Privacy Policy

Last updated: February 29, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Platform and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1. Interpretation and Definitions

a. Interpretation

If any word is used that denotes gender it should be interpreted to include an individual of any gender. The words of which the initial letter is capitalized have the meaning ascribed to it under Section (b) below unless indicated otherwise. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural form. When words such as “You” or “Your” or similar pronouns are used they shall all mean any individual or legal entity accessing or using the Platform (defined below) on behalf of themselves or anyone else. When words such as “We”, “Our”, “Us” or similar pronouns are used, they shall in every instance refer to Kwekence, LLC, the entity operating this Platform. Headings in this document are for convenience purposes only and should not affect or be used to interpret any portion of the Agreement. In the event of any ambiguity, all words should be interpreted within the reasonable context, meaning and purpose of this Agreement.

b. Definitions

For the purposes of this Privacy Policy: Account means an online account that was created by You that is not shared with anyone else that is uniquely and exclusively Yours that You use to access Our

Platform or aspects of Our Platform.

Affiliate means an entity that controls, is controlled by or is under common control with a person, where "control" means the power to direct activities of a person (whether natural or corporate) that most significantly impact economic performance and potential to receive significant benefits or absorb significant losses.

Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California. Company means Kwekence, LLC, 5000 Thayer Center Ste. C Oakland, Maryland 21550, and equally references to "We", "Us", or "Our" in this Agreement shall mean Kwekence, LLC, 5000 Thayer Center Ste. C Oakland, Maryland 21550 and its affiliates, agents, successors, assigns, subsidiaries, officers, directors, and employees.

CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Content means content such as text, images, or other information that can be posted, uploaded, linked to or otherwise made available by You on the Platform, regardless of the nomenclature, type, and/or form of such content.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: United States

Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that may be used to access the Platform and Order the Service such as a computer, a cellphone or a digital tablet or any other device (regardless of nomenclature or type).

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet Users to control the tracking of their online activities across websites.

Facebook Company Page is a public profile named Kwekence specifically created by the Company on the Facebook social network, accessible from https://facebook.com/kwekence

GDPR refers to EU General Data Protection Regulation.

Kwekence means the Platform (defined below).

Mentor means any person who uses the Platform to advertise and offer their services as a Service Provider of mentorship services.

Mentorship Services means any instructional, scaffolding, educational and or coaching services provided to a mentee for a fee in a specific field of study or subject area for their own personal or professional development. Mentorship services does not include the provision of legal counsel, medical advice, or any other professional assistance whose professional and ethical responsibilities might conflict with these Terms.

Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Platform means the Platform comprising Kwekence website and/or application hosting an online marketplace for Mentorship Services which may be found at www.kwekence.com.

Platform Data and Information Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Platform on behalf of the Company, to perform services related to the Platform or to assist the Company in analyzing how the Platform is used. For the purpose of the GDPR, Platform Data and Information Service Providers are considered Data Processors.

Third-Party Providers refers to Platform Data and Information Service Providers, Our Affiliates, Our business partners, Our Payment Processors, and or Third party providers to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You. Usage Data refers to data collected automatically, either generated by the use of the Platform or from the Platform infrastructure itself (for example, the duration of a page visit).

Users means any Mentorship Service Provider, Client, visitor, and any other person who accesses and uses the Platform in any way.

Website refers to Kwekence, accessible from www.kwekence.com

You means the individual accessing or using the Platform, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Platform.

2. Collecting and Using Your Personal Data a. Types of Data Collected

i. Personal Data While using Our Service, We (or Our third party providers) may ask You to provide Us with certain personally identifiable information that can be used to contact or identify and verify your identity. This information is provided to Us by you voluntarily and for the exclusive purpose of using this service. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Listing information
• Government issued identification.
• Publicly available information
• Job Title
• Username

This information is stored and collected for the purpose of carrying the fundamental and vital business interest which includes, but is not limited to, verifying the identity and qualification (where relevant) of Users and to provide Users a reasonable means of identifying Users best suited for mentorship services.

ii. Platform interaction Usage Data. Our analytics tool keeps an account of such information as: Page url, User browser information, User operating system information, User device type, the country or region or city the User is interacting with the Platform from and the User http referrer. This information is collected without storing any personal identifying information about individual Users. This information is stored and collected for the purpose of carrying the fundamental and vital business interest which includes, but is not limited to, ensuring that Our Platform is fully functional to all Users and to assess, on a macro level, User interest in Our Platform.

iii. Data related to Platform Communication and Service Interactions. The Platform stores and collects any information derived from email communications or correspondence between it and the User. The Platform stores and collects all information originating from mentee and mentor reviews. The Platform stores and collects all information related to and originating from booking related information. This information is stored and collected for the purpose of carrying the fundamental and vital business interest which includes, but is not limited to, ensuring that Our Platform is fully functional to all Users and to make reasonable efforts to ensure that Platform transactions are occurring securely and efficiently.

b. Information from Third-Party Social Media Services The Company may provide you the ability to create an account and log in to use the Platform through the following Third-party Social Media Services: § Google § Facebook § LinkedIn If You decide to register through or otherwise grant Us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account. You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

c. Tracking Technologies and Cookies Cookies are software tools that website owners use to provide an array of services to users. These tools collect data from users that help websites provide an array of services including inquiring information about users and facilitating website functionality. We may use Cookies and similar tracking technologies to track the activity on Our Platform and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

§ Cookies or Browser Cookies. A cookie is a small file placed on Your Device to collect information. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, Our Platform may use Cookies.

§ Web Beacons. Certain sections of Our Platform and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

§ HTML Local Storage. Certain sections of Our Platform may contain a technology supported by web browsers that affords websites the ability to store a users local data on their own device. This data can record the users general preferences when it comes to interacting with the website and it remains stored persistently. This mean that it will remain stored on your device until it is either removed by the user or website owner. All Cookies used by this site are required. We use the following Cookies for the purposes set out below:

§ Necessary / Essential Cookies Name: m m.stripe.com Administered by: Stripe Purpose: These Cookies are essential to provide You with the full services available through the Website and to enable You to use some of its features. These cookies help to authenticate Users and prevent fraudulent use of User accounts. Without these Cookies, the payment services needed to complete a purchase or receive payment for services rendered, cannot be provided. The expiration time for the above cookies range from less than an hour to almost 2 years.
Period: 1 year 1 month 4 days

§ Necessary / Essential Cookies Name: __stripe_mid Administered by: Stripe Purpose: This cookie is designed to facilitate the processing of payments. Prevents fraud by tracking the behavior of the user across the various pages of the website. Period: 1 year

§ Necessary / Essential Cookies Name: __stripe_sid Administered by: Stripe Purpose: This cookie Helps maintain the security of transactions during the checkout process. Helps to ensure fraud is prevented by tracking user activity. Period: 1 hour

§ Necessary / Essential Cookies Name: st-hosted-token Administered by: Sharetribe Purpose: This cookie is essential to provide You with the full services available through the Website and to enable You to use some of its features. This cookie is administered by Sharetribe which hosts our Platform and is used for session information. At present, it is not used to store any personal information. Period: 1 month.

§ HTML Local Storage Type: Persistent Administered by: Mapbox Purpose: HTML Local Storage affords You the ability to use and store, in a manner that does not require cookies, geolocation services when identifying the location of Your services for users. The HTML local storage functions persistently meaning that it operates without an expiration date or period.

d. Use of Your Personal Data The Company may use Personal Data for the following purposes: § To provide and maintain Our Service, including to monitor the usage of Our Service.

§ To manage Your Account: to manage Your registration as a User of the Service. The Personal Data You provide can give You access to different functionalities of the Platform that are available to You as a registered User.

§ For the performance of a contract: the development, compliance and undertaking of the purchase contract for services You have purchased or of any other contract with Us through the Service.

§ To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

§ To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

§ To manage Your requests: To attend and manage Your requests to Us.

§ For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Platform Users is among the assets transferred.

§ For other purposes: We may use Your information for other purposes, such as investigations, enforcement procedures, data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve Our service, its security, products, marketing and your experience. We may share Your personal information in the following situations:

§ For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

§ With Affiliates: We may share Your information with Our Affiliates, in which case We will require those Affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

§ With business partners: We may share Your information with Our business partners to Provide Us or offer You certain products or services. These business partners include vendors and third party service providers who assist Us in providing the robust services offered to You on this Platform.

§ With other Users: when You share personal information or otherwise interact in the public areas with other Users, such information may be viewed by all Users and may be publicly distributed outside. If You interact with other Users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other Users will be able to view descriptions of Your activity, communicate with You and view Your profile.

§ With Your consent: We may disclose Your personal information for any other purpose with Your consent.

e. Retention of Your Personal Data The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

f. Transfer of Your Personal Data Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

g. Delete Your Personal Data You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Platform may give You the ability to delete certain information about You from the Service. You may update, amend, or delete Your information at any time by signing into Your Account, if You have one, and visiting the account settings section that allows You to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us. Please note, however, some information like messages between you and Users, reviews and posts may remain on the Platform in a de-identifiable form and may not be deleted. Please also note that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

h. Disclosure of Your Personal Data Business Transactions If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy. Law enforcement Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Other legal requirements The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: § Comply with a legal obligation § Protect and defend the rights or property of the Company § Prevent or investigate possible wrongdoing in connection with the Service § Protect the personal safety of Users of the Platform or the public § Protect against legal liability You acknowledge that the Platform shall not be held liable, in any regard, in relationship to any of the above disclosures.

i. Security of Your Personal Data The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Therefore, YOU PROCEED WITH THE USE OF THIS SERVICE AT YOUR OWN RISK.

3. Detailed Information on the Processing of Your Personal Data The Platform Data and Information Service Provider We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Platform in accordance with their Privacy Policies.

a. Analytics The third-party Platform Data and Information Service Provider We may use to monitor and analyze the use of Our Platform include but may not be limited to: § Plausible Analytics Plausible is a web analytics service that is designed to provide website owners with a privacy focused alternative to some of the other major data analytic services. Plausible collects only data that is essential for analytical purposes and unlike other alternatives, Plausible does not track Users as they navigate from across websites and does not use cookies for the purpose of tracking individual Users. Moreover, Plausible all data collected by Plausible lacks personal identifying information. The function Plausible performs however is similar – It informs website owners what pages are being viewed, how many times its being viewed, and overall activity of a website without collecting User data through cookies or tracking Users individually.

b. Email Marketing We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. We may use Email Marketing Platform Data and Information Platform Data and Information Service Providers to manage and send emails to You. For instance, We may use Mailchimp, a third-party service provider that provides email services to Us. These email services afford Us the ability to contact Users in mass and to provide account notifications when necessary. You acknowledge that this information may be shared with Mailchimp for the aforementioned purposes. For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/ We may also use SendGrid, a third-party service provider that provides email services to Us. These email services afford Us the ability to contact Users in mass and to provide account notifications when necessary. You acknowledge that this information may be shared with SendGrid for the aforementioned purposes. For additional information about the security of your information, please visit SendGrid's privacy policy at https://www.twilio.com/en-us/legal/privacy.

c. Payment Services We use Stripe, a third-party payment processing services to process the purchase of services on Our site. Stripe may collect from You sensitive financial information needed to process payments on the Platform .The payment information used by this third-party payment processing services is not collected or stored by Our Platform. The payment information You provide to this third-party payment processing services is provided to them by you directly and with Your consent. Your relationship with Stripe is governed by their privacy policy. Stripe’s Privacy Policy can be found at https://stripe.com/us/privacy

d. YouTube We may use YouTube, a third-party video streaming Platform, for marketing and informational purposes. User information on Our website may be collected by YouTube by means of a cookie to collect cookie consent preferences as it relates to videos embedded on the site. The cookie registers and collects anonymous statistical data. Youtube’s Privacy Policy can be found at https://policies.google.com/privacy

4. Links to and use of Third Party Services Our Platform may contain links to third party websites that are distinct, independent, separate and unaffiliated with Our Service. If You click on any of these links You will be subjected to the privacy policy of those services of which We share no responsibility. Our Platform may use Third Party Services to acquire information related to your identity and criminal background. You acknowledge that the information these Services provide Us may not be accurate. You also acknowledge that in the event your reputation is harmed, damaged or you experience any other form of injury as a result of Us being in possession of such information, your sole remedy or opportunity for redress - outside of requesting Us to delete the information, is against the Third Party Website or Third-Party Providers.

5. GDPR Privacy a. Legal Basis for Processing Personal Data under GDPR We may process Personal Data under the following conditions: § Consent: You have given Your consent for processing Personal Data for one or more specific purposes. § Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof. § Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject. § Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person. § Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company. § Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company. In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

b. Your Rights under the GDPR The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to: § Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update, request restriction on the processing of Your Personal Data, or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions Yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You. § Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected. § Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes. § Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it. § Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You. § Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

c. Exercising of Your GDPR Data Protection Rights You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

6. CCPA/CPRA Privacy Notice (California Privacy Rights) This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies to all visitors, Users, and others who reside in the State of California and might be applicable to residents of other states.

a. Categories of Personal Information Collected We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which We may collect or may have been collected from California residents within the last twelve (12) months. Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

§ Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: Yes.

§ Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: Yes

§ Category C: Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No

§ Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: No

§ Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No

§ Category F: Internet or other similar network activity. Examples: Interaction with Our Platform or advertisement. Collected: No

§ Category G: Geolocation data. Examples: Approximate physical location. Collected: No

§ Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No

§ Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No

§ Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No.

§ Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: Yes

§ Category L: Sensitive personal information. Examples: Account login and password information, precise geolocation data. Collected: No

Under CCPA/CPRA, personal information does not include: § Publicly available information from government records § Deidentified or aggregated consumer information § Information excluded from the CCPA/CPRA's scope, such as: o Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data o Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

b. Sources of Personal Information We obtain the categories of personal information listed above from the following categories of sources: § Directly from You. For example, from the forms You complete on Our Service, preferences You express or provide through Our Service or information you voluntarily provide Us through the use of Our messaging system or correspondence with Us or other Users.

c. Use of Personal Information for Business or Commercial Purposes We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples: § To operate Our Platform and provide You with Our Service. § To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our Service. § To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about Our Service, We will use that personal information to respond to Your inquiry. § To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. § As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA. § For internal administrative and auditing purposes. § To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities. § Other one-time uses. Please note that the examples provided above are illustrative and not intended to be exhaustive. If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

d. Disclosure of Personal Information for Business and Commercial Use We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Category K: Inferences drawn from other personal information.

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been disclosed. When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

e. Sharing of Personal Information We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third party providers: § Platform Data and Information Service Providers § Our Affiliates § Our business partners § Our Payment Processors § Third party providers to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

f. Personal Information of Minors As detailed in Our Terms of Service, this service is for Users who are 18 years or older. We do not knowingly collect personal information from minors under the age of 18 through Our Service, although certain third party websites that We link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission. If You have reason to believe that someone under the age of 18 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

g. Your Rights under the CCPA/CPRA The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights: § The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used. § The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

o The categories of personal information We collected about You o The categories of sources for the personal information We collected about You o Our business or commercial purposes for collecting or selling that personal information o The categories of third party providers with whom We share that personal information o The specific pieces of personal information We collected about You o If We sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:

§ The categories of personal information categories sold § The categories of personal information categories disclosed § The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. § The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct Our Platform Data and Information Service Providers to correct) Your personal information, unless an exception applies. § The right to limit use and disclosure of sensitive Personal Data. In the event Your sensitive personal information has been collected by Us, You have the right to request Us to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. § The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Platform Data and Information Service Providers to delete) Your personal information from Our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Platform Data and Information Service Providers to:

o Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform Our contract with You. o Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. o Debug products to identify and repair errors that impair existing intended functionality. o Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. o Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). o Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent. o Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us. o Comply with a legal obligation. o Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

§ The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by: o Denying goods or services to You o Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties o Providing a different level or quality of goods or services to You o Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

h. Exercising Your CCPA/CPRA Data Protection Rights In order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us By email: support@kwekence.com Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must: § Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative § Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it We cannot respond to Your request or provide You with the required information if We cannot: § Verify Your identity or authority to make the request § And confirm that the personal information relates to You We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt. For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

i. Website If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell My Personal Information" buttons listed on the Platform to review Your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service. Additionally, You can opt out of receiving ads that are personalized as served by Our Platform Data and Information Service Providers by following Our instructions presented on the Service: § The NAI's opt-out platform: http://www.networkadvertising.org/choices/ § The EDAA's opt-out platform http://www.youronlinechoices.com/ § The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by Your browser, You will need to opt out again.

k. Mobile Devices Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests: § "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices § "Limit Ad Tracking" on iOS devices You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device. m. Limit the Use or Disclosure of My Sensitive Personal Information If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods. We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please contact Us.

l. "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA) Our Platform does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser. m. Your California Privacy Rights (California's Shine the Light law) Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third party providers direct marketing purposes. If You'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us at support@kwekence.com.

7. Children Rights

a. California Privacy Rights for Minor Users (California Business and Professions Code Section 22581) California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered Users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

b. Children's Privacy Our Platform is not designed to be used by anyone under the age of 18 (or the age of majority in your country) . We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

8. Changes to this Privacy Policy We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. When this Policy has been modified, We will post the “Last Updated Date” at the top of the page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Continued use of the Service constitutes acceptance of the modified version of this Policy.

9. Contact Us If You have any questions about this Privacy Policy, You can contact Us: By email: suppport@kwekence.com By visiting this page on Our website: https://kwekence.com/en/infos/privacy