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Participant Privacy Notice

PXLD AI Ltd | Version 1.0 | Updated 13 August 2026

This notice is for people who take part in our data collection sessions. If you are a user of PXLD Studio, our Product Privacy Policy applies to you instead.

1. Who we are

PXLD AI Ltd is the data controller for the information described here. • Company number 17365861 • Registered office: 46 Syon Lane, Isleworth, Middlesex, TW7 5NQ, United Kingdom • Contact: privacy@pxld.ai

2. What we collect

• Video, photographs, 360-degree captures, audio, depth or motion information, and environment and lighting captures, including your image, likeness, voice and movements • Footage you supply to us in connection with a data collection session • Your name, contact details, address, signature and information about whether a parent or legal guardian signs for you • Booking and payment records, session records and correspondence • A record of the release you signed, including the date and the version of this notice you were given

3. What we use it for, and our legal basis

Creating and maintaining datasets and training, testing, evaluating, developing and improving our generative AI and machine learning models, products and services. Our legal basis is our legitimate interests in developing and commercialising our technology and business. We assess those interests against your rights and you can ask us for a summary of that assessment. You have the right to object; see section 7. Using, reproducing, distributing, displaying, modifying, adapting and combining footage for research and development, research publications, demonstrations, technical materials, business development, investor and customer materials, marketing, promotion and other commercial activities connected with our technology, products and services. This may include public use of footage in which you are identifiable. Our legal basis is our legitimate interests in researching, demonstrating, promoting and commercialising our technology and business. We assess the nature and context of each use against your rights. Licensing, selling, assigning or otherwise transferring footage, or datasets containing footage, to third parties for AI or machine learning research, training, testing, evaluation, product development and commercialisation. Our legal basis is our legitimate interests, and those of the recipient, in developing and commercialising AI technology. Before sharing personal data for these purposes, we assess the proposed disclosure against your rights and put appropriate terms in place with the recipient. Keeping records of the releases we hold, so we can administer data collection sessions, show what permissions we received and defend legal claims. Our legal basis is our legitimate interests in administering the programme and keeping appropriate records. Our models are generative. They learn from footage of real people in order to produce images and video that may contain human figures. Footage may be modified, adapted or combined, and model outputs may include or be derived from human figures. We do not use participant footage for biometric identification or surveillance. We do not use your footage to identify you, and we do not attach your name to it in our datasets.

4. Participants under 18

If you are under 18, your parent or legal guardian must sign the image rights waiver and assignment on your behalf. We use your footage for the same purposes described in this notice and take your age into account when assessing our legitimate interests. We also process your parent or legal guardian's name, contact details, signature and confirmation of their authority to act for you. Our legal basis is our legitimate interests in administering the session, recording the permissions we receive and defending legal claims.

5. Who we share it with

• Our cloud hosting and IT providers, who act on our instructions • Our professional advisers, including lawyers and accountants • Actual or prospective investors, purchasers and partners, under confidentiality, as part of due diligence • A purchaser or successor if our business or assets are sold or transferred • Law enforcement, regulators or courts where we are legally required to disclose • Businesses, research organisations and technology developers to whom we license, sell, assign or otherwise transfer footage or datasets, including for AI training, research and product development Where we share footage or a dataset with a recipient for its own purposes, we use appropriate written terms covering the permitted purposes, security, confidentiality, onward disclosure and assistance with data-protection rights. A recipient acting as an independent controller is also responsible for complying with data protection law.

6. Where we store it, and for how long

We store footage on servers in the United Kingdom. If we transfer your personal data to a country not covered by UK adequacy regulations, we use an appropriate safeguard. This may include the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for more information or a copy of the relevant safeguard. We keep footage for as long as the dataset it belongs to is in active use, and we review this annually. We keep signed release forms for 7 years after that, so we can show we had permission. Footage removed from our systems may remain in secure backups for up to 90 days before being permanently overwritten.

7. Your rights

You have the right to: be told how we use your data; get a copy of it; have inaccurate data corrected; ask us to delete it; ask us to restrict how we use it; receive it in a portable format; and object to processing based on legitimate interests, including our use of your footage for training, marketing or third-party licensing. These rights depend on the circumstances and may be subject to legal exceptions. To exercise any of these rights, email privacy@pxld.ai. We will normally reply within one month. If you object or ask us to delete your footage, we will remove it from our datasets and stop using it in any future training, unless we have compelling legitimate grounds to continue or need it for legal claims. Where footage has already been used to train a model, we cannot remove its influence from that trained model. Where required by data protection law, we will also tell relevant recipients about your request and take reasonable steps to help give effect to it. The image rights waiver and assignment gives us contractual permissions and deals with intellectual property and performers' rights. Those contractual provisions are separate from the lawful bases described in this notice and do not remove your statutory data-protection rights. If you are unhappy with how we handle your data you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We would rather you raised it with us first so we can put it right.

8. Changes

This is version 1.0, updated 13 August 2026. It aligns this notice with the current image rights waiver and assignment. If we make material changes to how we use participant footage, we will update this notice and, where we can, tell you before the new use begins.

Version 1.0 | 13 August 2026

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