PRIVACY POLICY Last updated: January 05, 2026 This Privacy Notice for JCODE LLC DBA (doing business as Clinksoft) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you: Download and use our mobile application (Tipsy - Wine App), or any other application of ours that links to this Privacy Notice. Engage with us in other related ways, including any marketing or events. Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at j@jcode.io. SUMMARY OF KEY POINTS What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the choices you make, and the features you use. Do we process any sensitive personal information? We do not process sensitive personal information (e.g., racial/ethnic origin, sexual orientation, religious beliefs). Do we collect any information from third parties? We do not collect any information from third parties. How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties, such as during business transfers. How do we keep your information safe? We have organizational and technical processes in place to protect your personal information, though no electronic transmission is 100% secure. What are your rights? Depending on your location, you may have certain rights regarding your personal information. How do you exercise your rights? The easiest way to exercise your rights is by visiting http://www.jcode.io or by contacting us. 1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us, or when you contact us. Sensitive Information: We do not process sensitive information. Application Data: If you use our application, we may request access to your device's camera. If you wish to change our access or permissions, you may do so in your device's settings. Push Notifications: We may request to send you push notifications regarding your account or certain features. You can turn these off in your device's settings. 2. HOW DO WE PROCESS YOUR INFORMATION? We process your personal information for a variety of reasons, including: To facilitate account creation and authentication. To save or protect an individual's vital interest (e.g., to prevent harm). We only process information for other purposes with your prior explicit consent. 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? We only process your personal information when we have a valid legal reason, such as: Consent: You have given us permission for a specific purpose. Legal Obligations: To comply with law enforcement or regulatory agencies. Vital Interests: To protect your safety or the safety of others. 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? We may share your information in the following situations: Business Transfers: In connection with any merger, sale of assets, financing, or acquisition of our business. 5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS? Yes, we offer products, features, or tools powered by artificial intelligence (AI Products). AI Service Providers: We use third-party providers, including OpenAI. Your input and personal information will be shared with these providers to enable the AI functions. Functions: Our AI Products are designed for AI applications. 6. HOW LONG DO WE KEEP YOUR INFORMATION? We keep your personal information for as long as it is necessary for the purposes set out in this notice (e.g., as long as you have an account with us), unless a longer period is required by law. 7. HOW DO WE KEEP YOUR INFORMATION SAFE? We have implemented technical and organizational security measures. However, transmission to and from our Services is at your own risk; you should only access the Services within a secure environment. 8. DO WE COLLECT INFORMATION FROM MINORS? We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn we have collected data from a minor, we will deactivate the account and delete the data. 9. WHAT ARE YOUR PRIVACY RIGHTS? In regions like the EEA, UK, Switzerland, and Canada, you have rights to access, rectify, or erase your data, and the right to data portability. You can withdraw your consent at any time. 10. CONTROLS FOR DO-NOT-TRACK FEATURES We do not currently respond to Do-Not-Track (DNT) browser signals as there is no uniform technology standard for doing so. 11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? Residents of states like California, Colorado, Virginia, and others have specific rights to: Know if we are processing your data. Access, correct, or delete your data. Obtain a copy of your data. Opt out of targeted advertising or the sale of personal data. Categories of Personal Information Collected (Preceding 12 Months): Identifiers: No. California Customer Records: No. Protected Classifications: No. Commercial Information: No. Biometric Information: No. Internet Activity: No. Geolocation Data: No. Audio/Sensory Data: No. Professional/Employment Information: No. Education Information: No. Inferences: No. Sensitive Personal Information: No. 12. DO WE MAKE UPDATES TO THIS NOTICE? Yes, we will update this notice as necessary to stay compliant with relevant laws. The "Revised" date at the top will indicate when it was last changed. 13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? If you have questions, email us at support@jcode.io or contact us by post: JCODE LLC DBA 5221 Bayshore Blvd, Apt 53 Tampa, FL 33611 United States 14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? Based on applicable laws, you may have the right to request access to, change, or delete your personal information. To do so, visit: http://www.jcode.io.