PRIVACY POLICY

Last update: 19 May 2023

	1. WHO ARE WE? This application (the "App") has been developed and is operated by MWM, a French simplified joint stock company registered in the Nanterre Trades and Companies Register under number 513 627 299 with its headquarters located 54, Avenue du Général Leclerc, 92100, Boulogne-Billancourt, France, (hereinafter “MWM”). In this context and except mentioned otherwise, MWM is determining the purposes and means of personal data processing (acting as “Data Controller” in accordance with the GDPR or “Business” in accordance with the CCPA). If you have any question or request, feel free to contact us by email at contact@mwm.io. If you wish to contact our data protection officer (DPO) regarding the handling of your personal data and/or to exercise your rights, feel free to contact us at dpo@mwm.io and detail your request.
	2. WHAT IS THIS DOCUMENT? MWM is very mindful and committed to respect your private life, the security and the confidentiality of personal data relating to you which is defined by the regulation applicable to you as “Personal Data”. This privacy policy is intended to inform you of how your Personal Data are collected, stored, used and processed by MWM (as Data Controller) and its partners when you use the App and related services (“Services”, including “Premium Services” which are paid services available on subscription). MWM undertakes to process your Personal Data in accordance with the applicable laws and regulations, including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data  (“GDPR”),  the California Consumer Privacy Act of 2018 (“CCPA”) (hereinafter the “Applicable Regulations”). Please note that MWM can amend or update this privacy policy at any time. In such case, you may be informed by a push notification or email notification under certain circumstances and/or you can access our privacy policy via the application at any time. We encourage you to regularly check for potential updates. The "Last Update" legend at the top of this page indicates when this privacy policy was last revised and the amended version will be effective as of the date it is published.
	3. WHAT PERSONAL DATA ARE COLLECTED, BY WHOM AND WHAT FOR? MWM and/or MWM’s partners process your Personal Data in the situations, for the purposes and on the legal grounds set out below. Please note that not all of the information detailed below may not always be considered as Personal Data in your jurisdiction. 3.1 Personal Data collected when you download the App Type of Personal Data collected: When you download the App, MWM might collect the time, date and install source of your download. When you start using our App and Services, the user is anonymously associated with a randomly generated user ID which does not allow identification of the final user (“User ID”). Reasons: To track installs and attribution. Legal Ground for collecting and processing these Personal Data: our legitimate interests. 3.2 Personal Data collected when you use the App Type of Personal Data collected:  MWM may collect Data limited to: - The apps you are using - Your IP address - Your mobile device identifiers, such as Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings) - Technical information about the device you use and your connection (user agent, type of connection, timestamp) - Data in relation to your preferences and activities on the App, and notably your settings in the App, the way in which you interact with our applications (e.g., how and when you use our applications) and with the advertising served in our applications (e.g., number of ads served, potential clicks) - The content you may upload onto the App which may contain Personal Data Reasons: To let you use the App and get the best experience, better organize and manage the content presented on the App, to run analytics and understand how users interact with our product and services in order to continuously improve them, and to serve advertising tailored to the preference and interests of our users. Legal Ground for collecting and processing these Personal Data: our legitimate interest, your express consent. 3.3 Personal Data collected when you subscribe to Premium Services in relation to the App Premium Services as paid services require the collection and processing of specific personal data but please note that MWM does not collect or process any Personal Data in relation to payment (such as credit card number) for the Premium Services, other than Personal Data collected for the regular Services. They will only be processed for the payment or subscription you ordered by Google or Apple who operate the distribution platform that consists of any mobile application store. This processing is necessary for entering into and executing a contract with you. Type of Personal Data collected: In case of in-app purchases, including subscriptions, your card details and invoice information (name, surname and postal address) are collected and processed by Google or Apple, depending on the mobile application store you use. Google or Apple act as sole data controller for these Personal Data and do not share these Personal Data with MWM. 3.4 Personal Data collected when you contact MWM through or in relation to the App Type of Personal Data collected: While you are using the App, you may contact MWM for various reasons. While doing so, MWM might collect Personal Data such as your email address, your name, surname, and any other information you include in your messages.  Reason: To process and answer your questions and claims. Legal Ground for collecting and processing these Personal Data: our legitimate interests, contract.
	4. PERSONALIZED ADVERTISING When you have opted for a version of the App with Ads, when such version is available, please note that MWM monetizes its ads inventory by allowing advertising partners (most of the time MWM’s advertising partners are third-party mobile application providers) to serve personalized advertising to users. Type of Personal Data collected:  While you use the App and, MWM may collect data limited to: - The apps you are using - Your IP address - Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings) - Technical information about the device you use and your connection (user agent, type of connection, timestamp) - Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks). Reasons: To help advertisers promote their products and services and improve our own advertising services. Legal Ground for collecting and processing these Personal Data: In order to deliver such services for its partners, MWM can receive and process data based on your consent and for different legitimate purposes and interests: ● To help advertiser partners promote their products and services: MWM ads services help advertisers promote their products and services to an audience that has demonstrated interests in similar products and services and allow them to optimize their marketing spends. ● To improve MWM Ads services: MWM is committed to constantly improve the services delivered to its publishers and advertisers. To do so, MWM Ads services processes the data listed above in a way that notably allows it to better understand how users interact with the ads of our advertiser partners and optimize their user experience. For your information, you have the ability to opt-out of personalised advertising on mobile applications by checking the privacy settings of your device. Apple Devices ● If you have iOS 14 or more recent OS o Open Settings o Select Privacy & Security o Select Apple Advertising o Turn off ‘Personalized Ads’ ● If you have iOS 13 or older OS o Open Settings o Select Privacy o Select Advertising o Enable ‘Limit Ad Tracking’ Android Devices ● Open Settings ● Select Google ● Select Ads ● Enable ‘Opt out of Ads Personalization’   Please note that opting out does not mean that you will stop seeing advertisements when using our Services, but that third-party advertising networks will show you contextual advertisements which are not tailored to your interests.
	5. WITH WHOM MAY WE SHARE YOUR PERSONAL DATA OR WHO MAY ACCESS YOUR PERSONAL DATA? The first time you connect on the App, a pop up will be displayed, informing you that if you give your consent, your advertising ID and other data, such as location data, and other demographic and interest data about you will be collected and transmitted to our Ad partners and Analytics partners for the purpose of providing you with a personalized advertising experience and analytics purpose. You are free to refuse or agree to such processing. When you consent to the collection of data for advertising and analytics purpose, we may share some of the data listed above with the following categories of recipients: ● Analytics partners: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDK and therefore act as independent controller (and not processor on MWM’s account) with respect to the Personal Data they collect on their own without MWM sharing any. ● Ad partners: that allow us to monetize the ad inventory of the App and provide users with free products and services. Please note that those partners usually collect data via their own tools (software development kits or “SDK”) and are therefore independent controller (and not processor on MWM’s account) with respect to the Personal Data they collect on their own without MWM sharing any. ● Authorities: only to the extent we are obliged to by applicable laws and regulations. ● Service providers: technical, hosting or client support services providers ● External advisors: MWM may also need to share your Personal Data with its external advisors (lawyers, accountants, etc.) but such sharing will occur on a need-to-know basis. For further information, please, see our List of Partners Schedule and their own privacy policies. We may update it from time to time, so you understand who we partner with to provide you our Services.
	6. WHAT IF WE TRANSFER YOUR PERSONAL DATA TO THIRD COUNTRIES?  Our Services are global by nature and your Personal Data can therefore be transferred and processed in countries other than your country of residency with different data protection laws being applicable. For instance, for users based in the European Economic Area (“EEA”), MWM may transfer personal data to countries outside the EEA. In any case, such data transfers are always based on appropriate safeguards in accordance with Applicable Regulations, including (a) the standard contractual clauses developed by the European Commission; (b) the decisions of adequacy of the European Commission; or (c) binding corporate rules.
	7. HOW LONG DO WE STORE YOUR PERSONAL DATA FOR? MWM shall store your Personal Data for any length of time required for your use of the App. Furthermore, if you remain inactive for a period of 3 years after the final user action, MWM may send you an email to inform you of the deletion of your account. You are hereby informed that MWM reserves the right to store your Personal Data in its temporary archives where strictly necessary to defend its rights in the event of a dispute, for the applicable limitation period. Except for any legal obligation that sets a longer data retention period, at the end of these periods, the personal data processed will be deleted.
	8. HOW DO WE PROTECT YOUR PERSONAL DATA? Your Personal Data may be processed, as described in this privacy policy, through both automated and manual procedures and may be stored at MWM premises and on our service providers’ servers. MWM implements technical, organisational, and security safeguards to reduce the risks of damage, loss, improper use and alteration of your personal data, such as but not limited to : access limitation, use of firewalls, data encryption and de-identification/anonymization procedures.  Please note that ensuring your Personal Data security requires also that you take appropriate measures when using a device or network to communicate with us or use our App. If you want to avoid any risk, you should not provide any personal data.
	9. HOW CAN YOU EXERCISE YOUR RIGHTS? In accordance with the Applicable Regulations, you have the rights to access, rectify your Personal Data as collected and have them deleted. Under the conditions of the Applicable Regulations, you also benefit from the rights to request the limitation of the processing, the portability of your Personal Data, and the right to object to processing for reasons pertaining to your personal situation when the processing is based on MWM’s legitimate interest. You can also communicate instructions about the fate of your Personal Data in the event of your death. You can also, at any time, and without reason, object to the processing of your Personal Data for the purposes of direct marketing. You can exercise these rights with MWM by sending your request accompanied by a copy of an identity document by email to the following email address: privacy@mwm.io or by mail, writing to the following address: MWM, 54, Avenue du Général Leclerc, 92100, Boulogne Billancourt, France. In any case, you may, at any time, submit a claim to the competent national authority (depending on your place of residence).
	10. SPECIFICS 10.1 NO PERSONAL DATA RELATED TO CHILDREN COLLECTED Please note that our Services are exclusively designed for individuals aged 16 and above. Therefore, we do not intentionally collect Personal Data from children under the age of 16. If you suspect that we have obtained personal data from children below 16 years old, please reach out to us at privacy@mwm.io. Shall such suspicion be true, we will take appropriate measures to erase such Personal Data and close the user’s account linked to an individual below 16 years old. 10.2 NO SALE OF PERSONAL DATA Please note that we do not sell our users’ Personal Data. This rule applies to all of our users independently of their country of residence. Consequently, our Californian users can be reassured on the fact they do not have to opt-out to ensure their Personal Data is not sold which is a requirement under the CCPA when a business sells their Personal Data.