Meekle: PRIVACY POLICY

I. PRESENTATION

Meekle (“Meekle”, “Us”, “We”) respects your right to privacy and understands the importance of protecting your personal data (“Data“). We have adopted this privacy policy (the “Policy”) to explain how we collect, process, store, share, and protect the Data that you provide to Us or that we collect when you use our application (“Application”). We reserve the right to modify the terms of this Policy at any time and in our sole discretion. If we modify the Policy, we will publish the modifications on the home page of the Application so that you are fully informed. Any changes to the Policy will take effect thirty (30) days after its publication. Your continued use of our Services will constitute acceptance of the policy changes.

II. WHAT TYPE AND WHEN WE COLLECT YOUR DATA

On the Application

We collect the following kinds of data when you use the Application and our Services:

• Your contact data such as your full name, picture, email address, and password when you create your account.
• Your preferences such as the events you are interested in, the location, and time of events you wish to join.
• Your transaction data such as banking data and billing information when you subscribe to the Application to access premium features.
• The content, communications, and other information that you provide to Us when you use the Services including when you create or share content, and message or communicate with Us and others when you use the chat feature.
• The content, communications, and information that other people provide when they use the Services. This can include information about you, such as when they send a message to you or upload, sync, or import your contact information.

III. FOR WHICH PURPOSES AND LEGAL BASIS WE PROCESS YOUR DATA

On the Application

We process your Data in order to perform our contract with you and provide you with the Services including the following purposes:

• Create and manage your account in order for you to access and use the Services.
• Enable you to use the chat of the Application and share your content with other users.
• Manage the technical and customer support in order to assist you in solving your technical issues or customer issues in relation to fee claims.

We process your Data where necessary for the purposes of the legitimate interests pursued by Us including the following purposes:

• Improve the Application and Services by monitoring its use, in order to enhance user satisfaction.
• Personalize and enhance your user experience by contacting you to determine how we can improve our Services to better meet your needs.
• Send you promotional communications about our Services, in particular about new events and features.

We process your Data with your consent for the following purposes:

• Personalize, measure, and improve our advertisements.
• Place cookies on your browser in order to send you personalized advertising.
• Send you promotional communications about our other Products and Services or the Products and Services of our partners that you may be interested in.

We may also de-identify and/or aggregate and/or anonymize your data for various business purposes including product, service, and program development and improvement. De-identified data, in individual or aggregated form, may also be used for research purposes both internally by Meekle or with research partners and other third parties for the advancement of knowledge.

IV. COOKIES AND SIMILAR TECHNOLOGIES

When you use the Services, We may use cookies and other IT functions to collect your Data. Cookies are small text files that are automatically created by your browser and stored on your device when you connect to the Application and use the Services.

We use cookies which will not be saved on your device or which will only be saved on your device for as long as your browser is active (e.g. session cookies) or which will be saved on your device for a longer period (e.g. persistent cookies) for the following purposes: (i) the provision of the Services, (ii) your technical support and the enhancement of the Services, (iii) the improvement of your user experience, and (iv) to show you personalized advertising under your consent.

You have the choice to refuse to keep all or certain cookies in your browser or to disable all or certain cookies, after accepting their deposit on your browser, by configuring your settings. With regard to the use of advertising-related or personalization-related technologies, you can determine whether you consent or not to the use of cookies for marketing purposes.

V. HOW WE STORE YOUR DATA

We store your Data on storage facilities located within the United States for a period of time not exceeding what is necessary for the purposes for which your Data were collected and processed by Us and, in any event, in accordance with legal requirements.

Your Data will be stored in our active base for the time necessary to provide the Services and will be irreversibly deleted or anonymized by Us or archived in an intermediate database with limited access to it upon the termination of your subscription to the Application except for your contact data which will be kept in our active base for a period of time of 3 years in order to send you promotional communications on our Services upon your consent.

Your Data will be archived in an intermediate database with limited access when We are legally obliged to keep your Data longer such as for legal compliance, establishing the evidence of our rights or our contract with you, or for tax, accounting, or auditing purposes. In these cases, the duration of the storage processing will depend on the respective statutory limitation or retention periods and will be deleted after the relevant retention periods have expired.

VI. HOW WE KEEP YOUR DATA SECURED

We seek to safeguard the security of your Data and have implemented security measures consistent with accepted practices in the industry to protect your data and limit access to it.

In particular, we have implemented appropriate technical and organizational measures to minimize risks associated with data loss, misuse, unauthorized access, and unauthorized disclosure using encryption technology, such as Secure Sockets Layer (SSL) during data transport and at rest as well as physical access restrictions for our data centers and authorization controls for data access. However, despite our efforts to protect your Data, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your Data over the Internet will be intercepted. Unfortunately, we cannot guarantee the absolute security of your data, nor can we guarantee that the Data that you provide will not be intercepted while being transmitted to Us over the Internet. Therefore, we urge you to also take every precaution to protect your Data when you are on the Internet or using the Application.

VII. YOUR RIGHTS AS A DATA SUBJECT

You have the following rights on your Data and the data processing:

• Right to access to your Data;
• Right to rectify your inaccurate Data;
• Right to erase your Data unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims;
• Right to request the limitation of the processing of your Data to the extent that the accuracy of your Data is contested by you, the processing is unlawful, but you oppose the erasure of the personal data and request the limitation instead, We no longer need the data, but you need it to assert, exercise or defend legal claims or you have objected to the processing;
• Right to receive a copy of your Data in a structured electronic format or ask for the transfer of it to another controller, when technically possible;
• Right to object to your Data processing on grounds related to your particular situation including profile or for marketing purposes and to withdraw your consent at any time when the processing is based on consent;
• Right to delete your personal data. You can request erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.

You can exercise your rights by sending us a clear and specific request by email to [email protected]. Your request will be handled by our team within a reasonable delay from the date of its receipt and granted or refused subject to our legal obligations and within the limits of your rights.

You can also access, update and delete your Data at any time by logging into the Application and accessing your account settings.

VIII. HOW WE MANAGE THE PROTECTION OF CHILDREN

We are committed to protecting the privacy of children. Our Application and Services are not designed or intended for children and we do not knowingly collect data of users under 18 years old.

In any case, We request all users to confirm at the subscription to the Application and the Services that they are 18 years old or over and if not, We request the parent’s consent before authorizing the user to get access to the Application and the Services and never collect Data of children under 13 years old.

For users under 18 years old, We may limit how we collect, use, and store their Data meaning that We will be unable to authorize access to certain features to these users.

IX. WITH WHOM WE SHARE YOUR DATA

We share your Data with employees of our internal services such as the IT, development, or marketing services in order to provide you with the Services and assist you in your user experience.

We also share your Data with third parties including service providers acting on our behalf which may host your data and/or manage the payment of the subscription for Us and/or send you promotional communications about our Services and other products and/or detect, prevent or mitigate illegal activity and/or elaborate aggregate statistics.

In that case, we ensure that the service providers adhere to our Privacy Policy and comply with the same data protection obligations as the ones set out for Us. We also ensure that they provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the processing will meet the requirements of this Policy and more broadly of the applicable data protection and e-privacy regulations.

We also share your Data when you ask Us to chat with another user. Some of your data like your name and your picture are also visible by default to other users on the Application. We may share your data with some of our partners with your consent in order to send you offers on their products and services that We believe may have an interest for you.

We may be lastly required to disclose your Data to other competent authorities to exercise our rights conferred by law or to comply with the law or a court decision. Unless required by law or jurisdiction, We are not obligated to notify you of such data disclosures.

X. THIRD-PARTY LINKS

Our Application may contain third-party links or contents. Through these links or contents, you may be providing your Data to third parties for which We are not responsible for how it collects or uses your Data as well as we do not guarantee compliance with the same data protection practices as those of Meekle. We encourage you to read the privacy policies of every third-party website, application, and/or services that you visit or use including those third parties you interact with through our services.

In addition, we may rely on third-party advertisers, ad networks, and ad servers to promote our App. This includes Facebook, X (formerly Twitter), or Google. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about users’ behavior on this and other Apps to serve them interested-based (behavioral) advertising. No information you share within our Application will be shared with third-party advertisers. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

Contact Us

If you have any questions or concerns about our Privacy Policy, please contact us at [email protected]