Last revised in April 2019

Dear Dappin user,

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Your privacy is for us our top priority. We respect your privacy and are transparent with the personal data we collect about you. That’s why we have put in place a privacy policy that explains to you in detail our use of your personal data. We want to make sure that you understand the personal data we collect, the reason we collect your data, how we use it and how long we keep it. We value your trust by giving us your personal data and we make sure that your data is secure with us.

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By downloading and using our app, you acknowledge that you have read and understood the privacy policy. If you do not want us to process your personal data, please contact us through the contact form on our website www.dappin-app.com

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1. Who collects your data: Data controller

The data is collected by JAFELO S.àr.l. registered under number B232313 RCS in Luxembourg, which owns the mobile application Dappin. The company is considered as data controller.

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2. Why do we collect your personal data: Purpose of treatment

The collecting and processing of your personal data is necessary for the performance of the contract to which you are party and for the purposes of the legitimate interests pursued by us. We collect your personal data for the following purposes:

• To give you the opportunity to enter in contract with us by creating an account in our app

• To give you the opportunity to use the app

• To enable us to monitor the performance of our app

• To carry out statistical and marketing analysis on the usage of our app

• To send you our newsletters

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3. What type of personal data do we collect: Data collection

Data we collect from you during registration by email address

• First name: We only ask for your first name and not your last name

• Email address: This information will not be shared with other users

• Date of birth: This information will not be shared with other users. Only the age deducted from the date of birth will be shown to other users

• Gender: This information is not compulsory

• Picture: We ask you to upload a picture during the sign up process

Data we collect from you during registration via Facebook

• First name: We only ask for your first name and not your last name

• Email address: This information will not be shared with other users

• Date of birth: This information will not be shared with other users. Only the age deducted from the date of birth will be shown to other users

• Picture: If the user decides to create his account via Facebook, the Facebook profile picture will be used. The user has the possibility in the profile section of the application to upload another picture.

Special notice about the photo uploaded: The photo must represent the user. The photo must not represent a celebrity (except if you the user is the celebrity), include a portrait of a minor, racist, offensive, illegal or sexual message, or contain personal information. By creating an account and becoming a user, the user accepts the publication of his/her photo in the application.

Location-based data

We ask you to activate location data on your device. If you authorize us to access and process your location data, we will send you location-based information: You will see on your homepage screen activities based on your geographical radius, as we are able to identify the distances with other users. We do not analyze the movements of our users. At no time will your exact location be shared with other users.

If you no longer wish to share with us your location data, you have the possibility to deactivate it in Settings – Privacy – Location Services.

You can use the app without giving us access to your location data. You have the possibility to choose in the profile section the location for which you want to see the activities.

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Communication data

The messages you send to other users will be stored encrypted on our servers at Amazon. Those messages are strictly private and will not be accessible to other users not involved in the exchange of messages, or to any third party.

Mobile data

We collect server logs that may include information such as IP addresses, operating system version, the day you access and use the app, user behavior, etc. We use this information for our internal analytical purposes.

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4. How long we keep your personal data: Data retention

We will retain your personal data as long as you have a Dappin account. Once the purpose for processing of your personal data does no longer exist, we will delete your personal data. However, it could be that we may keep your personal data for a limited period of time if necessary to comply with applicable legal, tax or accounting requirements.

5. How de we secure your personal data: Data security

We try to ensure the security of your personal data. In order to protect your personal data

• we invite you to protect your account with a strong password

• we have secured the databases on which your personal data is stored

• we limit the access to your personal data to those who have a legitimate purpose in handling your personal data

• personal data published by the user in the application is strictly invisible by non registered users

We undertake to provide the best efforts at our disposal to guarantee the optimal security of the personal data. However, the security measures put in place are never fully secure or error free, so we are careful in reviewing and updating the security measures on a regular basis.

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6. How you can exercise your rights: Data subject rights

You have the following rights:

• You may request access to your personal data and get a copy

• You may request modification of your personal data

• You may request deletion of your personal data. In case you have a Dappin account at the time of the request, we will inform you that your account and your messages associated will be permanently deleted

• You may request portability of your personal data

• You may opt-out from the newsletters sent by email by clicking on the “unsubscribe” button

• You have the right to complain to a data protection authority (in Luxembourg: the CNPD) about our collection and use of your personal data

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You can exercise those rights by sending a message through our contact form on www.dappin-app.com

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7. Who has access to your personal data: Data access

Only employees who have a purpose in processing your personal data have access to the databases on which the personal data is stored.

We may also contract with reliable subcontractors who may access, host and / or process some personal data of users on behalf of us, according to our instructions and in accordance with this privacy policy; and who guarantee the security and confidentiality of users’ personal data.

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8. Data transfer outside the EU

When registering, the user expressly agrees that his personal data may be transmitted to service providers located outside the European Union for the purpose of carrying out statistical studies and hosting the processed data by the application. If this is the case, we make sure that your personal data is transferred to countries which are deemed adequate by the European Commission or to countries for which we put in place appropriate safeguard to ensure that your personal data remains protected.

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We thank you for reading our Privacy Policy to the end.

• If at any point you feel that you are not happy about how we collect or use your personal data, please contact us immediately and we try to resolve the issue together.

With all the best,

Loïc and JF