Pingvalue Privacy Policy

Pingvalue, cares about the privacy of its users personal datas, this is why in addition to the Terms of Use, the
relation between Pingvalue S.à r.l., a private limited liability company validly established and set up under
the laws of Luxembourg, having its registered office 560a, rue de Neudorf, L-2220 Luxembourg, Luxembourg,
registered with the Luxembourg register and trade office under umber B 186394 (hereinafter referred to as
“Pingvalue”) and any of its users, including both private and professional users (hereinafter globally referred
as the “Users” or individually as the “User”), shall also be submitted to the present privacy policy
(hereinafter referred as the “Privacy Policy”).

1. Personal Datas collected by Pingvalue

1.1 When Users browses on www.pingvalue.com, personal datas (hereinafter referred globally as the “Personal
Datas” or individually “Personal Data”) concerning themselves are collected from them by Pingvalue.

1.2 These Personal Datas are provided to Pingvalue by Users when they sign up, when they browse on
www.pingvalue.com (notably because of cookies, see section 2 below), when they share tastes by recommending
brands or products, when they ask for rewards for their promotional efforts (for private users) and when they
buy credits or provide rewards (for professional users).

1.3 These Personal Datas are constituted of the User name, email address and/or other contact means such as
his/her phone or fax number, birthday, gender, localization, profile pictures but also his/her interests (when
he promotes a brand/product for instance) and some of his/her bank details such as bank account number (when
realizing transactions with Pingvalue) and more generally of everything posted on Pingvalue by Users.
1.4 Personal Datas are also collected about large groups of people, such as a specific customer base of people
who spend earned credits in specific stores and for specific products. These people then get suggestions based
on their browsing (like of products, share of products, addition of products to a wishlist and reviews of
products), and on the profiles they follow such as specific individuals, stores and brands. Based on their
profile, they can also look for like-minded people with similar interests. In that particular case, no use is
made of cookies or tracking on other websites (see below).

1.5 Pingvalue will never collect and process information about racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership as well as information relative to health or sexual
life of Users. This prohibition does not apply if Users decide to make these information public in any way.

1.6 Pingvalue also receives Personal Datas from or about the devices (computer, cell phone, tablets…) Users use
to connect to and browse on www.pingvalue.com, including when others users than him/her connect from these
devices, such as his/her IP address, mobile phone number, internet provider, location, operating system and type
of device used.

1.7 Pingvalue also receives Personal Datas (such as friends’ list) of Users from other websites such as
Facebook™ or Twitter™ when they use their implemented applications on www.pingvalue.com and/or use Pingvalue
services through them.

2. Personal Datas collected throughout use of “cookies”

2.1 A cookie is a small textfile data sent to the User’s browser by an internet website and stored on the
storage system of the User’s device. One or several cookies can be stored by Pingvalue on the User’s device
storage system.
2.2 Their purpose is solely to collect information concerning browsing habits of the Users in order to recognize
him when he/she reconnects to www.pingvalue.com, facilitate management of Pingvalue or realize statistical
studies.

2.3 Users are informed of the cookies’ utilisation by Pingvalue and can oppose to their installation by
configuring their browser accordingly.

2.4 In case the User did not oppose to the installation of cookies, he/she is deemed to have authorised the
installation and use of cookies by Pingvalue.

3. Location datas

3.1 By using Pingvalue’s Products and Services, as well as software on mobile devices, Pingvalue may determine
the location of the User’s device (“hereinafter referred as “Location Datas”). Location Datas may refer to the
latitude, longitude and altitude of the user’s terminal equipment, to the direction of travel, to the level of
accuracy of the location information, to the identification of the network cell in which the terminal equipment
is located at a certain point in time and to the time the location information was recorded.

3.2 When using Pingvalue’s Products and Services, as well as software (esp. mobile applications) the User
expressly agrees that Pingvalue uses the Location Data of the User.

3.3 Pingvalue may use and store information about the User’s location to provide features of our Services, such
as informing of a free Wi-Fi zone nearby his/her position or commercial offers available at the User’s location,
and to improve and customize the User’s experience, for example, with more relevant content like local trends,
ads and suggestions of new products.

3.4 Location tracking is “on” by default on the mobile application. The User can switch off or on the tracking
mode of the software by selecting the chosen mode directly in the settings menu of the mobile device.

4. Personal Datas shared to the public

4.1 Due to the concept of social network, when a User uses Pingvalue, he/she agrees to make public some of
his/her Personal Datas (hereinafter referred as “Public Datas”) on his/her personal page, for instance other
Users can see his/her user name, profile pictures, gender and, in some cases, his/her contact details as well as
what he/she recommends to people (private users) or the products he/she wants Users to share (professional
users).

4.2 Some Personal Datas about fans and ambassadors of certain brands and retailers (such as the User profile
name) are available on the brand/retailer page itself, and thus visible to all Pingvalue registered members,
(e.g. if a User becomes a fan of a particular brand, other Users can be informed of this on the brand page
concerned).
4.3 Users are deemed to be aware of what Public Datas they accepted to share by using Pingvalue.

4.4 Personal Datas, other than Public Datas, on purchases in specific locations or of specific products are
never made public.

5. Detention and safety of Personal Datas

5.1 Personal Datas are collected and processed by Pingvalue and stored in its datacenters located in Dublin and
Amsterdam.

5.2 Pingvalue undertakes to implement all technical measures and the appropriate organization to ensure
protection of Personal Datas against accidental or illegal destruction, accidental loss, alteration, diffusion
or unauthorized access.

5.3 In order to ensure Users the best safety, the infrastructure of Pingvalue is built in Microsoft Azure Cloud,
which complies with global data privacy standards such as ISO27001, SOC1 and SOC2, and is a cloud provider to be
approved by the EU for meeting the current existing standards for international transfers of data.

5.4 Pingvalue shall keep the Personal Datas of Users only for the duration of the relationship between Users and
Pingvalue.

5.5 Once the relationship between the User and Pingvalue ends, Pingvalue shall delete as soon as possible, all
the User’s Personal Datas.

6. Personal Datas processing

6.1 Personal Datas are used by Pingvalue to :

* suggest to a private user brands or products likely to interest him/her;

* suggest to a professional user a private user likely to become a good ambassador for him/her;

* help friends from other social networks to find the User on Pingvalue when they sign in;

* display advertising for products likely to interest the User;

* send Users notification when a comment is made on a product they recommended or when a product they propose is
recommended;

* send Users newsletter (subject to prior request);

* send Users automatized and unsolicited commercial communications as well as any type of communications via
electronic means; and * realize statistics concerning Users’ habits on www.pingvalue.com

6.2 By using Pingvalue’s Products and Services, the User expressly agrees that Pingvalue may use his/her
Personal Datas in order to send him/her automatized and unsolicited commercial communications as well as any
type of communications via electronic means.

6.3 Pingvalue implements different new technologies which deals with Personal Datas such as profiling, data
mining, geolocalization and possible NFC for the use of earned credits.

6.4 These means mainly aim at identifying a pattern of behavior, and the credibility of a person on the basis of
his/her activities and product knowledge as brand-ambassador.

6.5 Note that transactions and activities not direclty managed by Pingvalue such as the use of credits in
specific stores (offline and online) might be conducted anonymously or through a pseudonym.

6.6 Please also note that forecasting analyses, such as predicting a trend through the activity of individuals,
will be based solely on numbers and statistics and not on specific individuals, thus remain also completely
anonymous.
6.7 Pingvalue undertakes that no illegal use will be made of Users Personal Datas.

6.8 Personal Datas will neither be sold nor used for promotional activities outside Pingvalue.

6.9 In the event Pingvalue would be sold or transferred in any form whatsoever to a new owner, Personal Datas
will be provided to this new owner.

6.10 Pingvalue provides some of Users Personal Datas to third-parties (hereinafter referred to as
“Third-Parties” or individually “Third-Party”) which are constituted of :

* other websites like Facebook™ or Twitter™ (hereinafter referred to as “Other Websites”) when Users connect to
www.pingvalue.com from them when already log on with their Other Websites account or, conversely, connect to
them from www.pingvalue.com using the implemented applications of the Other Websites available on
www.pingvalue.com

* professional users of Pingvalue.

6.11 Users can set which Personal Datas they agree to share and which they do not by adjusting their profile
settings accordingly.

6.12 If Personal Datas are transfered outside Europe and European Economic Area, Pingvalue will determine if the
Third-Party provide a sufficient level of protection for Personal Datas which means a level of protection at
least equal to the one provided especially by the modified Law of 2nd August 2002 relative to the protection of
persons regarding processing of personal datas, as amended, (“Loi modifiée du 2 août 2002 relative à la
protection des personnes à l’égard du traitement des données à caractère personnel”) and more generally by all
legal provisions relative to data protection applicable in Europe.

6.13 The protection level will be considered as sufficient if the Third-Party’s country is referred to in one of
the adequacy decisions of the European Commission or, as far as the United States are concerned, if it is a
signatory of the safe harbor principles.

6.14 If Pingvalue considers the protection level as insufficient, it will not transfer any Personal Datas unless
the concerned User gave his/her express and enlightened consent to it by agreeing the notice sent to him by
Pingvalue by email or directly displayed on www.pingvalue.com.

6.15 Pingvalue will respond, to the extent reasonably possible and with the information reasonably available to
it, to any enquiries from Users concerning processing of the Personal Datas by Third-Party. Responses will be
made within a reasonable time.

6.16 Pingvalue will also communicate Users Personal Datas in response to a legal request sent by any judicial or
admnistrative competent authorities.

7. Users rights to access and modify Personal Datas

7.1 According to the modified Law of 2nd August 2002 relative to the protection of persons regarding processing
of personal datas, as amended (“Loi modifiée du 2 août 2002 relative à la protection des personnes à l’égard du
traitement des données à caractère personnel”) each User has a right to access and modify his/her Personal
Datas.

7.2 Users can obtain the confirmation by Pingvalue that his/her Personal Datas are or are not processed and
information about the purposes of the processing, the categories of datas processed and the recipients or
categories of recipients to which Personal Datas are transferred.

7.3 The access may be asked at reasonable intervals, is free-of-charge and must be granted by Pingvalue without
excessive delays.

7.4 Users can ask a copy of any Personal Data held by Pingvalue to be delivered, in an intelligible form, to
them.

7.5 They can also ask for the Personal Datas to be rectified, completed, clarified, updated or deleted.

7.6 In case of rectification, completion, clarification, update or deletion of Personal Datas, Pingvalue will
notify it to the User without delay. This communication will be made unless it is impossible for Pingvalue to
contact the User.

8. Opposition right

8.1 Each User has a right to oppose himself/herself, at anytime, for specific and legitimate grounds relative to
his/her situation, to the processing of his/her Personal Datas.

8.2 Each User can also oppose himself/herself, by mere and free-of-charge request to Pingvalue, to the
processing of his/her Personal Datas for marketing purposes.

8.3 Each User can also ask to Pingvalue, by mere and free-of-charge request, to inform him/her before the first
communication of his/her Personal Datas to Third-Parties for marketing purposes and to be expressely provided
the right to oppose, freely, to the aforementionned communication.

9. Contact details

9.1 In order to exercise these rights at any time or for any further information relating to Pingvalue or the
the present Privacy Policy, Users can :

* send an email to contact Pingvalue at info@pingvalue.com; or

* send a letter to the following address Pingvalue SARL, 560a, rue de Neudorf, L-2220 Luxembourg, Luxembourg

10. Update

10.1 This Privacy Policy is subject to changes.

10.2 When such a change occurs, Users will be notified by proposing to agree with the last version of Pingvalue
Privacy Policy. If the User refuses to do so, he/she is deemed to stop using or browsing on www.pingvalue.com.

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