Privacy policy | Kwooble

At REVELSON, we take the protection of your personal data very seriously. This is why we have developed a Privacy Policy to explain how we collect, use, and process your personal information, including user location data. We encourage you to take a few moments to read our Policy.

SCOPE OF PRIVACY POLICY

We have developed an app called KWOOBLE that enables you to visit cities in an immersive way. Based on your location, the interactive platform will provide you with riddles, historical curiosities, and practical tips to fully enjoy your surroundings. The use of the REVELSON website, the KWOOBLE website and KWOOBLE mobile app (hereafter referred to jointly as "Services") is subject to the collection of a limited amount of personal information. The collection and use of the data will be explained in more detail below.

DATA CONTROLLER

For the purposes of the General Data Protection Regulation ("GDPR"), REVELSON SAS is the data controller. REVELSON's legal registration is:

REVELSON SAS

4 Rue Valerien,

38170 Seyssinet-Pariset,

France

E-mail Address: contact@revelson.com

LEGAL BASES

In accordance with the French Data Protection Act and the GDPR, we may use and process your data only for one or more of the following reasons:

• You have given us your consent.

• A legal obligation compels us to use your data for a particular reason.

• It is necessary to perform the Terms of Service concluded with you.

• It is necessary to pursue our legitimate interests.

Please note that you still retain the right to withdraw your consent at any time and for whatever reason via the device or browser settings in accordance with the conditions set out in this Privacy Policy. However, withdrawal of consent will result in the inability to use the Services to their full capacity.

LEGITIMATE INTERESTS

At REVELSON, we care about providing you with the most innovative and suitable experience for your entertainment. As such, we have aligned the collection, use, and processing of your personal information to our legitimate interests, including:

• Developing and providing personalized gameplay experiences.

• Ensuring that the Services are secure and protected against criminal activity, fraud, spam, and abuse, etc.

WHAT DATA IS COLLECTED AND FOR WHAT PURPOSE?

Personal information

Personal information may include the following data as well as any other type of information that we specifically request to provide through the Services, such as:

• Name or nickname

• Age

• Profile picture

• Mobile phone number

• E-mail address

• Password

• Other data that you share voluntarily

In addition to the above personal information, the app also collects location data to enhance your user experience. This location data includes your real-time geographic location information obtained through background location tracking and other means. It allows us to offer personalized gameplay experiences, display available gameplays near you and indicate corresponding itineraries.

Please be aware that the app utilizes background location tracking to continue collecting your location data even when the app is not open or actively being used. This enables us to provide accurate information and deliver relevant content based on your real-world location.

Please note that when you consent to using the geolocation-based resources of our app, your location data (GPS) will be collected by Google Maps, a third-party service we rely on, to show the gameplay itinerary and provide travel instructions. We encourage you to review Google's Privacy Policy to understand how they handle the processing and collection of your personal information through Google Maps.

We want to emphasize that the collected location data is used solely within our app for the purposes mentioned above. We do not share this data with any third parties for advertising or marketing purposes.

If you wish to disable the collection of location data, you can adjust the location settings on your device. However, please note that disabling location tracking will disable the functionality and features available to you within the app.

We prioritize the security and confidentiality of your data and have implemented appropriate measures to protect your personal information. If you have any concerns or questions about the collection and use of your personal information, including location data, please feel free to contact us using the provided contact information in this Privacy Policy.

Please note that the registration interface may contain links to social media plug-ins that are not operated by us. Once you click on the third-party link and are redirected to another site, we no longer assume responsibility regarding the third party's policies or services. We, therefore, encourage you to consult the privacy policy of each third-party site you access.

We also use your personal information to communicate with you about the Services, REVELSON's products – if you have consented to it – and respond to any complaints or questions.

HOW WE COLLECT YOUR PERSONAL INFORMATION

You directly provide us with most of the data we collect. We collect data when you:

• Register online on our Services.

• Use or view our Services via your browser's cookies.

• Voluntarily provide us with your personal information.

Our Services may also automatically collect personal data, such as:

• The operating system ("OS") and browser type running on your device.

• The IP address of your computer, which may be used to obtain your geolocation.

• The URLs of your connections, including the access times and dates, and the content you access on the Services.

WHO RECEIVES YOUR PERSONAL INFORMATION?

Except for the geolocation data, which is processed by Google Maps solely for the purpose of providing you with a functional gameplay experience, the personal information collected from the use of the Services will be retained only by REVELSON to ensure an engaging and proper functioning gameplay. We will not disclose or transfer your data to third parties without your prior express consent.

The entirety of your personal information will be hosted in France, and no transfer will be made outside of the country.

DATA RETENTION PERIOD

We will retain your personal information only for as long as it is necessary to comply with legal, customer-related, and commercial requirements. We will periodically review the personal information you have provided, and when we realize that the retention of your data is no longer justified, we will securely remove it.

If you wish to close your user account with REVELSON, all the information provided for the creation or administration of the account will be deleted within three months of the closure of the user account. Please note that we retain the data collected about the use of the mobile app, including the gameplays you have completed and your preferences, in order to create statistics. However, we will ensure that the data does not contain references to your account anymore.

SECURITY AND CONFIDENTIALITY

REVELSON prioritizes the security and confidentiality of your data. This is why we have implemented appropriate technical and organizational measures to ensure a sufficient level of protection of your personal information. All measures are reviewed on an ongoing basis and kept up to date.

PROFILING

Your experience with REVELSON's mobile app depends largely on your locations of interest. In order to promote the most suitable gameplays for you, we may use the information collected for profiling purposes.

However, you retain the right to object to and delete the data processed for profiling purposes (see "Your rights and how to exercise them" section).

When you use our Services, we may collect information through the use of "Cookies." These are text files with small pieces of data that uniquely identify your computer or mobile phone. Through a web server, the Cookies are then stored on your hard drive. We use Cookies to improve your web browsing experience and to better understand your preferences.

You can manage Cookies by changing your web browser settings. Possible options include accepting no cookies at all, accepting them only on request, or deleting them after the closure of the browser session. Please note that if you block some or all Cookies, you may not be able to register, log in, or make full use of the Services.

The retention period for Cookies is 13 months after collection.

YOUR RIGHTS AND HOW TO EXERCISE THEM

If you wish to exercise one or more of the following rights, please make a request to REVELSON via:

E-mail Address:

dataprotection@kwooble.com or contact@revelson.com

Letter:

REVELSON SAS

4 Rue Valerien,

38170, Seyssinet-Pariset

France

We will respond to your request within one month of receipt.

The right of access to personal data:

Under Article 15 of the GDPR, you can request access to your personal data located in our databases. REVELSON is available to provide clarification regarding the processing, purposes, categories, and retention period of the personal information, as well as the recipients of the data and how to obtain a copy of such data. Please note that we may charge a small fee if you wish to obtain more than one copy.

The right to rectify your personal data:

In accordance with Article 16 of the GDPR, REVELSON's Services allow you to view and update the personal information that you have provided. If the personal data collected about you is inaccurate or incomplete, you can update or correct the information by accessing your personal account.

The right to have your personal data erased:

You may request that REVELSON delete your personal data, under the conditions set out in Article 17 of the GDPR. Please note that you should always reset your device before selling it to ensure that all your personal data are erased. In case your device is stolen, you can contact REVELSON to have your personal data erased.

The right to restrict processing of your personal data:

You may request that REVELSON restrict the processing of your personal data, in accordance with Article 18 of the GDPR.

The right to object to the processing of your personal data:

In accordance with Article 21 of the GDPR, you may object to the processing of your personal data for profiling and direct marketing purposes. To exercise this right, you may withdraw your consent to the processing of your data for profiling purposes by sending an email to dataprotection@kwooble.com. Once you withdraw your consent, you will no longer have access to REVELSON's Services.

The right to the portability of your data:

In accordance with Article 20 of the GDPR, you have the right to receive your personal information and transmit it to another data controller or request us to transmit your personal data to another controller, where technically feasible. The data processed by REVELSON for statistical purposes will be excluded.

We value your privacy and aim to handle your personal information in accordance with applicable data protection laws. If you have any questions, concerns, or requests regarding our Privacy Policy or the processing of your personal data, please don't hesitate to contact us using the provided contact information.

If you have further queries on this Privacy Policy, you can contact us at dataprotection@kwooble.com or contact@revelson.com.

[REVELSON keeps its Privacy Policy under regular review and places any updates on the Services. This Privacy Policy was last updated on June 17, 2023].