Effective as of December 22, 2025

PPL Privacy Policy

This Privacy Policy applies to the family of PPL applications (collectively, the “PPL Applications”). PPL is a mobile and internet-enabled application developed by PPL LLC PPL is an online service that allows users (referred to as “Creators”) to design, create, interact with and share their own digital friend (referred to as “Content”), to chat with them and guide them on their path, to play through challenges, unlock followers, and see what it takes to grow into a star.  

To avoid confusion, we refer to PPL as the relevant entity throughout this policy. However, PPL is the business that collects and stores your information and Content. PPL knows that you take your privacy seriously. Your data and privacy is important to us and our affiliated companies (collectively, “PPL”, “us”, “our”, or “we”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share data from or about individuals who use the PPL (an “app”) or visit our website at www.ppl.xyz (collectively, the “Services”) to use our Services. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Use, found at http://www.ppl.xyz/terms. 

INFORMATION WE COLLECT

We collect a variety of information from or about you or your devices from various sources, as described below.

Information you give us directly.

• Registration information. When you sign up to PPL using your Apple or Google credentials, you provide us with basic information like your first name, last name and e-mail address. 

• Content. When you upload any content through the PPL application (such as text, images, and/or audio-visual content), or you provide text, video or audio prompts during the Content creation process, we collect the contents of the message, any attachments to the message (including any Content), and the content of your prompts.    

• PPL communications. When you reach out to us (through, for example, an in-app report or email, we collect and store the contents and details of that communication, including things like date, time, method of communication, and resolution (if applicable).

• Polls, surveys, and questionnaires. When you voluntarily respond to polls, surveys, and questionnaires, we receive the contents of your responses and any other information you provide, such as your address and basic demographic information.

• User Contacts. We collect the information of the people and organizations you connect and interact with when using our Services. 

Information we collect when you use our Services.

• Log and data usage information. We collect information about your activity on the PPL applications and how you use the Services, such as information about the Content you upload or create, the time, duration, and frequency of your use, your engagement with other users Content, and your settings, as well as your internet protocol ("IP") address, and how you use third-party websites or services accessed through the app.

• Device and browser information. We collect information from and about the device you use to access our Services, which may include information like your hardware model, operating system version, device model and/or carrier, web browser type and settings, push notification tokens, advertising identifiers (e.g. Apple IDFA or Google Advertising ID), unique device identifiers, and mobile network information, as well as information you’ve shared with us through device settings, like GPS location, camera access, photos and related metadata.

• User-Generated Content.  We collect and store all Content you create using our Services, including AI generation prompts you submit for image, video, and story generation, AI-generated images, videos and stories created through the PPL platform and its third party partners, edits and variations, or customizations you make to generated content, and content you share with the PPL community.

• Information collected from cookies and similar technologies. We and our third-party partners, such as advertising partners, may collect information through the use of cookies and similar technologies like web beacons. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

Information we get from Third Parties.

• Information from third parties. We may receive information about you from third parties, including third parties that integrate with the Services or that provide services to us. This may include information such as log and data usage information collected from our Services or other online services, device and browser information, location information, and information collected through cookies or other similar technologies. We may combine this information with demographic and other interest-based segment information we receive from third parties.

• Information from third-party services. When you created your account using a third-party account, such as your Apple or Google account, we may receive certain information about you from these third parties such as your first name, last name, and profile picture. If you wish to limit the information we receive, you should visit the privacy settings of your third-party accounts to learn about your options.

HOW WE USE INFORMATION

We use the information we collect to:

• Provide, maintain, improve, and enhance the Services. We use information we collect about you to provide the Services you request from us and to provide the functionality of the app and the features you choose to use. For example, we use the information we collect to facilitate your use of the PPL features, to allow you to create and post Content, to process your AI image, video, and story requests submitted during creation and modification of your digital friend(s).  We also use your information to register you for new PPL features and apps.

• Personalize your experience on the Services. For example, we use the information we collect to personalize content and make suggestions that are relevant to you.

• Understand and analyze how you use the Services. We aim to continuously improve our offerings to bring you the best way to make meaningful connections. Accordingly, we are continuously analyzing how users access and use the app and its features in order to improve existing Services and develop new ones. Our analysis of how you use the PPL applications can help us do things like evaluate the popularity and functionality of certain features, identify and fix potential bugs, and understand what our users want.

• Communicate with you. The information we collect lets us to respond to your comments and questions or otherwise provide customer support, and keep you updated on other information such as PPL’s latest product announcements, software updates, and upcoming events.

• Enable social functionality. We use the information we collect to support the social functionality of the Services, which includes posting your Content on PPL’s public stream, and may in the future allow you to share Content on third-party services, such as social media networks.

• Promote safety and security. We also use information to find and prevent fraud and promote trust and safety on the Services. For example, we may scan Content for inappropriate content or capture screen shots of video streams included within the Content or your communications to protect the safety and integrity of our Services and our users.

• Compliance purposes. We may use the information we collect (including Content you create) to enforce our Terms of Use and other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

• Deliver ads and other sponsored content. We use the information we collect, including information about your interests, actions and preferences, to select, personalize, and deliver ads, offers and other sponsored content.

• Send you push notifications. We may use the information we collect to send you push notifications.

• Other purposes. We may also use the information we collect for other purposes for which we provide notice at the time the information is collected.

HOW IS INFORMATION SHARED

• Other users. In the future, the Services may allow Users to send messages and share Content with one another.  However, at this time, messaging and direct sharing functionality is not currently supported on the PPL application. 

• Social networks. In the future, our services allow you to share links to your Content with social networking services, such as Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third-party platforms and your settings on that platform. We encourage you to review their privacy policies before sharing any information with them.

• Third-party integrations and Payment Services. Certain features you use through PPL are offered by third parties such as logging in or processing of payments with Google or Apple, or AI content creation engines like ChatGPT that facilitate Content creation from the various prompts that you enter during the Content creation process. Those features may include web pages optimized for the PPL Applications, etc. When you choose to make payments or use these third-party features, or other services that use, or are integrated with, our Services, those third parties (and other users of those third-party services) may be able to see things like your user profile and receive information about the Content that you create. These third parties may use this information (including prompts, usage data, IP Addresses etc.) as described in their privacy policies, which can include advertising and train their algorithms, models and AI products and services using machine learning. You understand and agree that the use of your information by these third parties will be governed by the privacy policies of these third-party platforms and your settings on that platform. We encourage you to review their privacy policies before sharing any information with them.

• Our service providers. We share the information we collect with third-party service providers that help operate our business. Examples include suppliers who host our data or provide customer service.

• Our related companies. We may share some or all of your information with our affiliated companies, subsidiaries, or joint ventures.

• Other PPL Applications. In furtherance of servicing and operating the PPL applications, your registration and account information and associated data will be shared and available across all PPL products that you are eligible to access.

• To protect PPL and its users, or for legal purposes. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) detect, prevent or address fraud or other illegal activity (b) respond to your requests; (c) comply with law enforcement requests and legal process, such as subpoenas, warrants, production orders, or similar instruments; or (d) protect your, our, or others’ rights, property, or safety, including when there is an emergency involving potential harm, loss of security or serious injury to people or threats of such emergencies. For the avoidance of doubt, we may disclose your information if you post any objectionable content on or through the Services.

• Merger, financing or sale. We may share your information with service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a merger, financing, acquisition, dissolution transaction, bankruptcy or proceeding involving the sale, transfer, or divestiture of all or a portion of our business or assets.

• Advertising partners. We work with third-party advertising partners to show you ads that we think may interest you. Please see the “USER CONTROLS” section below for information about how to opt-out of receiving interest-based ads from some of these partners.

• Consent. We may also share your information with your permission. 

USER CONTROLS

• Update your information. You can update your profile information through the PPL Applications settings.

• Delete your account. You can request to delete your account by emailing support@ppl.xyz. You should be aware that even if you delete your account, some of your information may still be available to other users through the PPL Applications and will not be deleted by us.

• Blocking and reporting users. You can block users or report users who are engaging in harmful or offensive conduct to us through the controls provided in the PPL Applications.

• Marketing and promotional communications. You may unsubscribe from emails in the footer of any marketing or promotional email. Please note that even if you opt-out of receiving marketing or promotional messages from us, you will continue to receive administrative messages from us.

• Interest-based advertising. We adhere to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. You may opt out of interest-based advertising as follows:

1. You may opt out of seeing interest-based ads from us or our third-party advertising partners on your desktop browser and/or mobile web browser by visiting the DAA at http://www.aboutads.info/choices/ or by visiting the Network Advertising Initiative (“NAI”) at http://www.networkadvertising.org/choices/.

2. You may opt out of seeing interest-based ads in the App by downloading the DAA’s AppChoices application, which is available at http://www.aboutads.info/appchoices.

3. Certain versions of your device’s operating system permit you to opt out of interest-based advertising. Please visit your device settings to limit such tracking.

Please note that when you opt out of interest-based ads, you will still see ads, but they will no longer be based on your interests or behavior.

SECURITY OF YOUR INFORMATION

We make reasonable efforts to protect your information by using safeguards designed to improve the security of the information we maintain. For example, Content files are protected with industry-standard encryption. Despite these efforts, you should know that we cannot guarantee the privacy or security of your information because we cannot fully eliminate the security risks associated with online transmissions.

INTERNATIONAL USERS

The PPL Applications and all of our data, including your Data, are hosted on servers in the United States. If you are using or accessing the Services from outside of the United States, your Data will be transferred to, processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain your Data through laws applicable in the United States. United States laws may not offer the same privacy protections as the law of your jurisdiction.

Personal information collected in the EU may be transferred to, and stored at, a destination outside of the EU and processed by employees operating outside of the EU who work for us, one of our business partners, or service providers. We utilize standard contract clauses (see https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087), rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States and other countries. When we transfer personal information across country borders, we will make sure there is a transfer mechanism in place to transfer the data in a manner consistent with that described this Privacy Policy.

For citizens of the European Union, you should know that PPL is a controller and a processor of your personal information. The legal basis for which we collect and use the information described above depends on what the information is and why we collected it. The four basis upon which we rely include:

• Contract. This means we need the information to perform our contract with you. For example, when you want to send a message through the application, we use information to carry out your request to transmit that message to its intended recipient.

• Legitimate Interests. This means we have a legitimate interest that does not outweigh your privacy rights. When we collect and process information based on our legitimate interests, we consider how we can accomplish what we need to in a way that is the least obtrusive on your privacy. For example, it is in our interest to protect your safety and security in the app, so we collect and use information that has been flagged by users or requested by law enforcement; to make sure you are satisfied with how the Services work, troubleshoot technical problems or develop new features, we collect and use information about how you and others use the Services; and to respond to your service inquiries, we collect and use information in that request and, if relevant to the inquiry, information about how you access and use the Services.

• Legal Obligations. We may need to use your personal information to comply with a law enforcement preservation request, subpoena, or other legal process or to protect the rights of other users.

• Consent. If we have no other legal basis for collecting or using your information, we will ask you for consent for a specific purpose. If we do, you have the right to withdraw consent at any time. Withdrawing your consent will not apply to any processing conducted in reliance on lawful processing bases other than consent.

EU Users' Rights

In addition to other rights detailed in the policy (such as requesting deletion, correction or updating of your personal information), EU citizens have certain rights regarding your personal information, including:

• Right to Object and Restrict Processing. You have the right to object to or restrict our use of your personal information for direct marketing purposes or under certain circumstances when the legal bases for using your information is based upon our legitimate interest. If you wish to object to our use of your information, you can send us a request to delete your account by emailing us at support@ppl.xyz. 

• Right to Erasure. You have the right to have your personal data erased and no longer processed. You can send us a request to delete your account by clicking here. Upon receiving the request, we will make a reasonable effort to delete your personal information from the app and from our internal network within a reasonable period of time as long as we are not obligated to preserve your information due to things like law enforcement preservation requests, subpoenas, investigations, litigation, or otherwise meet any of our other legal obligations. We may also retain depersonalized information after deletion.

• Data Portability. You can exercise your right to export your personal data by emailing support@ppl.xyz. 

• File a complaint. You have the right to complain to the data protection authority located in your Member State. To find contact details, click here.

CALIFORNIA USERS

If you are a California user, please refer to our California Resident Privacy Notice for additional information about the data we collect and your rights.

CHILDREN’S PRIVACY

We require users of PPL to be of legal age to form a binding contract (or if not, that the user received their parent’s or guardian’s permission to use the Services and have gotten their parent or guardian to agree to this Privacy Policy on their behalf).

We don’t knowingly collect personal information for the PPL Application from individuals under 13, and no part of our Services is directed to children under 13. 

If we learn that we have inadvertently collected the personal information of a child under 13 while using the PPL application, or we become aware that a user under the age of 13 has gained access to and used the PPL application and thereby shared personal information with us, we will take steps to delete the information as soon as possible. If you learn that a child under 13 has provided us with personal information in violation of this Privacy Policy, you may alert us at support@ppl.xyz. 

THIRD PARTIES

This Privacy Policy does not apply to services offered by other companies or individuals, including products or services that we link to or display on the Services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information to them.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time, and the updated version will be effective when posted. We encourage you to regularly check this page to review any changes we might make. If we make material changes to the Privacy Policy, we will notify you by posting an

announcement on our Services, or by sending you an email or other communication

CONTACT US

If you have any questions, comments, complaints or suggestions, please contact us at: 

PPL, Inc.

Attention: Privacy Office

Contact form: http://www.ppl.xyz/contact 

Email: support@ppl.xyz 

California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy at http://www.ppl.xyz/privacy.  It applies to individuals residing in California from whom we collect Personal Information as a business under California law.

The Table below describes how we process California consumers’ personal information (excluding our personnel), based on definitions laid out in the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this notice, 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 consumer or household, or as otherwise defined by the CCPA.

Personal Information does not include information that is: (1) lawfully made available from government records, (2) deidentified or aggregate information, or (3) otherwise excluded from the scope of the CCPA.

Not all of the items listed in the Table below are relevant to you. For example, we do not collect Social Security numbers from our users, but we may collect this data in the course of evaluating a job applicant.