Personal Data Protection Policy

This document was automatically translated from French. In the event of any discrepancies between the translated version and the original French version, the French version shall prevail.

Last updated March 3, 2026

WeWard SAS

WeWard SAS, data controller (hereinafter referred to as “WeWard SAS”) is a simplified joint-stock company with a share capital of €1,203.32, headquartered at 111 Avenue Victor Hugo 75016 Paris, registered under SIRET number 85361417000035 with the Paris Trade and Companies Register. This personal data protection policy applies to the use of the WeWard Mobile Application (the “Mobile Application”), to access the Services we provide, and aims to inform you about the collection, use and, more broadly, the processing of your personal data. All terms in capital letters not defined herein shall have the meaning given to them in the Terms of Use.

Please note that you must be of the legal age required to use the Services, in accordance with the applicable legislation in your country of residence. In particular, if you reside in a country of the European Economic Area, you must be at least 16 years old (or the minimum age allowed by your national legislation, if lower — 15 years in France, for example) to be able to give consent alone to the processing of your personal data.

1/ WeWard SAS collects and processes personal information electronically including, in particular, your name, your mobile phone number, your email address, your IP address, unique device identifiers and other identification identifiers, photographs and/or payment information. The legal basis for the processing lies in the performance of the contract (Terms of Use to which you have adhered) concluded between you and the Company.

More specifically:

Data Purposes
Email address, unique account-related identifiers, consents, your time zone, language, date of birth (optional) Allow login to the Service (creating an account), authenticate users and enable proper use of the app. Know which time zone you are connected to (to reset your step counter from midnight). Translate texts according to your language.
Number of steps and geolocation data (optional) Count the user's steps, estimate distance traveled, verify eligible physical activities, grant rewards, position the user on the map and display nearby Virtual Objects.
Number of consecutive days on the application Calculate and display the number of flames.
Number of consecutive days on the application, username, amount of XP, number of Wards, number of steps, number of flames Rank users within leagues, among their friends, within championships and communities.
Last name, first name, postal address, mobile phone Provide “physical” gifts (data transmitted to merchants who must deliver gifts), manage participation in sweepstakes, organize events, assist the delivery driver in case of issue. Manage any purchases.
IP address (city-level) Provide the service by assigning points based on actions at partners or in the application.
History of transactions, earnings and virtual items Provide you with the history of your transactions, earnings and collections.
In case of connection with the Facebook Connect or Google service: email address, first name, last name and profile picture from the Facebook or Google account Login to the service and completion of the user profile.
Your identification data, including your email address, your journey in the app, the messages you send us, problems encountered, IP address Support, correct functioning of the app and compliance with our commitments, sending transactional emails.
Email address Sending emails about offers, challenges, promotions, events related to earning Wards.
User-generated data, such as photos, images, blog comments, questions, messages, original works and any other content or information that you generate, transmit or make available on the Service, as well as the associated metadata. Metadata includes information about how, when, where and by whom content was created, as well as formatting or modification of that content. Metadata also includes information you may add, or that may be added to your content, such as keywords, geographic or location data and other similar information. Service execution, proper functioning of the application and compliance with our commitments, animation of the WeWard community.

Within the Services, we may provide you with a feature allowing you to search for friends using their phone number, name, first name, username or by using your Facebook and/or Google identifiers. If you wish, you will be invited to authorize the WeWard Application to access your address book or certain information associated with your Facebook and/or Google account, such as your name, profile picture, gender and friends list. To the extent you consent, this information will be processed by us to identify your friends who are users of the Application or to allow you to invite friends to install the WeWard Application. WeWard SAS will never directly contact your friends who are not users of the platform.

2/ With your consent (legal basis), we will collect information about your location and your physical activity in order to (i) personalize the visible reward offers in the Application based on your profile and position, (ii) offer you virtual items to collect. You can enable and disable location using the settings of your mobile device’s operating system. However, when you disable this feature, you will only have access to limited features of the Application and, in particular, it will be technically impossible for us to collect information related to your physical activity and your location, which will prevent tracking and/or converting your movements into Wards. You will still be able to earn Wards by performing other actions (watching ads, making purchases, participating in surveys, etc.).

With your consent, we also process:

Data Purposes
Data necessary for targeted advertising and campaign performance measurement: account creation date, number of Wards, country, age (if provided), Advertising Identifier (information from your phone that you can reset), in-app journey, clicks, IP address, web journey, device data (such as OS type and version, manufacturer and model, browser type and version, screen resolution, language settings), unique identifiers, IP address, email address. Data transferred by WeWard to advertising partners for advertising targeting and performance measurement. Non-exhaustive list of partners includes: Facebook, Google, Ironsource, Adcolony, Vungle, Applovin, Meta Platforms, TikTok, Unity, Adjoe, Adjust…
Gender and date of birth (optional) Commercial targeting.
Profile photo (optional) Updating the User profile.

You may withdraw your consent at any time by contacting us at the email address listed at the end of this Policy or directly from the settings of the Mobile Application.

3/ As WeWard is a user community, each person can view certain information related to other users (number of steps, number of Wards, number of flames, amount of XP, Wards used to support charitable projects, their followers, CO2 saved). To avoid sharing this data, you can choose to make your account “private” in the application “settings” so that you are visible only to your followers and not to all users. You can also remove followers from your account at any time. Note that the amount of XP remains visible to other Users at all times even in private mode.

As WeWard is present on social networks, exchanged messages and posts are also analyzed and taken into account for the proper operation of the company.

The legal basis for these processing operations is WeWard’s legitimate interest, it being specified that sending the requested photo is not mandatory and refusal has no consequence.

Other processing operations are based on WeWard’s legitimate interest:

Data Purposes Company’s legitimate interest
Photograph of your identity document, your IBAN, your date of birth, your last name, your first name and your address. Traceability and compliance with legal obligations in the event of a bank transfer Be able to respond to banks’ questions within the scope of their legal obligations
Activity time and calories. Step data up to 12 months before app installation. Provide statistics on the person’s physical activity to improve their performance Provide additional content to users and allow the user to track their performance. Measure the app’s effectiveness on user motivation and develop motivational factors.
IP address (city-level) Perform anonymous statistical studies on user geolocation Know the number of users in each city
Email address Communicate with you, in particular to inform you of news, offers, challenges, promotions, updates of the Application, the Website, our Terms of Use and/or this Privacy Policy, invitations to events Provide additional information
Referral code, referrer-referee links, referred user's Wards balance. Offer referral deals Increase the number of users and enhance the user experience
History of places visited. Carry out anonymous statistics Know the number of users in certain locations
Type and model of mobile device, browser type, device identification, connection times and pages visited, mobile OS and its version, as well as network connection type Enable the Application to function, detect malfunctions to maintain quality and for general anonymous statistics Maintain Service quality and improve general customer knowledge, R&D
Statistical data (number of views, number of clicks, revenue generated) per partner. Perform general statistics and improve knowledge of partners — transfer of this information to merchant partners in anonymous form Improve knowledge and service performance, R&D. Allow merchant partners to evaluate WeWard’s performance
Device identifier (plain and hashed), cheat score*, number of referees, all identifiers that have used the WeWard account, source step applications, all transactions with partners, number and amount of transfers, surveys and offerwall executed, as well as the hashed IP address Verification of suspicious actions. Fraud detection (people having multiple IPs for one phone, having an abnormal number of referees, having the same IBAN for several accounts) Detect fraud
Email exchanges and banking transaction and reward distribution data. Access to your transaction and earnings history Comply with contractual and regulatory obligations, including for internal audits. Preserve evidence in the event of litigation
Advertising identifier, in-app journey, impressions, clicks. Measure marketing campaign effectiveness Conduct business, R&D
Purchases made on the Top Deals page Manage the Top Deals page and fulfill accounting obligations Retain commercial documents
File of requests to exercise rights (right of access, objection, erasure...) Respond to your requests within the statutory deadline Comply with our legal obligations (GDPR)
Identification data (last name, first name), contact data (email address, billing and delivery addresses), technical data (IP address) and transactional data related to voucher purchases. Detection, prevention and securing of fraud related to payment operations carried out in connection with the purchase of vouchers on the application. Secure payment operations, protect WeWard’s economic interests, prevent payment fraud and limit risks of losses and payment disputes.

*An anti-cheat detection algorithm is used by WeWard whenever a user requests a transfer, a gift card, requests to exchange their Wards for certain gifts or makes a donation. The objective is to detect suspicious behaviors (e.g.: artificial simulation of steps, artificial simulation of geolocation points, incoherent ad viewing, falsification of purchases or actions performed with our partners, falsification of referrals). If the user uses such methods, their account will be suspended. They will be informed in advance.

All data from the table above may be used by WeWard to comply with its contractual and regulatory obligations, including for internal audits and to retain evidence in the event of litigation.

4/ We work with third parties (local merchants, advertising networks, analytics providers, affiliate platforms hereinafter “Partners”) who may provide us with or receive information about you.

Data Purposes
Responses to questionnaires from survey companies (data for which WeWard is not the data controller). WeWard only sends a customer ID to the partner. Only when the user responds to a survey: data collected and processed by partner survey companies (for example Tap Research and Theoremreach as data controllers) for their own statistical study purposes. Questionnaires that allow the user to earn Wards. Non-exhaustive list of partners includes: Tap Research, InBrain, Pollfish…
Advertising identifier (information from your phone that you can reset) Provide rewards based on videos watched (legal basis: performance of the contract). Offer targeted advertising (legal basis: consent): ID collected by WeWard and transferred to advertising partners for advertising targeting. Non-exhaustive list of partners includes: Facebook, Ironsource, Adcolony, Vungle, Applovin…
Unique account identifier and purchases made with partners Provide rewards based on videos watched and purchases made (legal basis: performance of the contract). Provide statistics on the person’s physical activity in order to improve their performance.
Unique identifier (email, database identifier) and user sessions (pages visited, clicks…) Provide statistics on application usage (pages viewed, clicks, retention…) and allow support and engineers to resolve bugs to improve Application performance, R&D. Non-exhaustive list of partners includes: Amplitude, Google (Firebase), Datadog…

Users for whom the law of their country of residence allows it can obtain the exhaustive list of these partners on simple request to the email address indicated at the end of this Policy. They may obtain the identity of the third parties to whom we disclosed their personal data during the previous calendar year for direct marketing purposes.
Please note that we do not accept requests by phone, postal mail or fax, and that we are not responsible for incorrectly labeled, misdirected or incomplete requests.

Recipients

Your personal data is processed by WeWard for the purposes described above and, to that end, WeWard may transfer your data to third parties belonging to the following categories:

1/ To our processors: WeWard may engage trusted partners acting as processors and, in particular:

These third parties are contractually prohibited from using the personal data transmitted by WeWard except to provide the services for which they were engaged, and they are required to maintain the security and confidentiality of your information with protection equal to or greater than that offered by WeWard. A contract in accordance with Article 28 of the GDPR is concluded with each of our processors. You can obtain the list of these processors on simple request to the email address indicated at the end of this Policy.

2/ To our Partners: WeWard seeks as far as possible to ensure that Services are offered transparently by the Partners with whom WeWard collaborates. For example, Partners may ask WeWard to obtain confirmation of a click in order to enable you to benefit from the offered Services (Rewards). They may also receive the information necessary to validate an action or a challenge, so that Wards can be allocated to you. WeWard may also transmit certain data to payment partners in order to fight fraud related to payment operations, notably when purchasing vouchers.
WeWard ensures that the data it transmits to Partners is communicated only for the purposes necessary to provide the Services. Any processing carried out beyond these purposes is exclusively the relationship between you and the Partner, in accordance with its privacy policy.

You can obtain additional information about these Partners by emailing the address indicated below.

3/ To our affiliated companies

In the context of providing our Services and for the purposes described in this Policy, we may share your personal data with our affiliated companies or companies within our group located within the European Economic Area or in the United States, when necessary to ensure continuity of operations or improve our Services. These transfers are governed in accordance with applicable law.

‍In any case: aside from the situations described above, WeWard will disclose your personal data, without prior notice, only if required by applicable law or if such disclosure is necessary to comply with applicable law or regulation, judicial proceedings and/or an administrative or judicial order; to protect and defend the rights or property of the Company and/or to act in urgent circumstances to protect the personal safety of Application Users or third parties. WeWard will never transfer its Users’ list to third parties without your prior consent. Subject to your express prior agreement, WeWard partners may contact you directly or through us to offer you commercial offers.

Security

WeWard processes your data in full confidentiality and security by implementing the technical and organizational measures necessary to optimally preserve their security, confidentiality and integrity.

Only persons strictly authorized by WeWard will have access to your data. No unauthorized third party may access them, except under a legal obligation or a union-related obligation incumbent on the data controller.

Security risk is inherent to any Internet and information-related technology. We make every effort to ensure the security of personal data but we cannot guarantee it.

Retention period

WeWard retains your personal data for the period necessary to provide the Services. Then, the data is kept in an active database for a maximum of 7 days after account deletion, or after 24 months of inactivity (then 5 years in intermediate archiving), subject to legal and regulatory retention obligations.

Specifics:

Data Retention
IP address The IP address is retained for the duration of the relationship. It is nevertheless deleted after 3 months of inactivity on the Application or 7 days after deletion of your account.
Information that you participated in a survey WeWard only keeps the fact that you earned X Wards for a survey on a given day and time, and this for the duration of the relationship, 7 days after account deletion, and/or after 24 months of inactivity.
Facebook or Google username, Facebook or Google profile photo, Facebook or Google gender and friends list WeWard does not retain the friends list. You can remove the Facebook-Google/WeWard link from your Facebook/Google account. WeWard keeps the link for the duration of the account’s existence.
(Geo)location data Location data related to the collection of a virtual object is retained while your account is active, 7 days after account deletion, and/or after 24 months of inactivity. Geolocation points are not retained.
Identity document 1 month after uploading your identity document. The information that your identity document is validated is kept for the duration of the relationship, 7 days after account deletion, and/or after 24 months of inactivity.
Cheat score WeWard retains the anonymized cheat score after deleting your account.
Messages (content) 4 years
File of requests to exercise GDPR rights 3 years from the end of the calendar year of your request. 1 month for the copy of your identity document if it was requested from you.

COOKIES/TRACKERS

Trackers are small text files (called “cookies” in English) placed on your terminal by your browser and/or the websites and applications you visit, including the site published by WeWard.

Mobile applications do not use cookies as a website would. They use SDKs (software development kits).

Cookies and SDKs are primarily used to enable the site and the application to function, or to function more efficiently, but also to provide information to partner site owners or to improve your user experience and to display personalized content or ads to you.

On the site www.wewardapp.com, we use only a functional cookie (Datadog) to detect malfunctions.

No cookie is placed by third parties and WeWard does not use any advertising cookie on this site.

On the WeWard app, we use:

  • trackers necessary for the application to function correctly and improve your experience: trackers (Facebook Sign In, Apple Sign In, Google Sign In, Firebase) to recognize you when you arrive on the application and an “IPbase” tracker to identify your country and offer you a version of the app corresponding to your country and language (trackers necessary for the provision of a service you request).

    We also use trackers (Firebase Crashlytics, Datadog) to detect application malfunctions.

  • The CodePush tracker to update the application which does not collect any personal data.

  • Trackers (Firebase) to manage the sending of notifications. — You can disable notifications by going to your device settings.

  • Audience measurement trackers, not subject to consent (Amplitude and Firebase) and strictly necessary for the provision of the service (performance measurement, detection of navigation problems, optimization of the technical performance or ergonomics of the site, estimation of server capacity needs, analysis of content viewed), and which meet the criteria for exemption from consent.

  • Advertising trackers (Ironsource, Applovin, Adcolony, Unity, A4G, Bidmachine, DT Exchange, Google AdMob, InMobi, Liftoff, Meta, Mintegral, Ogury, Verve, Pangle, Line, App Prizes, Ayet Studio, MyChips, Tapjoy, Bitlabs, CPX, PrimeSurvey, TapResearch, Theorem Reach) collect data on campaign performance and exposure and serve ads or surveys when you wish to obtain rewards.

  • Attribution trackers (Adjust and Facebook Ads) to analyze and manage acquisition campaigns. You can consult Facebook’s ad settings and update your preferences at any time.

You can object to one or more trackers by sending your request to privacy@wewardapp.com.
You can contact WeWard at any time (privacy@wewardapp.com) to access the privacy policies related to these trackers.

Information collected by trackers is retained for a maximum of 6 months.

Processing of data from these cookies is carried out in accordance with our Cookie Policy which we invite you to consult.

Transfers of data outside the European Union

In the context of providing Services, WeWard may use analytics and notification providers whose headquarters or servers are located in countries that are not members of the European Union and that have not been the subject of an adequacy decision by the European Commission. These countries (USA, Madagascar, UK) provide a lower level of protection than the framework existing within the European Union. In these cases, WeWard ensures that such transfer is carried out in conditions compliant with applicable regulations by taking all appropriate measures and within a legal, technical and operational framework intended to ensure the confidentiality and security of these data. These third parties undertake to respect the European Commission’s Standard Contractual Clauses.

You can obtain information about transfers by sending an email to the address indicated below.

Data deletion

You can delete your data at any time by going to the app, to the profile page, via the “delete my account” button or by sending an email to contact@wewardapp.com. These data will be archived in full within 7 days and deleted after 3 months.

Third-party sites and services

Our Services may contain links to websites, mobile applications or online services operated by third parties. We may also integrate certain content or features from these third parties. These links or integrations do not constitute approval or affiliation with these third parties.

We exercise no control over these third-party sites, applications or services and cannot be responsible for their personal data protection practices. We recommend that you review each of these third parties’ privacy policies to understand how your personal data is processed there.

Your rights

In accordance with applicable regulations, you have the right of access, objection, rectification, erasure of your personal data as well as the right to restriction of processing, data portability and to determine the fate of your data in the event of death. Finally, regarding profiling operations, you have the right to object to the use of such a process. You may also withdraw prior consent. However, exercising some of these rights (opposition to profiling, withdrawal of consent for geolocation) may make it impossible for WeWard to provide you access to the Application or to use all or part of the Services.

These rights can be exercised by contacting us at privacy@wewardapp.com. In addition, please note that you can directly exercise certain of these rights through your account settings (delete documents, delete optionally requested information and even general deletion of your account). You can remove the Facebook-Google/WeWard link from your Facebook/Google account.

You can unsubscribe from commercial emails by following the unsubscribe instructions at the bottom of these emails, or by contacting us. Please note that if you choose not to receive marketing emails, you may still receive service-related emails or other non-commercial communications.

Advertising choices. In some cases you can limit the use of your information for interest-based advertising by configuring the following options:

  • Browser settings. You can modify your web browser settings to block third-party cookies.

  • Privacy-focused browsers or extensions. You can use privacy-focused browsers and/or extensions (modules) that block ad-tracking technologies.

  • Platform settings. Some platforms like Google and Facebook offer opt-out features for targeted advertising, accessible at the following addresses:

  • Industry tools. You can also choose not to receive targeted advertising from companies that are members of the following opt-out programs:

  • Mobile settings. You can configure your mobile device settings to limit the use of your device’s advertising identifier for targeted advertising.

Please note that these opt-out settings must be applied separately on each device and each browser you use.
We cannot guarantee that the companies we work with participate in the opt-out programs mentioned above.

Do Not Track. Some web browsers can be configured to send “Do Not Track” signals to the online services you visit. Currently, we do not respond to these “Do Not Track” signals. For more information on “Do Not Track”, please consult your local authorities’ websites (for the US: http://www.allaboutdnt.com)

If you are not satisfied, you have the right to lodge a complaint with the local data protection authority which you can find at the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_fr

For France, WeWard’s lead supervisory authority:
Commission nationale de l’informatique et des libertés (CNIL) 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 Tel.: 01 53 73 22 22

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect changes in our practices, our Services or legal requirements. In the event of a substantial change affecting your rights or requiring your consent, you will be informed by appropriate means (for example, in-app notification or by email) and, if necessary, we will request your consent again.

The updated version of the Privacy Policy will be published on our Services with the revised date. We invite you to check this Policy regularly to be informed of any changes.

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