Personal Data Protection Policy

This document was automatically translated from French.
In the event of any discrepancies between the translated version and the original French version, the French version shall prevail.

Last updated September 4, 2025

WeWard SAS

WeWard SAS, the data controller (hereinafter referred to as “WeWard SAS”), is a simplified joint-stock company with a share capital of €1,203.32, headquartered at 111 Avenue Victor Hugo, 75016 Paris, registered under SIRET number 85361417000035 in the Paris Trade and Companies Register. This personal data protection policy applies to the use of the WeWard Mobile Application (the “Mobile Application”), to access the Services we provide, and has the purpose of informing you about the collection, use and, more generally, the processing of your personal data. All capitalized terms not defined herein shall have the meaning attributed to them in the Terms and Conditions.

Please note that you must be of the legal age required to use the Services, in accordance with the applicable law in your country of residence. In particular, if you reside in a country of the European Economic Area, you must be at least 16 years old (or the minimum age allowed by your national law if it is lower — 15 years in France, for example) to be able to consent alone to the processing of your personal data.

1/ WeWard SAS collects and processes personal information electronically, including but not limited to your name, mobile phone number, email address, IP address, unique device identifiers and other identification identifiers, photographs and/or payment information. The legal basis for the processing is the performance of the contract (Terms and Conditions to which you have agreed) concluded between you and the Company.

More specifically:

Data Purposes
Email address, unique account identifiers, consents, your time zone, language, date of birth (optional) Allow access to the Service (create an account), authenticate users and enable proper use of the app. Know which time zone you are connected in (to reset your step counter from midnight). Translate texts according to your language.
Number of steps and geolocation data (optional) Count the user's steps, measure distance traveled, verify eligible physical activities, grant rewards, position the user on the map and display nearby Virtual Objects.
Number of consecutive days on the app Calculate and display the number of flames.
Number of consecutive days on the app, username, amount of XP, number of Wards, number of steps, number of flames Rank users within leagues, among friends, within championships and communities.
First name, last name, postal address, mobile phone Provide physical gifts (data transmitted to merchants who must deliver gifts), manage participation in sweepstakes, organize events, assist the delivery person in case of issues. Manage potential purchases.
IP address (city level) Provide the service by awarding points based on actions with partners or on the app.
Transaction history, earnings and virtual items Provide you with the history of your transactions, earnings and collections.
In the case of sign-in with Facebook Connect or Google: email address, first name, last name and profile picture from the Facebook or Google account Sign in to the service and complete the user profile.
Your identification data, including your email address, your activity in the app, the messages you send us, issues encountered, IP address Support, proper functioning of the app and compliance with our commitments, sending transactional emails.
Email address Sending emails about offers, challenges, promotions, events related to earning Wards.
User-generated data, such as photos, images, blog comments, questions, messages, original works and any other content or information you generate, transmit or make available on the Service, as well as associated metadata. Metadata includes information such as how, when, where and by whom the content was created, as well as formatting or modification information. Metadata also includes information you may add, or that may be added to your content, such as keywords, geographic or location data and other similar information. Service execution, proper functioning of the application and compliance with our commitments, management and animation of the WeWard community.

As part of the Services, we may provide you with a feature that allows you to search for friends using their phone number, first and last name, username or by using your Facebook and/or Google identifiers. If you so choose, you will be asked to authorize the WeWard Application to access your address book or certain information associated with your Facebook and/or Google account, such as your name, profile picture, gender and friend list. To the extent you consent, this information will be processed by us to identify your friends who use the Application or to allow you to invite friends to install the WeWard Application. WeWard SAS will never contact your friends who are not users of the platform directly.

2/ With your consent (legal basis), we will collect information about your location and physical activity in order to (i) personalize reward offers shown in the Application according to your profile and position, and (ii) offer you Virtual Objects to collect. You may enable and disable location using the settings of your mobile device operating system. However, when you disable this feature, you will only have access to limited features of the Application and, in particular, it will be technically impossible for us to collect information relating to your physical activity and location, which will prevent the tracking and/or conversion of your movements into Wards. You may nevertheless earn Wards by carrying out other actions (watching ads, making purchases, taking surveys, etc.).

With your consent, we also process:

Data Purposes
Data necessary for targeted advertising and campaign performance measurement: account creation date, number of Wards, country, age (if provided), advertising identifier (a phone identifier you can reset), app journey, clicks, IP address, web journey, device data (such as OS type and version, manufacturer and model, browser type and version, screen resolution, language settings), unique identifiers, email address. Data transferred by WeWard to advertising partners for ad targeting and performance measurement. The non-exhaustive list of partners includes: Facebook, Google, Ironsource, Adcolony, Vungle, Applovin, Meta Platforms, TikTok, Unity, Adjoe, Adjust…
Gender and date of birth (optional) Commercial targeting
Profile photograph (optional) User profile update

You may withdraw your consent at any time by contacting us at the email address shown at the end of this Policy or directly from the Mobile Application settings.

3/ As WeWard is a user community, each person may view certain information related to other users (number of steps, number of Wards, number of flames, amount of XP, Wards used to support associative projects, followers, CO2 saved). To avoid sharing these data, you can choose to make your account “private” in the application “settings” so that you are visible only to your followers and no longer to all users. You can also remove followers from your account at any time. Note that the amount of XP remains visible to other Users at all times even in private mode.

WeWard being present on social networks, exchanged messages and posts are also analyzed and taken into account for the proper operation of the company.

The legal basis for these processing activities is WeWard’s legitimate interest, it being specified that sending the requested photo is not mandatory and that refusal has no consequences.

Other processing activities are based on WeWard’s legitimate interest:

Data Purposes Company’s legitimate interest
Photograph of your identity document, your IBAN, your date of birth, your first and last name, and your address. Traceability and compliance with legal obligations in the case of a bank transfer To be able to answer banks’ questions as part of their legal obligations
Activity time and calories. Step data up to 12 months prior to app installation. Provide statistics on the person's physical activity to improve performance Provide additional content to users and allow the user to track performance. Measure the effectiveness of the app on user motivation and develop motivational factors.
IP address (city level) Conduct anonymous statistical studies on user geolocation Know the number of users in each city
Email address Communicate with you, including to inform you of new features, offers, challenges, promotions, updates to the Application, the Website, our Terms and Conditions and/or this Privacy Policy, invitations to events Provide additional information
Referral code, referee-referrer links, referee’s Wards balance. Propose referral offers Increase the number of users and improve user experience
History of places visited. Produce anonymous statistics Know the number of users in certain locations
Mobile device type and model, browser type, device identification, connection times and pages visited. Enable the Application to function, detect malfunctions to maintain quality and for general anonymous statistics Maintain Service quality and improve overall customer knowledge, R&D
Statistical data (number of views, number of clicks, revenue generated) by partner. Produce general statistics and improve partner knowledge. Transfer of this information to partner merchants in anonymous form. Improve knowledge and performance of the service, R&D. Allow partner merchants to evaluate WeWard’s performance
Device identifier, cheat score*, number of referees, all identifiers that have used the WeWard account, source apps for steps, all transactions with partners, number and amount of transfers, surveys and offerwall executed. Verify suspicious actions. Detect fraud (people using multiple IPs for one phone, abnormal number of referees, same IBAN for multiple accounts). Detect fraud
Email exchanges and bank transaction and reward distribution data. Access the history of your transactions and earnings Comply with contractual and regulatory obligations, including for internal audits. Keep evidence in case of disputes
Advertising identifier, app journey, impressions, clicks. Measure the effectiveness of marketing campaigns Conduct business, R&D
Purchases made on the Top Deals page Manage the Top Deals page and comply with accounting obligations Keep commercial documents
File of requests to exercise rights (access, objection, erasure…) Respond to your requests within the statutory time limit Fulfill our legal obligations (GDPR)

*An anti-cheating detection algorithm is used by WeWard as soon as a user requests a transfer, a gift card, requests to exchange their Wards for certain rewards or makes a donation. The objective is to detect suspicious behaviors (e.g.: artificial simulation of steps, artificial simulation of geolocation points, inconsistent ad viewing, falsification of purchases or actions carried out with our partners, falsification of referrals). If the user uses such methods, their account will be suspended. They will be informed in advance.

All of the data in the table above may be used by WeWard to comply with its contractual and regulatory obligations, including for internal audits and to retain evidence in the event of disputes.

4/ We work with third parties (local merchants, ad networks, analytics providers, affiliate platforms hereinafter “Partners”) who may provide us with or receive information about you.

Data Purposes
Responses to questionnaires from survey companies (data for which WeWard is not the data controller). WeWard only sends a customer ID to the partner. Only when the user answers a survey: data collected and processed by partner survey/research companies (for example Tap Research and Theoremreach as data controllers) for their own statistical study purposes. Questionnaires allowing the user to earn Wards. The non-exhaustive list of partners includes: Tap Research, InBrain, Pollfish…
Advertising identifier (a phone identifier you can reset) Provide rewards depending on videos watched (legal basis: performance of the contract). Offer targeted advertising (legal basis: consent): ID collected by WeWard and transferred to advertising partners for ad targeting. The non-exhaustive list of partners includes: Facebook, Ironsource, Adcolony, Vungle, Applovin…
Unique identifier of your account and purchases made with partners Provide rewards depending on videos watched and purchases made (legal basis: performance of the contract). Provide statistics on the person’s physical activity to improve performance.
Unique identifier (email, database identifier) and user sessions (pages visited, clicks…) Provide statistics on app usage (pages consulted, clicks, retention…) and enable support and engineers to resolve bugs to improve App performance, R&D. The non-exhaustive list of partners includes: Amplitude, Google (Firebase), Datadog…

Users for whom the law of their country of residence allows it can obtain the exhaustive list of these partners upon simple request to the email address indicated at the end of this Policy. They may obtain the identity of third parties to whom we have disclosed their personal data during the previous calendar year for direct marketing purposes.
Please note that we do not accept requests by telephone, postal mail or fax, and that we are not responsible for requests that are mislabelled, misaddressed or incomplete.

Recipients

Your personal data are processed by WeWard for the purposes described above and for this purpose WeWard may transfer your data to third parties in the following categories:

1/ To our processors: WeWard may use trusted partners acting as processors, in particular:

These third parties are contractually prohibited from using the personal data transmitted by WeWard except to provide the services for which they were engaged, and they are required to maintain the security and confidentiality of your information with protection equal to or greater than that offered by WeWard. A contract in accordance with Article 28 of the GDPR is concluded with each of our processors. You can obtain the list of these processors upon simple request to the email address indicated at the end of this Policy.

2/ To our Partners: WeWard strives to ensure that Services are offered transparently by the Partners with whom WeWard collaborates. For example, Partners may request confirmation from WeWard of a click to allow you to benefit from the offered Services (Rewards). WeWard ensures that Partners with access to your personal data only process them for the purposes described at the time of converting Wards into a Reward.

You can obtain additional information about these Partners by sending an email to the address indicated below.

3/ To our affiliated companies

In the context of providing our Services and for the purposes described in this Policy, we may share your personal data with our affiliates or group companies located within the European Economic Area or in the United States, where necessary to ensure continuity of our operations or to improve our Services. These transfers are governed in accordance with applicable law.

In any event: apart from the cases described above, WeWard will not disclose your personal data without notice except where required by applicable law, or where such disclosure is necessary to comply with law or regulation, judicial proceedings and/or an administrative or judicial order; to protect and defend the rights or property of the Company and/or to act in urgent circumstances to protect the personal safety of Application Users or third parties. WeWard will never transmit its Users’ list to third parties without your prior consent. Subject to your express prior agreement, WeWard partners may contact you directly or through us to offer commercial offers.

Security

WeWard processes your data confidentially and securely by implementing the necessary technical and organizational measures to preserve their security, confidentiality and integrity under optimal conditions.

Only persons strictly authorized by WeWard will have access to your data. No unauthorized third party may access them, except as required by law or collective bargaining obligations applicable to the data controller.

Security risk is inherent to any Internet- and information-related technology. We make every effort to ensure the security of personal data but cannot guarantee it.

Retention period

WeWard retains your personal data for the period necessary to provide the Services. Afterwards, data are kept in the active database for up to 7 days after account deletion, or after 24 months of inactivity (then 5 years in intermediate archiving), subject to legal and regulatory retention obligations.

Particular cases:

Data Retention
IP address The IP address is retained for the duration of the relationship. It is nevertheless deleted after 3 months of inactivity on the Application or 7 days after deletion of your account.
Information that you participated in a survey WeWard only retains the fact that you earned x Wards for a survey on a given day and time, and this for the duration of the relationship, 7 days after account deletion, and/or after 24 months of inactivity.
Facebook or Google username, Facebook or Google profile picture, gender and Facebook or Google friend list WeWard does not retain the friend list. You can remove the Facebook-Google/WeWard link from your Facebook/Google account. WeWard retains the link for the life of the account.
(Geo)location data Location data related to the collection of a virtual object are retained while your account is active, 7 days after account deletion, and/or after 24 months of inactivity. Geolocation points are not retained.
Identity document 1 month after uploading your identity document. The information that your identity document is validated is retained for the duration of the relationship, 7 days after account deletion, and/or after 24 months of inactivity.
Cheat score WeWard retains the anonymized cheat score after deleting your account.
Messages (content) 4 years
File of GDPR rights exercise requests 3 years from the end of the calendar year of your request. 1 month for a copy of your identity document if it was requested.

COOKIES / TRACKERS

Trackers are small text files (called "cookies" in English) placed on your device by your browser and/or the websites and applications you visit, including the site maintained by WeWard.

Mobile applications do not use cookies in the same way a website would. They use SDKs (software development kits).

Cookies and SDKs are mainly used to allow the site and application to function, or to function more efficiently, but also to provide information to partner site owners or to improve your user experience and to display personalized content or ads.

On the site www.wewardapp.com, we use only one functional cookie (Datadog) to detect malfunctions.

No cookie is set by third parties and WeWard does not use any advertising cookie on this site.

On the WeWard app, we use:

  • trackers necessary for the application to operate properly and improve your experience: trackers (Facebook Sign In, Apple Sign In, Google Sign In, Firebase) in order to recognize you when you arrive in the app and an “IPbase” tracker to identify your country and offer you an app version corresponding to your country and language (trackers necessary to provide a service you requested).

    We also use trackers (Firebase Crashlytics, Datadog) to detect application malfunctions.

  • The CodePush tracker to update the application which does not collect any personal data.

  • Trackers (Firebase) to manage the sending of notifications. You can disable notifications by going to your device settings.

  • Audience measurement trackers, not subject to consent (Amplitude and Firebase) and strictly necessary for the provision of the service (performance measurement, detection of navigation issues, optimization of technical performance or usability of the site, estimation of server capacity needs, analysis of content viewed), and which meet the exemption criteria from consent.

  • Advertising trackers (Ironsource, Applovin, Adcolony, Unity, A4G, Bidmachine, DT Exchange, Google AdMob, InMobi, Litfoff, Meta, Mintegral, Ogury, Verve, Pangle, Line, App Prizes, Ayet Studio, MyChips, Tapjoy, Bitlabs, CPX, PrimeSurvey, TapResearch, Theorem Reach) that collect data on the performance and exposure of advertising campaigns and deliver ads or surveys when you wish to obtain rewards.

  • Attribution trackers (Adjust and Facebook Ads) to analyze and steer acquisition campaigns. You can consult the Facebook ad settings and update your preferences at any time: https://www.facebook.com/help/568137493302217.

You can object to one or more trackers by sending your request to privacy@wewardapp.com.
You can contact WeWard at any time (privacy@wewardapp.com) to access the privacy policies related to these trackers.

Information collected by trackers is retained for a maximum of 6 months.

The processing of data from these cookies is carried out in accordance with our Cookie Policy which we invite you to consult.

Transfers of data outside the European Union

In providing the Services, WeWard may use analytics and notification providers whose headquarters or servers are located in countries that are not members of the European Union and which have not received an adequacy decision from the European Commission. These countries (USA, Madagascar, UK) provide a lower level of protection than the framework within the European Union. In such cases, WeWard ensures that the transfer is carried out in compliance with applicable law by taking all appropriate measures and within a legal, technical and operational framework designed to ensure the confidentiality and security of these data. These third parties commit, in this respect, to comply with the European Commission’s Standard Contractual Clauses.

You can obtain information about transfers by sending an email to the address indicated below.

Data deletion

You can delete your data at any time by going to the app, to the profile page, via the “delete my account” button or by sending an email to contact@wewardapp.com. These data will be archived in full within 7 days and deleted after 3 months.

Third-party sites and services

Our Services may contain links to websites, mobile apps or online services operated by third parties. We may also integrate some content or features from these third parties. These links or integrations do not constitute an endorsement or affiliation with these third parties.

We exercise no control over these third-party sites, apps or services and cannot be responsible for their personal data practices. We recommend that you review each third party’s privacy policy to understand how your personal data is processed.

Your rights

In accordance with applicable law, you have the right of access, objection, rectification, erasure of your personal data as well as the right to restrict processing, data portability and to decide the fate of your data in the event of death. Finally, with regard to profiling operations, you have the right to object to the use of such a process. You may also withdraw prior consent. However, the exercise of certain of these rights (objecting to profiling, withdrawing consent to geolocation) may make it impossible for WeWard to provide you access to the Application or the use of all or part of the Services.

These rights may be exercised by contacting us at privacy@wewardapp.com. In addition, please note that you can exercise some of these rights directly via your account settings (delete documents, delete optionally requested information and even general deletion of your account). You can remove the Facebook-Google/WeWard link from your Facebook/Google account.

You can unsubscribe from marketing emails by following the unsubscribe instructions at the bottom of those emails, or by contacting us. Please note that if you choose not to receive marketing emails, you may still receive service-related or other non-commercial communications.

Advertising choices. In some cases you can limit the use of your information for targeted advertising by setting the following options:

  • Browser settings. You can change your web browser settings to block third-party cookies.

  • Privacy-focused browsers or extensions. You can use privacy-focused browsers and/or extensions (plugins) that block ad tracking technologies.

  • Platform settings. Some platforms like Google and Facebook offer options to opt out of targeted advertising, accessible at:

  • Industry opt-out tools. You can also choose not to receive targeted advertising from companies participating in the following opt-out programs:

  • Mobile settings. You can configure your mobile device settings to limit the use of your device advertising identifier for targeted advertising purposes.

Please note that these opt-out settings must be applied separately on each device and browser you use.
We cannot guarantee that the companies we work with participate in the opt-out programs mentioned above.

Do Not Track. Some web browsers can be configured to send “Do Not Track” signals to the online services you visit. Currently, we do not respond to these “Do Not Track” signals. To learn more about “Do Not Track”, please consult your local authorities’ websites (for the US: http://www.allaboutdnt.com)

If you are not satisfied, you have the right to lodge a complaint with your local data protection authority, which you can find by following this link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_fr

For France, WeWard’s lead supervisory authority:
Commission Nationale de l’Informatique et des Libertés (CNIL)
3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
Tel.: +33 1 53 73 22 22

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect changes in our practices, our Services or legal requirements. In the event of a substantial change affecting your rights or requiring your consent, you will be informed by appropriate means (for example, an in-app notification or email) and, if necessary, we will request your consent again.

The updated version of the Privacy Policy will be published on our Services with the updated revision date. We invite you to review this Policy regularly to learn about any changes.

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