ICONLINK — PRIVACY & COOKIES POLICY

Version: 1.0

Effective date: 12 January 2026

Applies to: Iconlink website - https://iconlink.ai/

Contact (privacy/legal): legal@iconlink.ai

1) Who We Are (Controller)

Brand & IP Holder: XANNOVA, S.A. (Republic of Panama) Registered office: Oficina 16-01, Midtown Tower, C-74 Este, Panama, Provincia de Panama. RUC / Tax ID: 155765810-2-2025 DV98 Public Registry / Business License: Aviso de Operaciones - 155765810-2-2025-2025-574413832 Legal representative: Tatiana Prisca Charbit Postal: XANNOVA, S.A., Oficina 16-01, Midtown Tower, C-74 Este, Panama, Provincia de Panama. Merchant of Record: XANDRIA LTD. (Republic of Bulgaria) — UIC 208408618 · VAT BG208408618 Address: Lavele Str. No. 19, Sredets, 1000 Sofia, Republic of Bulgaria Legal representative: Tatiana Prisca Charbit Phone: +33757691089 Email (privacy/legal): legal@iconlink.ai In Phase 1, Iconlink primarily collects lead and onboarding data (whitelist, early access, AI artist onboarding, Models and Brands). Payments may be enabled later.

2) What This Policy Covers

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you: • visit the Site; • submit a Model Whitelist application; • submit a Brand Early Access lead; • submit an AI Artist onboarding request; • contact us or subscribe to updates (if enabled).

3) Data We Collect

We may collect: A) Data you provide • Identity & contact: name, email, country, city (optional), phone (optional) • Professional/profile: social handles, portfolio links, categories, tags (appearance/style tags), brand/company name (for brands) • Messages: anything you write in forms or emails • Consents: acceptance of Terms, marketing opt-in (if enabled) B) Data collected automatically • Device/usage data: IP address, browser type, device info, pages viewed, referral URL, timestamps • Cookies/identifiers: cookie IDs and similar identifiers (see Cookies section) C) Sensitive data We do not ask you to provide sensitive data (e.g., health, religion, political opinions). Please do not submit sensitive data via our forms.

4) Why We Use Your Data (Purposes)

We use personal data to: 1. Operate the Site and provide its core functions 2. Process applications/leads (Model whitelist, Brand early access, AI artist onboarding) 3. Communicate with you (respond to requests, send operational messages) 4. Improve performance & security (fraud prevention, anti-scraping, monitoring, debugging) 5. Analytics (understand traffic and improve UX), where enabled and permitted 6. Marketing communications (only if you opt in, where required)

5) Legal Bases (GDPR-style approach)

Where GDPR/UK GDPR applies, we rely on: • Contract / pre-contractual steps: processing whitelist/onboarding/early access requests • Legitimate interests: site security, fraud prevention, improvement of services • Consent: cookies requiring consent; marketing emails where required • Legal obligation: where we must comply with applicable laws

6) Cookies and Similar Technologies

We may use cookies and similar technologies for: • Strictly necessary functions (security, load balancing) • Analytics (to understand usage) • Marketing/advertising (if enabled) Where required by law, we display a cookie banner and allow you to manage preferences and withdraw consent. Cookie details: see https://iconlink.ai/privacy (Cookies section / Cookie Policy).

7) How We Share Data (Recipients)

We may share personal data with: • Service providers (processors) who help us run the Site (hosting, email delivery, analytics, security, forms) • Professional advisors (legal, accounting) where necessary • Authorities where required by law, or to protect rights/safety We do not sell your personal data in the ordinary sense. If we ever use advertising/analytics that qualifies as "sharing" under certain US laws, you will have appropriate controls.

8) International Transfers

Your data may be processed in countries different from where you live (e.g., where our hosting/providers operate). Where required (e.g., EU/EEA/UK), we use appropriate safeguards such as contractual protections and, where relevant, Standard Contractual Clauses or equivalent measures.

9) Data Retention (Lean Schedule)

We keep data only as long as necessary for the purposes above: • Whitelist / AI Artist onboarding submissions: up to 24 months from last interaction, then deleted or anonymized unless you become an active participant or request earlier deletion. • Brand early access leads: up to 24 months from last interaction. • Support/legal emails: up to 36 months (longer if needed for disputes or legal obligations). • Security logs (IP, abuse signals): typically 6–12 months. • Cookie consent logs (if applicable): typically 12–24 months (or as required by law). We may retain limited records longer if necessary to establish, exercise, or defend legal claims.

10) Your Rights

Depending on your location, you may have rights including: access, rectification, erasure, restriction of processing, data portability, objection, and the right to lodge a complaint with a supervisory authority. To exercise your rights, contact us at legal@iconlink.ai.

11) Marketing (Opt-in / Unsubscribe)

We send marketing communications only where you have opted in. You can unsubscribe at any time via the link in our emails or by contacting legal@iconlink.ai.

12) Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or alteration.

13) Children

The Site is not directed at children under 16. We do not knowingly collect data from children. If you believe we have collected data from a child, please contact legal@iconlink.ai.

14) Changes & Contact

We may update this policy from time to time. The current version is always at https://iconlink.ai/privacy. For questions: legal@iconlink.ai.

ICONLINK — COOKIES POLICY

1) What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help the site function, remember preferences, and analyze traffic.

2) Why We Use Cookies

We use cookies to operate the Site, improve security, understand usage (analytics), and, where you consent, for marketing. We only use non-essential cookies with your consent.

3) Cookie Categories

Absolutely necessary (always on): required for the Site to work. Functional (optional): preferences and features. Analytics / performance (optional): usage statistics. Advertising (optional): only if you opt in.

4) Your Choices

You can manage cookies via our Cookie Consent Manager (if shown), your browser settings, or opt-out links in our emails. You can withdraw consent at any time.

5) Contact

For cookie-related questions: legal@iconlink.ai.