PRIVACY POLICY

Preamble The present privacy policy (“ Privacy Policy ”) has the goal to inform the users (“ Users ”), the participants (“ Participants ”), the client brand contacts (“ Advertisers ”) and the providers about the use of personal data (“ Data ”) made by The Social Company and its rights to this concern in the framework of its contractual relationship with its users, Participants, Advertisers, and providers. he Privacy Policy is available through the website www.skwad.com (the “ Website ”) and in any event it is available for any User, Participant, Advertiser, provider at the moment of their registration on the Website or Application or before the conclusion of a contract with The Social Company. It may be modified to take into account, in particular, the evolution of Data processingbeingimplemented and the applicable legislation. The former version is filed and stays available to Users. In this way, our providers, Users, Participants and Advertisers are encouraged to read carefully any new version that The Social Company provides.

1. The responsible of processing and the people involved in this Privacy Policy

The Social Company SAS is the operator of the website www.skwad.com ,and its mobile application skwad. It is the Data processing manager, taking the role of a professional who proposes a collaboration between Participants and Advertisers in order to increase the visibility of Advertiser’s products/services through Participants’ social network accounts. Therefore, The Social Company is submitted to the obligations imposed by the French and European Union legislation in force regarding personal data, especially the Regulation (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and to the free flow of such data (“ GDPR “). The people involved in the Data processing are the providers, Participants, and Advertisers, also including the internet users navigating on the Website (the “ Users “ or “ You “).

2. Définitions

The expression “personal data” means any information that makes a person identifiable directly as in their name and surname or indirectly as in their IP address, social security number or ID number (the “Data ”). A Data processing means every performed or contemplated operation, directly or indirectly, to the Data, such as the collection, register, organization, preservation, modification, consultation, transmission, diffusion, or any other form of provision, the record linkage or interconnexion, the limitation or erasure, etc.

3. Collected and processed data

Data You provide us The Social Company collects Data directly from its Users, Participants, and Advertisers through the forms available on the Website and the Application, on your mobile devices or not, or directly on The Social Company through the public accounts of Participants on their Social Networks. These Data is updated directly from the Users. In this respect, Users engage to communicate any updates of the aforementioned Data to the marketing/customer service without delay. Additionally, the e-mail exchanges are submitted to be registered and preserved in order to improve the quality of our customer service and train our colleagues. The Advertiser’s Data are also collected on the initial contact and on the execution of the contract connecting the Advertiser with The Social Company. The Personal Data that You provide us are used on the following processes:

• For the correct and needed execution of the contract for the appropriate functioning of the platform. For example, when You participate in a campaign: acceptance or refusal of your participation, moderation of your post, or confirmation e-mail when you request a password change, etc.
• For the sending of different e-mails at the moment You have given us your consent, from which You may decide if You want to receive them or not on your personal space:

– skwad information e-mails, which regularly inform you about the latest campaigns posted on the platform, our commercial and promotional offers, present our latest functionalities and keep you updated regarding our activities, etc.Data obtained by third parties Data can also be provided indirectly specially through a third party or a safe connection to Application Programming Interface (API), such as Google, Twitter, or Instagram. The privacy policy of these Google services may be consulted on the following link : http://www.google.com/policies/privacy. The Social Company collects data through cookies, especially through the services provided by Google for the behavioral data of internet users collected with the aid of Cookies and the data our publicity partners capture such as LinkedIn and Facebook. We may also receive Data about you from banks or credit institutions. In that case, we update your Data on our database. Data involving third parties that You provide us In the case You transfer Data from another person to us (example: in the context of a recommendation), you guarantee that you have the authority for accepting the process of Data in their name, you receive on their behalf all correspondence relating to their Data and given the case, you consent on their behalf the transfer of their Data abroad. We do not collect voluntarily the Data of minors of less than 15 years old. However, if you are the parent or legal tutor of this minor and you think that we possess Data of this minor, you may get the Data erased after proving your identity and your legal authority over the minor.

4. Grounds of Data Processing

Once the Data of the User, Participant, Advertiser or provider are processed by The Social Company, only the necessary Data for the purposes of processing are processed.This data processing is based on the following grounds:

• – Compliance with a legal obligation;
• – Contract implementation;
• – Lawful interest;
• – Your consent

In addition, Data whose collection is mandatory are identified as such (e.g., by an asterisk in the forms).

5. Overview table of purposes, processed Data,grounds of Data processing, retention period

The following table summarizes all processed Data, specifying for each purpose: involved Data, people/services that access these Data.

User
Collection context	Type of Data	Type of Data	Person/service havingaccess to these Data
Creation of a “prospects”database and commercialnewsletter subscription(if opt-in)	E-mail address;First name and last name;Name of position; Industry;Name of the Company;Number of employers; Country;Identification onsocial networks; Navigation data(cookies); Content in demand.	Establishing contact in the view ofthe collaboration proposal; Commercial offersproposal;	Commercial Manager;Marketing Manager.

Advertisers
Collection context	Type of Data	Type of Data	Person/servicehaving access tothese Data

Provision of thecollaborative service	First name and last nameProfessional e-mailaddressPhone numberProfessional post code addressRoleInvoices	Contract establishmentProvision of an access to theAdvertiser’s section of the WebsiteInvoice establishment	CommercialManager
Claims Management	See the box above	Collecting and processing the dataregarding delays on thepayment of Advertisersin order to prepare, pursue, and follow upa recovery action ora recourse to court and, whereappropriate, enforcing thedecision made.	The Social Companyexecutive teamThird parties (court bailiffs,licensedauctioneer,recovery company, lawyer)
Audit / acquisition	Totality of the Data	Audit from the potentialinvestors, buyers,purchasersControl of the correct applicationof our processesVerification of data processingfrom the Advertisersdata base	Externalservice providerPotentialpurchaser

Advertiser relationshipmanagement

Totality of the Data

End of contract management (e.g.refund of overpayment…)E-mail exchangeregisterCommercial offer and discount.Quality servicesurvey

CommercialManagerAccounting serviceproviderCommercialCustomer SuccessManagerOnboarding Manager

Participants
Collection context	Type of Data	Type of Data	Person/servicehaving access tothese Data

Provision of thecollaborative service	First name and last nameSex, ageMain interests;E-mail addressPhone numberPublic data availableon the account on socialnetworksPostal addressInvoicesBank informationGeolocation DataGPS location	Contract establishmentProvision of an access to theInfluencer’s section on the WebsiteA notification sent to theparticipant in order to proposecollaborations according tohis/her profile andlocalization (non-stockedinformation / non-shared withothers / non-accessible forother participants).	CommercialManagerCommunityManagerAdvertisercollaborating with theParticipant
Online sales service	See the box above	Proposal of an online sales service onthe Website	CommercialManagerAdvertisercollaborating with theParticipant
Claims Management	See the box above	Collection and process of datarelated to breachesof contractual obligationsfor the purpose of preparing, pursuing, and following upa legal action orrecourse and, where appropriate,enforcing thedecision made.	The Social Companyexecutive teamThird parties (court bailiffs,licensed auctioneer,recoverycompany,lawyer)

Audit / acquisition	Totality of the Data	Audit from the potentialinvestors, buyers,purchasersControl of the correctapplication of our processesProcessing Data controlfrom the Creatorsdatabase	The Social Companyexecutive teamExternalservice providerPotentialpurchaser
Participant RelationshipManagement	Totality of the Data	End of contract management (e.g.refund ofoverpayment…)E-mail exchangeregisterCommercial offer andcollaboration.Quality servicesurvey	CommercialManagerCommunitymanagerAccounting serviceprovider

Providers
Collectioncontext	Type of Data	Purpose of the processing	Person/service having access to these Data
Provision ofa service	First name and las nameE-mailaddressPhoneNumberContract	Contract establishmentImplementation and follow up ofthe provision of the service	The Social Company executive team

	Invoice and orderform
Provider’sclaimmanagement	see the boxabove	Follow up and process ofclaims in relation tothe provider’s contract.	The Social Company executive teamLegal officerThird parties (court bailiffs, lawyers…)

6. Who can access your Data?

Within The Social Company, the departments responsible for managing the various processes involved make the Data collected accessible. Within The Social Company, the departments responsible for managing the various processes involved make the Data collected accessible. The table above specifies for each purpose the people and departments of The Social Company likely to have access to the Data involved in the process in question.

7. Recipients and transfers of these Data

For certain purposes, The Social Company has aid from outsourcing services or services providers (e.g., those in charge of the IS maintenance or in charge of administrative services such as accountability) such as IT services providers (e.g., the web hosting provider), SaaS solutions that need access to Data to execute the mission that The Social Company entrust them, including some outside France. In that case, The Social Company imposes strict obligation to these co-contractors regarding the process, privacy and security of Data to which these providers have access. The Social Company may also communicate the Data to third parties in certain specific cases:

• If The Social Company considers transferring any activity or assets (including transfer of the company exercising this activity or possessing these assets), the Data may be given to the acquirer and the potential buyers in the framework of an audit including their committee.
• If a third party acquires all or part of the assets of The Social Company, the Data will also be a transferred asset. Data will be processed by the acquirer, who will act as the new processing manager, and their Data protection policy will determine the Data processing.
• If The Social Company is required to disclose or provide access to Data to comply with a legal obligation or court order, or to enforce or apply the service contract or any other accepted circumstances, or to protect the rights, property, or safety of The Social Company, its customers, or its employees;
• If law authorizes this transfer made by The Social Company

The Social Company does not sell the Data to third parties.

8. Retention period of Data

Data (especially the ones related to concluded contracts with The Social Company) are retained for a period of 5 years from the completion of the service whether it is about the completion of a service linking Participants and Advertisers or any other service by a provider. However:

• User’s or Participant’s Data will be deleted 3 years after their collection or last contact with the later,
• Regarding pre-litigation process: the Data are retained until the conclusion of a transaction protocol or, failing that, until the prescription of the corresponding legal action;● Regarding judicial litigation: the Data are retained until the decision has become final.

In general, Data are retained the required time for the accomplishment of the objective pursued at the moment of their collection and in accordance with the recommendations of the National Commission for Computerisation and Freedom (CNIL in French) and in compliance with legal obligations, in particular the accountable and fiscal ones. Furthermore, anonymous data and Users’ data may be retained with no limitation of time from the moment they don’t have any data.

9. Actions performed on the Data

The following actions are performed on the Data:

• Collection and register of Data.
• Organization or structuring of Data.
• Data hosting or retention through third party software.
• Data consulting.
• Sorting (through a solution edited by a third party).
• External archive.
• Data communication through transmission, diffusion, or any other form at the disposal of the services concerned.
• Modification / Consultation made by the customer or marketing service.
• Erasure or destruction of Data.

10. Localization of Data and security measures implemented

The totality of the User’s Data is located atIONOS SARL 7, place de la Gare – BP 70109 – 57201 SARREGUEMINES in France, in compliance with the applicable measures for this type of transfer.Apart from the case in which a User resides abroad, no data is transferred to a third party outside the European Union, except in the case where The Social Company must notify and/or execute legal acts (summons, judgement, seizure…) abroad taking into account the User resides out the European Union. In that case, the User’s Data are transferred to the authorities in charge of notify and/or execute the acts. In any case, The Social Company makes sure that the transferred Data are properly protected in order to ensure their security and integrity. The Social Company takes all the necessary precautions to ensure the confidentiality and the security of the Data and to prevent the alteration, corruption, or access of unauthorized people. An information system security policy has been implemented. As an example, the access to your Data is limited and restricted only to the people/services that need to access to. These data are saved on secure servers, with the bank information also encrypted. The access to the Data needs the usage of a username and a password. Nevertheless, the transmission of Data via the Internet is a risk. Therefore, The Social Company does not guarantee the security of Data transmitted via the Internet once The Social Company has respected its commitments regarding security.

11. Exercise of rights

In the framework of The Social Company making Data processing, Users have the right to:

• Have access to the copy of their processed data.
• Have the rectification of data.
• Have the erasure of the totality or a part of the Data once the Data (i) are not necessary anymore to the objectives they were collected, (ii) are based exclusively on consent, (iii) are subject to a demand of payment
• Oppose to the processing of their Data.
• Have temporary limitation of the processing in case the accuracy of Data is contested, the User opposes the processing, the Data are not necessary to The Social Company but still necessary for the contestation, the exercise or defense of rights in court.
• Unsubscribe or oppose to receiving market research messages at any moment by clicking the “unsubscribe” button in any e-mail or message The Social Company sends.
• Withdraw consent at any moment regarding processing based on consent. ● Get the portability of their Data once the processing is based on consent and on the fact that processing is implemented through automatic processes.
• Provide guidance on the event of their post-mortem Data.
• To file a complaint with the National Commission for Computerisation and Freedom (CNIL in French).

For the exercise of User’s rights or any question regarding the Privacy Policy herein, User may just send his/her request to the following address: The Social Company – 77 rue Port de Carême – 34470 PEROLS with a copy of his/her ID attached.