Privacy Policy

Effective as of 02/03/2023

This Privacy Policy describes how WeWard SAS (“WeWard”, “we”, “us” or “our”) handles personal information that we collect through our digital and online properties or services that link to this Privacy Policy, including as applicable, our website, mobile applications, social media pages, marketing and advertising activities, events and other activities described in this Privacy Policy (collectively, the “Service”).

Index

• Personal information we collect
• How we use your personal information
• How we share your personal information
• How long we keep your personal information
• Your choices
• Other sites and services
• Security
• International data transfer
• Children
• Changes to this Privacy Policy
• How to contact us
  

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• User contact data, such as your name, phone number, email address, and postal address.
• Account data, such as the username, profile picture, links to your profiles on social networks, preferences, place of birth, nationality, date of birth/age, height, weight, gender, photograph of your government-issued identification, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.  
• Exercise data, such as the number of steps taken, step history, distance travelled, activity time and calories, and verifying eligible physical activities.
• Communications data based on our exchanges with you, including when you contact us through the Service, e-mail, social media, or otherwise.
• Research data, such as your responses to surveys that we might ask you to complete for research purposes related to our business.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Transactional data, such as information relating to or needed to complete your purchases on or through the Service, including order numbers and transaction and earnings history.
• User-generated content data, such as photos, images, blog comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Payment data needed to complete transactions, including payment card information or bank account and routing number.
• Promotion data, such as such as photographs of receipts for purchases made in the recommended locations, shop concerned, date of purchase, items, purchase amount, amount of the reward to be rewarded, and other information you share when you enter a competition, promotion or complete a survey.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Note on Apple HealthKit Data

You can choose to connect and share your HealthKit information with WeWard. The information you provide to HealthKit is then governed by the Apple Terms and Conditions and Privacy Policy. The unique information you choose to send from HealthKit is not used by WeWard for marketing and advertising or transferred by WeWard to third parties for marketing and advertising.

Note on Health Connect

You can choose to connect and share Health Connect information with WeWard. This imported data may include fitness activities, number of steps/distance traveled, calories burned, and floors climbed. We will process this data in order to provide you with App functionality and features. Importing this data is subject to the Google Health Connect privacy policies and terms.

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Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, location information and other publicly available sources.
• Data providers, such as information services and data licensors that provide demographic and other information.
• Marketing partners, such as joint marketing partners and event co-sponsors.
• Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, geolocation, unique device identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), application’s version, time zone and general location information such as city, state or general geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails, advertisements, push notifications or clicked links within them.
• Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails or advertisements.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites or mobile apps store on user devices and that allow web servers to record users’ web or mobile browsing activities and remember their submissions, preferences, and login status as they navigate. Cookies used on our Service include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide, operate and improve the Service and our business;
• personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• establish and maintain your user account on the Service;
• enable security features of the Service, such as by sending you security links via email, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events in which you participate;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Health and Exercice data (Healthkit / Google Fit) We use this data to verify your physical movement and issue rewards on the basis of this verified data. Our legal basis for processing this data is based on consent and performance of a contract.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We, our service providers and our third-party partners may collect and use your personal information for marketing purposes:

• Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Advertising. To help us and our third-party advertising partners collect information about how you use the Service and other online services over time, which we and our partners use to show you ads on other online services they believe will interest you and measure how the ads perform.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our communications. For example, we use Amplitude for this purpose. To provide this service, Amplitude may collect certain information about you from your mobile device, including your email address, in accordance with its privacy policy https://amplitude.com/privacy

Events, promotions and contests. We may use your personal information to:

• administer promotions and contests;
• communicate with you about promotions or contests in which you participate; and
• contact or market to you after collecting your personal information at an event.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

Affiliates. Our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as maintenance services, database management, hosting, information technology, customer support, email delivery, consumer research, marketing, and website and mobile app analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Banking partner. Any bank information you share with the Service is collected and processed directly by our banking partner, Brex. Brex may use your bank information in accordance with its privacy policy, https://www.brex.com/legal/privacy.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.

Business and marketing partners. Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you link your Service account to a social media or other third-party service (e.g., Facebook or Google), we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in WeWard (including, in connection with a bankruptcy or similar proceedings).

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How long we keep your personal information

Data Retention, your personal data will be kept only for as long as is necessary to fulfil the purposes set out in this policy, for as long as we are required to do so by law or any regulatory obligation. Then, the data is kept in our database for a maximum of 7 days after the account is deleted, or after 24 months of inactivity.

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Your choices

In this section, we describe the choices available to you.

Data Deletion. You can delete your data at any time by opening the app, navigating to your profile settings, and selecting the “Delete my account” button. Alternatively, you can send an email to contact@wewardapp.com. Your data will be fully deleted within 7 days.

Access or update your information. If you have registered for an account with us through the Service, you may review, update, correct, or delete certain information in your registration profile on the mobile app or by contacting us.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:

• Google: https://adssettings.google.com/
• Facebook: https://www.facebook.com/about/ads

• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:

• Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp.
• Digital Advertising Alliance: optout.aboutads.info.  

• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

California Shine the Light Law. California residents may send us requests to privacy@wewardapp.com for identification of third parties to whom we have disclosed your personal information during the preceding calendar year for such third parties’ direct-marketing purposes. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the France and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children  

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

To exercise your choices or if you have questions about this Privacy Policy or our privacy practices, please contact us at privacy@wewardapp.com.

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