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 April 9, 2026

WeWard SAS

WeWard SAS, data controller (hereinafter referred to as “WeWard SAS” or “WeWard”) 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”), access to the Services we provide, and aims to inform you about the collection, use and, more broadly, the processing of your personal data. All capitalized terms not defined herein shall have the meaning attributed to them in the Terms and Conditions.

Please note that you must meet the legal age required to use the Services, in accordance with the applicable law 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 law, if lower - 15 years in France for example) to be able to consent alone to the processing of your personal data.

1/ WeWard SAS collects and processes personal information electronically, including notably your name, mobile phone number, email address, 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 and Conditions to which you have adhered) concluded between you and WeWard.

More specifically:

Data Purposes
Email address, unique account identifiers, consents, your time zone, language, date of birth (optional), phone number. Allow access to the Service (create an account), authenticate users and enable proper use of the application, know which time zone you are connected to (to reset your step counter at midnight), translate texts according to your language
Number of steps and geolocation data (optional) Count the user’s steps, evaluate 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 app Calculate and display the number of flames
Number of consecutive days on the app, username, XP amount, number of Wards, number of steps, number of flames Rank users within leagues, among friends, within championships and communities.
First name, last 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 person in case of issues. Manage any purchases.
IP address (city level) Provide the service by allocating points based on actions at partners or within the application.
Transaction history, earnings and virtual item history Provide you with the history of transactions, your earnings and your collections.
In the case of a Google or Apple sign-in: email address, first name, last name and profile picture from the account. Sign-in to the service and completion of the user profile.
Your identification data, including your email address, your journey within the app, messages you send us, problems encountered, IP address Support, correct functioning of the app and compliance with our commitments, sending transactional emails.
Phone number, first name, last name, IP address, technical information about the mobile device and content of messages sent Sending communications related to the Service
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 associated metadata. Metadata includes information about how, when, where and by whom the content was created, and about the 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, management/animation of the WeWard community.

As part of the Services, we may provide you with a feature allowing you to search for friends using their phone number, first name, last 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 contact your friends who are not users of the platform directly.

2/ With your consent (legal basis), we will collect information about your location and your physical activity in order to (i) personalize the reward offers visible in the Application according to your profile and location, and (ii) offer you virtual objects to collect. You can enable and disable location using the settings of your mobile device’s operating system. However, when you disable this functionality, you will only have access to limited features of the Application and it will be technically impossible for us to collect information related to your physical activity and location, which will prevent tracking and/or converting your movements into Wards. You may still 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 (your phone information which you can reset), in-app journey, clicks, IP address, web browsing history, device data (such as OS type and version, manufacturer and model, browser type and version, screen resolution, language settings), unique identifiers, email address. Data transferred by WeWard to advertising partners for advertising targeting and performance measurement. The list of partners (non-exhaustive) is: Facebook, Google, Ironsource, Adcolony, Vungle, Applovin, Meta Platforms, TikTok, Unity, Adjoe, Adjust…
Gender and date of birth (optional) Commercial targeting
Profile photo (optional) Update user profile

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

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 only visible 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 functioning of the company.

The legal basis for these processes is WeWard’s legitimate interest, provided that sending the requested photo is not mandatory and refusal has no consequences.

Other processing is based on WeWard’s legitimate interest:

Data Purposes Company’s legitimate interest
Photo of your identity document, your IBAN, your date of birth, your first and last name and your address. Traceability and compliance with legal obligations in the case of a bank transfer Respond to banks’ inquiries within the scope of their legal obligations
Activity time and calories. Step data up to 12 months prior to app installation. Provide statistics on the person’s physical activity to improve 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) Conduct anonymous statistical studies on users’ geolocation Know the number of users in each city
Email address Communicate with you, notably to inform you about new features, offers, challenges, promotions, updates to the Application, the Website, our Terms and/or this Privacy Policy, invitations to events Provide additional information
Referral code, referral links, referee’s Wards balance. Offer referral promotions Increase user numbers and enhance user experience
History of visited places. Conduct anonymous statistics Know the number of users in certain locations
Mobile device type and model, browser type, device identification, connection times and pages viewed, device OS and version, and network connection type Enable the Application to operate, 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. Produce general statistics and improve partner knowledge. Transfer of this information to merchant partners in anonymous form Improve service knowledge and performance, R&D. Allow merchant partners to evaluate WeWard’s performance
Device identifier (plain and hashed), device technical information, first name, last name, IP address, network data, telemetry data, behavioral signals (sampled interactions such as clicks and touch contacts), timestamps related to session initiation (e.g., account creation, login, session start), cheat score*, number of referees, all identifiers that have used the WeWard account, source step-tracking apps, all transactions with partners, number and amount of transfers, surveys and offerwalls executed. Verification of suspicious actions. Fraud detection (e.g., users with multiple IPs for one phone, abnormal number of referees, same IBAN for multiple accounts) Secure the Application and its reward mechanisms, prevent abuse and fraud, ensure fairness between users, protect WeWard’s economic interests and ensure the proper functioning of Services, which may require the use of specialized technical providers and tools for fraud prevention.
Email exchanges and banking transaction and reward distribution data. Access your transaction and earning history Comply with contractual and regulatory obligations, including for internal audits. Keep evidence in case 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 comply with accounting obligations Retain commercial documents
File of requests to exercise rights (right of access, objection, erasure…) Respond to your requests within the legal timeframe Comply with our legal obligations (GDPR)
Identification data (first name, last name), contact data (email, billing and delivery addresses), technical data (IP address) and transactional data related to deal purchases. Detection, prevention and securing of payment-related fraud in the context of purchasing vouchers on the application. Secure payment operations, protect WeWard’s economic interests, prevent payment fraud and limit the risk 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 behavior (e.g.: artificial simulation of steps, artificial simulation of geolocation points, incoherent ad viewing, falsification of purchases or actions carried out at our partners, falsification of referrals). If a user uses such methods, their account will be suspended. They will be informed in advance.

All the data in 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 case 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 allow the user to earn Wards. The list of partners (non-exhaustive) includes: Tap Research, InBrain, Pollfish…
Advertising identifier (your phone information which you can reset) Provide rewards based on viewed videos (legal basis: performance of the contract). Offer targeted advertising (legal basis: consent): ID collected by WeWard and transferred to advertising partners for ad targeting. The list of partners (non-exhaustive) includes: Facebook, Ironsource, Adcolony, Vungle, Applovin…
Unique account identifier and purchases made with partners Provide rewards based on viewed videos and purchases made (legal basis: performance of the contract). Provide statistics on the person’s physical activity to improve performance.
Unique identifier (email, database ID) and user sessions (pages visited, clicks…) Provide statistics on app usage (pages viewed, clicks, retention…) and allow support and engineers to resolve bugs to improve Application performance, R&D. The list of partners (non-exhaustive) includes: Amplitude, Google (Firebase), Datadog…

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

Recipients

Your personal data are processed by WeWard for the purposes described above and, for that purpose, WeWard may transmit your data to third parties belonging to the following categories:

1/ To our processors: WeWard may engage trusted partners acting as processors, and more specifically:

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 a level of protection equal to or greater than that provided by WeWard. A contract compliant with Article 28 of the GDPR is concluded with each of our processors. You may obtain the list of these processors upon simple request to the email address indicated at the end of this Policy.

2/ To our Partners: WeWard ensures as much as possible that Services are offered transparently by the Partners with which WeWard collaborates. For example, Partners may request WeWard to obtain information to confirm a click in order to allow you to benefit from the offered Services (Rewards). They may also receive the information necessary to validate an action or a challenge so that you can be awarded Wards. 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 subject to the relationship between you and the Partner, in accordance with the Partner’s privacy policy.

You may obtain additional information about these Partners by sending an email to 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 our 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 only disclose your personal data without prior notice if required by applicable law, or if such disclosure is necessary to comply with the law or regulation in force, a legal proceeding and/or an administrative or judicial injunction; 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 share its User list with third parties without your prior consent. Subject to your express prior consent, WeWard partners may contact you directly or through us to offer commercial offers.

Security

WeWard processes your data confidentially and securely by implementing the necessary technical and organizational measures 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 where required by law or regulatory obligation incumbent on the data controller.

Security risk is inherent to any Internet- or information-related technology. We make every effort to secure personal data but cannot guarantee it absolutely.

Retention Period

WeWard retains your personal data for the period necessary to provide the Services. Afterwards, data is kept in an active database for up to 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, however, deleted after 3 months of inactivity on the Application or 7 days after the deletion of your account.
Information indicating that you participated in a survey WeWard only retains that you earned X Wards for a survey on a given day and time, and this during the relationship, 7 days after account deletion, and/or after 24 months of inactivity.
Facebook or Google username, Facebook or Google profile photo, gender and Facebook or Google friends list WeWard does not retain the friends list. You can remove the Facebook-Google-WeWard link from your Facebook/Google account. WeWard retains the link for as long as the account exists
(Geo)location data Location data related to the collection of a virtual object are 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 retained 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 GDPR rights requests 3 years from the end of the calendar year of your request. 1 month for a copy of your identity document if it was requested.

COOKIES/TRACKERS

Trackers are small text files (called "cookies" in English) placed on your device 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 mainly used to allow the site and application to function, or to function more efficiently, but also to provide information to partner website owners or to improve your user experience and display personalized content or ads.

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

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

On the WeWard app, we use:

  • trackers necessary for the application to function properly and improve your experience: trackers (Facebook Sign In, Apple Sign In, Google Sign In, Firebase) to recognize you when you arrive in 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 to provide 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 to provide the service (measure performance, detect navigation issues, optimize technical performance and ergonomics of the site, estimate server capacity needed, analyze content viewed), and which meet the criteria for consent exemption.

  • Advertising trackers (Ironsource, Applovin, Adcolony, Unity, A4G, Bidmachine, DT Exchange, Google AdMob, InMobi, Litfoff, Meta, Mintegral, Ogury, Verve, Pangle, Line, App Prizes, Ayet Studio, MyChips, Tapjoy, Bitlabs, CPX, PrimeSurvey, TapResearch, Theorem Reach) to collect data on the performance and exposure of advertising campaigns and to display 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 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.

The 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 the 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) ensure a lower level of protection than the framework existing within the EU. In such cases, WeWard ensures that this transfer is carried out in conditions compliant with applicable law by taking all appropriate measures and within a legal, technical and operational framework aimed at ensuring the confidentiality and security of this data. These third parties commit to respect the EU 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 an endorsement or affiliation with these third parties.

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

Your Rights

In accordance with applicable law, you have the right to access, object to, rectify, erase your personal data, as well as the right to restrict processing, to data portability and to define the fate of your data in the event of death. Finally, concerning profiling operations, you have the right to object to the use of such a process. You may also withdraw a previously given consent. However, exercising some of these rights (objecting to profiling, withdrawing consent to geolocation) may make it impossible for WeWard to provide you access to the Application or use of all or part of the Services.

These rights may be exercised by contacting us at the following address privacy@wewardapp.com. In addition, you are reminded that you can directly exercise some of these rights via 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 those 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 targeted advertising according to your interests by configuring the following options:

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

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

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

  • Industry tools. You can also choose not to receive targeted advertising from companies participating in the following opt-out programs:

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

Please note that these opt-out settings must be applied separately on each device and 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 online services you visit. Currently, we do not respond to these “Do Not Track” signals. To learn more about “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 your local data protection authority, which you can find by following this 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 substantive change affecting your rights or requiring your consent, you will be informed by appropriate means (for example, notification in the application or by email) and, where necessary, we will request your consent again.

The updated version of the Privacy Policy will be published on our Services with the updated revision date. We invite you to review this Policy regularly to take note of any changes.

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