PRIVACY POLICY

This Privacy Policy contains rules which one must agree to abide by in order to use the GuidePal Platform and GuidePal Services. By entering into this Agreement, you also agree to the terms set out in our Terms of Use, which forms an integral part of this Agreement. Our Terms of Use explains how you are allowed to use our Platforms and Services. For full details, please refer to our Terms of u. This Privacy Policy and our Terms of use agreement constitutes the entire Agreement between you and GuidePal.

1. General This Privacy Policy is intended to inform you of GuidePal’s policies and practices regarding the collection, use and disclosure of any information about you that directly or indirectly may be referable to you, such as your name, email address, location and other information (”Personal Data”) that you submit or disclose to GuidePal when accessing the GuidePal Platform and/or using GuidePal Services (irrespective of whether it is public or non-public information).

2. Changes to the Agreement GuidePal may, from time to time and at its own discretion, change the terms of this Agreement. Any such change becomes effective when posted on GuidePal’s website. It is your sole responsibility to check for changes and your continued use of GuidePal Services will constitute your acceptance of such changes. GuidePal may revise the Privacy Policy and Terms & Conditions for its webpage at any time and without notice, so check them regularly. Should you not agree to a change of this Agreement, you must cease to access the GuidePal Platforms and cease to use GuidePal Applications.

3. Definitions In this Privacy Policy, “GuidePal” means GuidePal Group AB, a Swedish company with corporate identification number 556788-0520 and with its registered address at Hovslagargatan 5A1 in Stockholm, Sweden.

4. User Consent By registering a GuidePal Account and accessing the GuidePal Platform from your Device, you consent to the collection and use of your Personal Data as we have outlined in this Privacy Policy, which is incorporated into and forms part of our Terms of Service. You unconditionally consent to GuidePal’s collection and processing of your Personal Data as specified in this Privacy Policy (and as amended from time to time) by allowing the GuidePal Platform to access your Facebook or other Social Network account.

5. Controller of Personal Data For purposes of the European Union Data Protection Directive, GuidePal is the data controller of the Personal Data expressly requested by GuidePal and such Personal Data may be transferred to, processed and stored by GuidePal’s affiliates and group companies as well as third parties providing services to GuidePal. Some of these third parties may be located in a country outside the European Union (for instance, in the United States) where laws regarding processing of Personal Data may be less stringent than the laws in your country. GuidePal is committed to protecting your Personal Data at all times and the Personal Data will not be used or disclosed for purposes for which you have not given consent to pursuant to this Privacy Policy or which is not permitted under applicable laws. International Users: If you are located outside of the United States, please note that this site is hosted on our computer servers in the United States. Therefore, your information may be processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States. Your use of this site or the Service or your submission of any Personal Information to us will constitute your consent to the transfer of your Personal Information outside of your home country, including the United States, which may provide for different data protection rules than in your country.

6. Age Restrictions Children under the age of 13 are not permitted to use GuidePal Services, and we do not intentionally collect or maintain Personal Data from persons who are under the age of 13. By using GuidePal Services, you represent that you are at least 18 years of age, or that you are between 13 and 17 years of age and have a parent’s or guardian’s permission to use GuidePal Services. If we obtain actual knowledge that we have collected Personal Data from a person under the age of 13 or a person between 13 and 17 years of age who does not have a parent’s or a guardian’s consent to use GuidePal Services, we will take steps to remove that person’s Personal Data permanently from our databases.

7. Collection of Personal Data Personal Data That You Provide It is our ambition to make your use of the GuidePal Platform and GuidePal Services a good experience. GuidePal collects information that you voluntarily enter, including Personal Data, within the GuidePal Platform. GuidePal collects Personal Data about you and your friends who use GuidePal Services, from you and from the Social Network connected to the GuidePal Platform (including your profile photo), in order to provide you with a more personalised experience. We may collect information from your Social Network profile that you have permitted to be displayed through the GuidePal Platform and we may also collect information that you submit when using GuidePal Services. For example, age, gender and general location. All to generate a more sophisticated product experience. We may also request optional information from you to support and enhance your use of GuidePal Services. The information relating to you that is being processed by GuidePal includes: • Identification data (e.g. name, email address); • Profile information (e.g. age, gender, nationality); • Electronic identification data (e.g. IP address, cookies); and • Content that you submit during your use of GuidePal Services, such as photos, reviews and other information you choose to submit. ersonal Data from Other Sources We may receive Personal Data about you from other sources such as the Social Network connected to the GuidePal Platform, as well as other third parties that help us improve your experience of GuidePal Services and generally make GuidePal Services better. GuidePal may associate this information with the other Personal Data that GuidePal has collected about you. Email and Email Addresses f you send an email to us or fill out our “Feedback” form through the GuidePal Platform, we will collect your email address and the full content of your email, including attached files and other information you provide in order to document and to further develop GuidePal Services based on user feedback. If you provide feedback to us, we may use and disclose such feedback to third parties to improve or modify GuidePal Services. GuidePal may use and display your full name and email address when you send an email notification to a friend through the GuidePal Platform or the Social Network connected to GuidePal Services (such as in an invitation or when sharing your content). Additionally, we may use your email address to contact you on behalf of your friends (such as when someone sends you a personal message) or notifications from a Social Network or other website with which you have registered to receive such notifications. If you choose to sign up to receive information that may be of interest to you, GuidePal may collect your email address and other related information also for that purpose. GuidePal may use this email address to contact you for things such as notifications of limited-edition shop sales and other related advertisement information. You may at any time opt-out from any further advertisements to your email address by sending a notice to GuidePal at support@guidepal.com. Information Collected via Technology As you use GuidePal Services, certain information may also be passively collected and stored on our or our service providers’ server logs, including your IP address, browser type and operating system. We may also use cookies (as defined below) and navigational data like Uniform Resource Locators (”URLs”) to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed, or on which of the advertisements displayed on the GuidePal Platform you clicked. This type of information is collected to make GuidePal Services more useful to you and to tailor the experience with GuidePal Services to meet your special interests and needs. For example, we, or our service providers, may track your IP Address when you access the GuidePal Platform to assist with ad targeting. An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your Device when you use the Internet. In some cases your IP Address stays the same from browser session to browser session, but if you use a consumer Internet access provider, your IP Address probably varies from session to session. Cookies “Cookies” are small pieces of information that GuidePal sends to and stores on the Device that you use when accessing the GuidePal Platform. GuidePal uses cookies to provide you with a more personal and interactive experience with the GuidePal Platform and to improve GuidePal Services. Cookies help us evaluate what types of information that might be of interest to you and other users, to improve our and our Partners’ advertisements and to protect you and GuidePal from unlawful activities. We also use cookies to know when you are interacting with Partners or other third parties. In order to use GuidePal Services, your Device must accept cookies. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them). Persistent cookies can be removed or blocked by following your Internet browser´s help file directions. But some aspects of the GuidePal Platform may not work properly and you may not be able to use GuidePal Services if our cookies are removed or blocked. Location If the settings on your Device allow us to receive location information, GuidePal will collect that information in order to provide you with a more geographically targeted experience of GuidePal Services and provide you with nearby offers, Partner information, etc.

7. Use and Disclosure of Personal Data Personal Data that you submit to us is used by GuidePal to provide you with access to the GuidePal Platform and GuidePal Services; to administer your GuidePal Account; to improve GuidePal Services; to better tailor the features, performance and support of the GuidePal Platform; and to offer you additional information, advertisements, opportunities, promotions and functionality from us (including in cases when we contact you in connection with specific Partner advertisements, opportunities and promotions). GuidePal may provide your Personal Data to third-party service providers who work on behalf of or with us to provide some of the services and features of the GuidePal Platform and to help us communicate with you. Examples of such services include sending email, analysing data, providing marketing assistance, processing payments (including credit card payments) and providing customer service. Such third-party service providers may only process Personal Data to provide the relevant services to GuidePal and in accordance with GuidePal’s instructions. The Personal Data that you provide will allow GuidePal to inform you of GuidePal Services, such as new content as well as other services and products that may be of interest to you. GuidePal may use your Personal Data for processing, managing and providing you with retail offers, advertisements and other information related to your profile and interests. By using GuidePal Services you agree that GuidePal may contact you to conduct targeted advertising based on the information provided by you and collected by GuidePal. This type of targeting is performed to make GuidePal Services and solutions more useful to you and to tailor the experience with the GuidePal Platform to meet your special interests and needs. Sometimes this type of targeting and other offers, advertisements and promotions is performed by GuidePal on behalf of third parties. GuidePal does not disclose your Personal Data to third parties, but may make certain of your non-personally identifiable demographic information (like age, gender and general location) available in connection with our agreements with Partners. None of the information provided to Partners would allow them to identify you or your Personal Data. We may promote third-party products and/or services by placing advertisements on the GuidePal Platform on behalf of Partners and ad servers. These Partners may use cookies and/or “Web Beacons” (which are usually small, transparent graphic images) in order to monitor information related to served advertisements. Clicking on such advertisements will direct you to the website of such Partners. This Privacy Policy does not cover the privacy practices of any such Partners, as further described in Section 7 (Third-Party Websites) in the Terms of Service. Your Personal Data may also form part of GuidePal’s statistics but then we will exclude, for instance, your name. GuidePal will generally aggregate this information and use it in statistical analysis to help us analyse patterns in the use of GuidePal Services and to help Partners indirectly (via GuidePal) target users with the desired demographics. In the event GuidePal is subject to a business transition such as a merger, acquisition by another company or a sale of all or a portion of GuidePal’s assets, your Personal Data may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of GuidePal or its assets may continue to process your Personal Data as set forth in this Privacy Policy. In addition to the above, GuidePal may disclose your Personal Data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on GuidePal or pursuant to any other legal claims or (b) to protect and defend GuidePal’s rights, property or interests or (c) to protect your rights or any third-party rights or (d) fight against fraud or (e) to enforce our policies (including this Privacy Policy and our Terms of Service).

8. Ability to View Your Information When you register a GuidePal Account, your Social Network friends will be notified of your use of GuidePal Services. Your Social Network friends with GuidePal accounts will then be able to access the information you have published on the GuidePal Platform. It is up to you to make sure that you are comfortable with the information that you choose to provide to GuidePal and the information you choose to publish either directly on the GuidePal Platform or through your Social Network, which is connected to the GuidePal Platform. You acknowledge that when you use GuidePal Services, certain information that you post or provide through the GuidePal Platform (such as your name, profile, comments, collections and reviews,) may be shared with other users and posted on publicly available portions of the GuidePal Platform, including, without limitation, social media applications and other public forums in which you choose to participate. Please keep in mind that if you choose to disclose Personal Data when posting comments or other information or content through the GuidePal Platform, this information may become publicly available and may be collected and used by others, including people outside the GuidePal Platform. We will not have any obligations with respect to any information that you post via the GuidePal Platform and make available to others, and recommend that you use caution when giving out Personal Data to others through Social Networks.

9. Security of Collected Information GuidePal is committed to protecting the security of your Personal Data. We will take appropriate technical and organisational measures with due observance of the applicable obligations under relevant legislation to protect provided or otherwise collected Personal Data and traffic data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized or unlawful access, use or disclosure and accidental loss, destruction and damage. Even though GuidePal has taken significant steps to protect your Personal Data, no company, including ours, can fully eliminate security risks associated with Personal Data.

10. Access to, Rectifying and Deleting Your Personal Data You are entitled, once a year, to request information from GuidePal about the Personal Data relating to you which is being processed by GuidePal and to request, where relevant, that such Personal Data is rectified by sending a notice to GuidePal at the following address: GuidePal Group AB Hovslagargatan 5 A1 111 48 Stockholm Sweden GuidePal will make all reasonable efforts to accommodate a request to delete Personal Data, unless such data is required to be retained pursuant to applicable laws, or for lawful business purposes, or to protect and defend GuidePal’s rights, property or interests, or to fight against fraud, or to enforce our policies (including this Privacy Policy and our Terms of Service). You may also, at any time, ask us to discontinue processing your Personal Data for direct marketing purposes by notifying us at the address above that you would like us to stop sending you promotional communications.

11. Questions If you have any questions or complaints relating to our Terms of use or relating to our Privacy Policy, please contact hello@guidepal.com. We will endeavour to respond to you promptly.