More Dash Ads Privacy Notice

1. When this Notice applies

This Notice applies when DRESSX handles personal information for its own purposes, including information about:

• More Dash Ads account owners and authorized users;
• people who visit or use the Platform;
• billing contacts and representatives of advertisers; and
• people who contact us about More Dash Ads.

An advertiser may also provide personal information about its customers, visitors, prospects, or other individuals for audience matching, conversion measurement, attribution, or related campaign services (“Ads Customer Data”). For Ads Customer Data, the advertiser normally decides why and how the information is used, and DRESSX processes it on the advertiser’s instructions. The DRESSX Ads Data Processing Addendum included in the More Dash Ads Platform Terms governs that processing.

2. Personal information we collect

Depending on how the Platform is used, we may collect:

• Account and business information: name, work email, phone number, company, role, login credentials, permissions, and verification information.
• Billing information: billing contact, billing address, tax information, payment status, transaction history, campaign spend, top-ups, refunds, chargebacks, and account balance. Our payment provider collects payment-card or bank details directly; DRESSX does not store full payment-card numbers when the provider collects them.
• Campaign information: advertiser identity, campaign settings, budgets, advertisements, creative materials, product or catalog data, destination URLs, approvals, and campaign communications.
• Audience and conversion information: first-party information supplied or authorized by an advertiser, which may include hashed email addresses or phone numbers, cookies or online identifiers, device or browser information, event data, transaction or purchase data, and related metadata.
• Platform and device information: IP address, approximate location derived from IP, browser and device type, operating system, pages or features used, dates and times, clicks, log records, cookie identifiers, and security events.
• Support and communications: messages, feedback, files, and other information provided when someone contacts us.
• Campaign reporting: information received from OpenAI or other authorized providers about campaign delivery, spend, impressions, clicks, conversions, and performance.

We collect this information from Platform users and advertisers, their authorized integrations and service providers, payment providers, OpenAI and other campaign partners, and automatically through the Platform.

3. How we use personal information

We use personal information to:

• create, authenticate, administer, and secure accounts;
• provide the Platform and carry out advertiser instructions;
• prepare, submit, manage, measure, report on, and optimize campaigns;
• transmit authorized campaign, audience, and conversion information to OpenAI and other approved providers;
• process recurring charges and top-ups, apply the 10% platform fee, issue invoices, reconcile accounts, and address payment disputes;
• provide support and service-related communications;
• detect fraud, misuse, security threats, and violations of law or our terms;
• analyze, maintain, troubleshoot, and improve the Platform;
• comply with legal, tax, accounting, regulatory, and contractual obligations; and
• send marketing communications where permitted, subject to applicable choices and consent requirements.

Where EEA, UK, or Swiss law applies, our legal bases are performance of a contract, compliance with law, our legitimate interests in operating and protecting the Platform and our business, and consent where required, including for certain cookies or marketing communications.

DRESSX does not use Ads Customer Data for its own advertising or to create unrelated profiles about individuals.

4. OpenAI and ChatGPT data

We share campaign information with OpenAI when needed to provide the advertising services selected by an advertiser.

Under the OpenAI Ad Tools Data Processing Addendum, OpenAI generally acts as a separate, independent controller for personal information processed through its covered ad tools. For processing that OpenAI defines as “Restricted Processing,” OpenAI acts as a processor. OpenAI’s handling of personal information is governed by its own Privacy Policy, Ad Tools Terms, and other applicable policies.

OpenAI states that advertisers do not receive ChatGPT conversations, chat history, memories, or personal details from OpenAI. Advertisers may, however, provide their own first-party audience or conversion information through approved ad tools, as described above.

Questions or requests concerning a ChatGPT account, ChatGPT ad personalization, or information controlled by OpenAI should be directed to OpenAI through its privacy controls or privacy contact channels.

5. How we disclose personal information

We may disclose personal information to:

• the advertiser and its authorized users;
• OpenAI, as described above;
• service providers, including payment, hosting, cloud, security, analytics, communications, customer-support, identity-resolution, catalog, and measurement providers;
• professional advisers, such as lawyers, auditors, insurers, and accountants;
• authorities or other parties when reasonably necessary to comply with law, protect rights or safety, investigate fraud or misuse, or enforce our agreements; and
• a buyer, investor, or successor in connection with a financing, merger, reorganization, sale, or similar corporate transaction.

DRESSX does not sell Ads Customer Data or share it for cross-context behavioral advertising.

6. Cookies and similar technologies

We and our providers use cookies and similar technologies to operate the Platform, remember preferences, protect accounts, understand usage, and, where permitted, support analytics and marketing.

Some technologies used on DRESSX or More Dash marketing pages may be treated as a “sale,” “sharing,” or targeted advertising under certain U.S. state laws. Where applicable, you can opt out through the Cookie Settings link in the website footer. We also honor legally required browser-based opt-out signals, such as Global Privacy Control, where they apply.

Advertisers are responsible for providing any notice and obtaining any consent required for pixels, cookies, conversion tools, or other tracking technologies on their own websites and apps.

7. Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Notice. The retention period depends on the type of information, the duration of the account or campaign, security and fraud-prevention needs, payment and reconciliation requirements, and applicable legal, tax, accounting, and dispute-resolution obligations.

Ads Customer Data is returned or deleted as described in the DRESSX Ads Data Processing Addendum. Protected backups may remain until they are deleted through the ordinary backup cycle. OpenAI and other independent controllers retain information under their own policies and legal obligations.

8. Security and international transfers

We use reasonable technical, organizational, and administrative measures designed to protect personal information. No system is completely secure, and we cannot guarantee absolute security.

DRESSX is based in the United States, and we and our providers may process information in the United States and other countries. Where required, we use recognized safeguards for international transfers, such as adequacy decisions, approved contractual clauses, or another lawful transfer mechanism.

9. Your privacy rights

Depending on where you live, you may have the right to request access to, correction of, deletion of, restriction of, or portability of your personal information; object to certain processing; withdraw consent; or opt out of sale, sharing, or targeted advertising. You may also have the right to appeal a decision concerning a request and to complain to your local data-protection authority. We will not discriminate against you for exercising a privacy right.

To make a request about information DRESSX controls, email info@dressx.com. U.S. residents may also use the DRESSX Consumer Rights Request Form. We may need to verify your identity and authority before completing a request.

If your request concerns Ads Customer Data that DRESSX processes for an advertiser, please contact that advertiser first. We will assist the advertiser as required by our data-processing obligations. If your request concerns information controlled by OpenAI, you may need to contact OpenAI directly.

10. Children and sensitive information

The Platform is a business service and is not intended for children. Advertisers must not provide data from child-directed services or information about people they know are under 18.

Advertisers must not provide sensitive personal information through audience, conversion, creative, tag, label, event-name, or similar fields. This includes health information, precise location, financial-account or payment-card details, government identifiers, passwords, biometric or genetic data, information about race or ethnicity, religion, political opinions, union membership, sexual orientation or behavior, citizenship or immigration status, or other information treated as sensitive by applicable law or OpenAI policy.

11. Changes to this Notice

We may update this Notice to reflect changes to the Platform, our practices, OpenAI’s advertising services, or applicable law. We will update the date above and provide additional notice when required by law.

12. Contact us

For privacy questions or requests, contact:

More Dash Inc. d/b/a DRESSX
1925 Century Park E, #1700
Los Angeles, CA 90067, United States
info@dressx.com