to create and secure your account, such as your email address.

    2.3 Information collected automatically. When you use the Platform, we and our service providers automatically collect:

    • Device information, such as device type, operating system, and browser type.
    • Usage data, such as pages visited, features used, and actions taken.
    • Log data, such as IP address, access times, and referring URLs.
    • Cookies and similar technologies used for analytics, functionality, and attribution.
    • Information used to detect fraud and abuse, which may be stored in de-identified or hashed form.

    2.4 Biometric and avatar data. If you use avatar features, the photos and voice recordings you upload, and the identifying data derived from them to make your avatar look and sound like you (such as measurements of face geometry and characteristics of your voice), are collected only with your prior written consent, given at the upload step, and are used only to create and operate your avatar and avatar-based content. We do not sell, lease, trade, or otherwise profit from the disclosure of this data.

    Retention and destruction schedule. Your source photos and voice recordings are permanently deleted within 30 days after your avatar is replaced or your account is deleted, and in all cases no later than 1 year after your last activity on the Platform. Data derived from your uploads is deleted when your account is deleted. You can request earlier deletion at any time as described in Section 9, and deletion requests are honored within 30 days.

    3. How we use your information

    We use your information to:

    • Operate, maintain, and improve the Platform.
    • Match you with relevant Missions and brand partners.
    • Track content performance and calculate compensation.
    • Process payments, verify eligibility and identity where required, and issue tax documents where required by law.
    • Administer sweepstakes, contests, referrals, and the Gems rewards program.
    • Create and operate your digital avatar from images and voice recordings you upload, with your permission, and generate avatar-based content as described in our Terms of Service.
    • Send transactional and promotional communications. You can opt out of promotional emails at any time using the unsubscribe link in any marketing email.
    • Detect and prevent fraud and abuse, and enforce our Terms of Service.
    • Comply with legal obligations.

    4. How we share your information

    4.1 Brand partners. We share your profile information, content performance metrics, and Creator Content with brand partners for campaign management and reporting. Brand partners may use Creator Content for their marketing purposes as described in our Terms of Service.

    4.2 Service providers. We share information with third-party service providers who assist us in operating the Platform, including: identity and authentication providers; payment, payout, and tax-reporting providers; email delivery providers; cloud hosting, storage, and content delivery providers; analytics providers; security and error-monitoring providers; and technology providers that support content processing and review. These providers are contractually obligated to protect your information.

    4.3 Third-party social media platforms. When you connect, verify, or publish content to a third-party social media platform, that platform receives information in accordance with its own terms and privacy policy, which we do not control.

    4.4 Legal and safety. We may disclose information when required by law, to protect rights and safety, to enforce our Terms, or in connection with a merger, acquisition, or sale of assets.

    4.5 Sweepstakes and contest winners. If you win a sweepstakes or contest, we may publicly announce your name and likeness as permitted by law and the applicable Official Rules.

    4.6 With your consent or at your direction.

    5. Cookies and similar technologies

    We and our service providers use cookies and similar technologies to keep you signed in, remember preferences, measure how the Platform is used, attribute signups to marketing campaigns, and help detect fraud. Most browsers allow you to manage cookie preferences; disabling cookies may affect Platform functionality.

    6. Marketing communications and your choices

    When you create an account, you are subscribed to promotional emails from us. You can opt out of promotional emails at any time by clicking "unsubscribe" in any marketing email or adjusting your notification settings. You cannot opt out of transactional communications related to your account, earnings, or legal notices.

    7. Data retention

    We retain your information for as long as your account is active or as needed to provide services, comply with legal obligations (including financial and tax recordkeeping), resolve disputes, prevent fraud and abuse, and enforce agreements. Avatar photos, voice recordings, and data derived from them follow the defined retention and destruction schedule in Section 2.4. After account closure, we may retain certain information as required by law or for legitimate business purposes.

    8. Security

    We implement reasonable administrative, technical, and physical safeguards designed to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

    9. Your rights and choices

    • You can access and update certain account and profile information through the Platform settings, and you can disconnect linked social media accounts.
    • You can request a copy of your data or request deletion of your account through the options available in the app or by contacting us. Some information may be retained after deletion where retention is required or permitted by law, such as records related to payments, taxes, and fraud prevention.
    • You can opt out of promotional emails as described above.

    10. California privacy rights

    California residents have additional rights under the California Consumer Privacy Act, including:

    • The right to know what personal information we collect, use, and disclose.
    • The right to delete personal information, subject to exceptions.
    • The right to opt out of the sale or sharing of personal information.
    • The right to non-discrimination for exercising your rights.

    To exercise these rights, contact us at hello@echoclub.fun. We will verify your identity before processing requests. We do not sell personal information in the traditional sense, but sharing data with brand partners may constitute a "sale" or "sharing" under California law. You can opt out by contacting us.

    11. Age requirement

    The Platform is not intended for anyone under 18, and we do not knowingly collect personal information from anyone under 18. If we learn that a user is under 18, we will take steps to close the account and delete the associated information as required by law.

    12. United States only

    The Platform is intended for users in the United States, and information we collect may be stored and processed in the United States.

    13. Changes to this policy

    We may update this Privacy Policy from time to time. We will notify you of material changes via email or Platform notification. Your continued use after changes constitutes acceptance of the updated policy.

    14. Contact us

    Unblocked Brands, Inc.
    9000 Washington Blvd, Culver City, CA 90232
    Email: hello@echoclub.fun