We respect your privacy and are committed to protecting it through our compliance with this

or that you may provide (“Personal Information”) in the “Youphoria” mobile application (“Mobile

Application” or “Service”) and any of its related products and services (collectively, “Services”),

and our practices for collecting, using, maintaining, protecting, and disclosing that Personal

Information. It also describes the choices available to you regarding our use of your Personal

Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Youphoria,

LLC (“Youphoria, LLC”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a

business or other legal entity, you represent that you have the authority to bind such entity to

this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you

do not have such authority, or if you do not agree with the terms of this agreement, you must not

accept this agreement and may not access and use the Mobile Application and Services. By

accessing and using the Mobile Application and Services, you acknowledge that you have read,

understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the

practices of companies that we do not own or control, or to individuals that we do not employ or

manage.

Collection of personal information

You can access and use the Mobile Application and Services without telling us who you are or

revealing any information by which someone could identify you as a specific, identifiable

individual. If, however, you wish to use some of the features offered in the Mobile Application,

you may be asked to provide certain Personal Information (for example, your name and e-mail

address).

We receive and store any information you knowingly provide to us when you create an account,

publish content, or fill any forms in the Mobile Application. When required, this information may

include the following:

- Account details (such as user name, unique user ID, password, etc)

- Contact information (such as email address, phone number, etc)

- Basic personal information (such as name, country of residence, etc)

- Any other materials you willingly submit to us (such as articles, images, feedback, etc)

Some of the information we collect is directly from you via the Mobile Application and Services.

However, we may also collect Personal Information about you from other sources such as public

databases and our joint marketing partners.

You can choose not to provide us with your Personal Information, but then you may not be able

to take advantage of some of the features in the Mobile Application. Users who are uncertain

about what information is mandatory are welcome to contact us.

Privacy of children

We recognize the need to provide further privacy protections with respect to Personal

Information we may collect from children under the age of 13 and take many special precautions

to protect their privacy. We may require a child to disclose some Personal Information to use the

Mobile Application and Services. However, we do not require a child to disclose more

information than is reasonably necessary to use the Mobile Application and Services and

Personal Information will not be used or disclosed for purposes other than those for which it was

collected. All of the information created or submitted by a child is set to private by default,

meaning only the User who submitted it may view it. Parents and legal guardians can review

their child’s Personal Information, delete it, and refuse to allow any further collection or use of

such information. Parents and legal guardians also have an easy method for giving consent.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help

enforce this Policy by instructing their children never to provide Personal Information through

the Mobile Application and Services without their permission. We also ask that all parents and

legal guardians overseeing the care of children take the necessary precautions to ensure that

their children are instructed to never give out Personal Information when online without their

permission. We believe parents and legal guardians should be involved in the online activities of

their children and suggest that parents do their best to provide their children with a safe and

friendly online environment.

Use and processing of collected information

We act as a data controller and a data processor in terms of the GDPR when handling Personal

Information, unless we have entered into a data processing agreement with you in which case

you would be the data controller and we would be the data processor.

Our role may also differ depending on the specific situation involving Personal Information. We

act in the capacity of a data controller when we ask you to submit your Personal Information that

is necessary to ensure your access and use of the Mobile Application and Services. In such

instances, we are a data controller because we determine the purposes and means of the

processing of Personal Information and we comply with data controllers’ obligations set forth in

the GDPR.

We act in the capacity of a data processor in situations when you submit Personal Information

through the Mobile Application and Services. We do not own, control, or make decisions about

the submitted Personal Information, and such Personal Information is processed only in

accordance with your instructions. In such instances, the User providing Personal Information

acts as a data controller in terms of the GDPR.

In order to make the Mobile Application and Services available to you, or to meet a legal

obligation, we may need to collect and use certain Personal Information. If you do not provide

the information that we request, we may not be able to provide you with the requested products

or services. Any of the information we collect from you may be used for the following purposes:

- Create and manage user accounts

- Send marketing and promotional communications

- Send product and service updates

- Respond to inquiries and offer support

- Request user feedback

- Improve user experience

- Post customer testimonials

- Deliver targeted advertising

- Administer prize draws and competitions

- Enforce terms and conditions and policies

- Protect from abuse and malicious users

- Respond to legal requests and prevent harm

- Run and operate the Mobile Application and Services

Processing your Personal Information depends on how you interact with the Mobile Application

and Services, where you are located in the world and if one of the following applies: (i) you have

given your consent for one or more specific purposes; this, however, does not apply, whenever

the processing of Personal Information is subject to California Consumer Privacy Act or

European data protection law; (ii) provision of information is necessary for the performance of

an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is

necessary for compliance with a legal obligation to which you are subject; (iv) processing is

related to a task that is carried out in the public interest or in the exercise of official authority

vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by

us or by a third party. We may also combine or aggregate some of your Personal Information in

order to better serve you and to improve and update our Mobile Application and Services.

We rely on the following legal bases as defined in the GDPR upon which we collect and process

your Personal Information:

- User’s consent

Note that under some legislations we may be allowed to process information until you object to

such processing by opting out, without having to rely on consent or any other of the legal bases

above. In any case, we will be happy to clarify the specific legal basis that applies to the

processing, and in particular whether the provision of Personal Information is a statutory or

contractual requirement, or a requirement necessary to enter into a contract.

Managing information

You are able to delete certain Personal Information we have about you. The Personal

Information you can delete may change as the Mobile Application and Services change. When

you delete Personal Information, however, we may maintain a copy of the unrevised Personal

Information in our records for the duration necessary to comply with our obligations to our

affiliates and partners, and for the purposes described below.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide

any Service you have requested, we may share your information with our trusted subsidiaries

and joint venture partners, affiliates, contracted companies, and service providers (collectively,

“Service Providers”) we rely upon to assist in the operation of the Mobile Application and

Services available to you and whose privacy policies are consistent with ours or who agree to

abide by our policies with respect to Personal Information. We will not share any information

with unaffiliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to

perform services on our behalf or comply with legal requirements. Service Providers are given

the information they need only in order to perform their designated functions, and we do not

authorize them to use or disclose any of the provided information for their own marketing or

other purposes. We will share and disclose your information only with the following categories of

Service Providers:

- Advertising networks

- Affiliate programs

- Cloud computing services

- Communication and collaboration services

- Data analytics services

- Data storage services

- Financial services

- Government agencies

- Order fulfillment services

- Payment processors

- Performance monitoring services

- Product engineering and design services

- Sales and marketing services

- Social networks

- User authentication services

- Website hosting service providers

We may also disclose any Personal Information we collect, use or receive if required or

permitted by law, such as to comply with a subpoena or similar legal process, and when we

believe in good faith that disclosure is necessary to protect our rights, protect your safety or the

safety of others, investigate fraud, or respond to a government request.

In the event we go through a business transition, such as a merger or acquisition by another

company, or sale of all or a portion of its assets, your user account, and your Personal

Information will likely be among the assets transferred.

Retention of information

We will retain and use your Personal Information for the period necessary as long as your user

account remains active, to enforce our agreements, resolve disputes, and unless a longer

retention period is required or permitted by law.

We may use any aggregated data derived from or incorporating your Personal Information after

you update or delete it, but not in a manner that would identify you personally. Once the

retention period expires, Personal Information shall be deleted. Therefore, the right to access,

the right to erasure, the right to rectification, and the right to data portability cannot be enforced

after the expiration of the retention period.

Transfer of information

Depending on your location, data transfers may involve transferring and storing your information

in a country other than your own. The transfer of your Personal Information to countries outside

the European Union will be made only if you have explicitly consented to it or in the cases

provided for by the GDPR and will be processed in your interest.

You are entitled to learn about the legal basis of information transfers to a country outside the

European Union or to any international organization governed by public international law or set

up by two or more countries, such as the UN, and about the security measures taken by us to

safeguard your information. If any such transfer takes place, you can find out more by checking

the relevant sections of this Policy or inquire with us using the information provided in the

contact section.

Data protection rights under the GDPR

If you are a resident of the European Economic Area (“EEA”), you have certain data protection

rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the

use of your Personal Information. If you wish to be informed what Personal Information we hold

about you and if you want it to be removed from our systems, please contact us. In certain

circumstances, you have the following data protection rights:

(i) You have the right to withdraw consent where you have previously given your consent to the

processing of your Personal Information. To the extent that the legal basis for our processing of

your Personal Information is consent, you have the right to withdraw that consent at any time.

Withdrawal will not affect the lawfulness of processing before the withdrawal.

(ii) You have the right to learn if your Personal Information is being processed by us, obtain

disclosure regarding certain aspects of the processing, and obtain a copy of your Personal

Information undergoing processing.

(iii) You have the right to verify the accuracy of your information and ask for it to be updated or

corrected. You also have the right to request us to complete the Personal Information you

believe is incomplete.

(iv) You have the right to object to the processing of your information if the processing is carried

out on a legal basis other than consent. Where Personal Information is processed for the public

interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate

interests pursued by us, you may object to such processing by providing a ground related to

your particular situation to justify the objection. You must know that, however, should your

Personal Information be processed for direct marketing purposes, you can object to that

processing at any time without providing any justification. To learn whether we are processing

Personal Information for direct marketing purposes, you may refer to the relevant sections of

this Policy.

(v) You have the right, under certain circumstances, to restrict the processing of your Personal

Information. These circumstances include: the accuracy of your Personal Information is

contested by you and we must verify its accuracy; the processing is unlawful, but you oppose

the erasure of your Personal Information and request the restriction of its use instead; we no

longer need your Personal Information for the purposes of processing, but you require it to

establish, exercise or defend your legal claims; you have objected to processing pending the

verification of whether our legitimate grounds override your legitimate grounds. Where

processing has been restricted, such Personal Information will be marked accordingly and, with

the exception of storage, will be processed only with your consent or for the establishment, to

exercise or defense of legal claims, for the protection of the rights of another natural, or legal

person or for reasons of important public interest.

(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal

Information from us. These circumstances include: the Personal Information is no longer

necessary in relation to the purposes for which it was collected or otherwise processed; you

withdraw consent to consent-based processing; you object to the processing under certain rules

of applicable data protection law; the processing is for direct marketing purposes; and the

personal data have been unlawfully processed. However, there are exclusions of the right to

erasure such as where processing is necessary: for exercising the right of freedom of

expression and information; for compliance with a legal obligation; or for the establishment, to

exercise or defense of legal claims.

(vii) You have the right to receive your Personal Information that you have provided to us in a

structured, commonly used, and machine-readable format and, if technically feasible, to have it

transmitted to another controller without any hindrance from us, provided that such transmission

does not adversely affect the rights and freedoms of others.

(viii) You have the right to complain to a data protection authority about our collection and use of

your Personal Information. If you are not satisfied with the outcome of your complaint directly

with us, you have the right to lodge a complaint with your local data protection authority. For

more information, please contact your local data protection authority in the EEA. This provision

is applicable provided that your Personal Information is processed by automated means and

that the processing is based on your consent, on a contract which you are part of, or on

pre-contractual obligations thereof.

California privacy rights

Consumers residing in California are afforded certain additional rights with respect to their

Personal Information under the California Consumer Privacy Act (“CCPA”). If you are a

California resident, this section applies to you.

In addition to the rights as explained in this Policy, California residents who provide Personal

Information as defined in the statute to obtain Services for personal, family, or household use

are entitled to request and obtain from us, once a calendar year, information about the

categories and specific pieces of Personal Information we have collected and disclosed.

Furthermore, California residents have the right to request deletion of their Personal Information

or opt-out of the sale of their Personal Information which may include selling, disclosing, or

transferring Personal Information to another business or a third party for monetary or other

valuable consideration. To do so, simply contact us. We will not discriminate against you if you

exercise your rights under the CCPA.

How to exercise your rights

Any requests to exercise your rights can be directed to us through the contact details provided

in this document. Please note that we may ask you to verify your identity before responding to

such requests. Your request must provide sufficient information that allows us to verify that you

are the person you are claiming to be or that you are the authorized representative of such

person. If we receive your request from an authorized representative, we may request evidence

that you have provided such an authorized representative with power of attorney or that the

authorized representative otherwise has valid written authority to submit requests on your

behalf.

You must include sufficient details to allow us to properly understand the request and respond to

it. We cannot respond to your request or provide you with Personal Information unless we first

verify your identity or authority to make such a request and confirm that the Personal

Information relates to you.

Data analytics

Our Mobile Application and Services may use third-party analytics tools that use cookies, web

beacons, or other similar information-gathering technologies to collect standard internet activity

and usage information. The information gathered is used to compile statistical reports on User

activity such as how often Users visit our Mobile Application and Services, what pages they visit

and for how long, etc. We use the information obtained from these analytics tools to monitor the

performance and improve our Mobile Application and Services.

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