1. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL INFORMATION?

Ubiquity6 is the controller of the personal information we hold about you in connection with your use of the Service. This means that we determine and are responsible for how your personal information is used.

2. PERSONAL INFORMATION WE COLLECT FROM YOU WHEN YOU USE THE SERVICE, AND HOW WE USE IT

2.1 Information you provide to us directly. We collect personal information that you voluntarily submit directly to us when you use the Service. This can include information you provide to us. through the Site, when you download and set up an account on the App, correspond with us by e-mail or otherwise, subscribe to our mailing lists or other forms of marketing communications, when you report a problem with the Service or use some other feature of the Service

2.2 Data collected through the use of the Service. We collect information about how you use the Service, your actions on the Service, and content you post to the Service, including the groups you belong to, your interaction with your friends and with others on the Service, and photos and videos you post to the Service, and any content you provide through in-app messages, chat, or other functionality (“User Content”). We also collect information from your device with your permission, such as your photos, videos, camera, accelerometer data about your mobile device movements, and location. If you need to update your permissions, you can do so in the “Settings” app of your device. Please remember that Ubiquity6 may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Service, you consent to the recording, storage, and disclosure of such communications you send or receive for these purposes

2.3 Address Book information. With your permission, Ubiquity6 may access your contact list available on your mobile device so that you can locate your friends and contacts on the Service and invite your friends and contacts to connect with our Service. When we send the invitation to your friends to join the Service, we will include your name and photo to let them know that you are the person extending the invitation. After sending these invitations, we may also send reminder emails to your invitees on your behalf, which may also include your name and photo. We will store these contacts for purposes of alerting you when your contacts join Ubiquity6 at a later time so that you may connect with them on the Service, and to suggest friends and connections to other members of Ubiquity6. Ubiquity6 may also use the information collected from your contact list and your friends' contact lists to suggest new friends you may want to connect with on the Service. We make these recommendations based on your address book information as well as your friends' address book information and try to find common friendships or connections to introduce you to.

2.4 Location Data. We also use GPS technology to determine your current location. Some of our location-enabled services require your personal information for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling "Location Data" in the App settings

2.5 Registration via Single sign-on. When you first register for an account with us, you have the option of using a single sign-on ("SSO") account. Currently, we offer you the ability to use SSO services provided by Facebook, Google and Apple. If you choose to use those SSO services, we will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties.

2.6 If you choose not to provide such personal information, we may not be able to provide those parts of the Service to you or respond to your other requests.

2.7 The table at Annex 1 sets out in detail the categories of personal information we collect about you and how we use that information when you use the Service, and for users based in the European Economic Area ("EEA") the legal basis which we rely on to process the personal information and recipients of that personal information

3. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY

3.1 We also automatically collect personal information indirectly about how you access and use the Service, and information about the device you use to access the Service. For example, we may collect:

• (a) information about the features you use and the pages you view;
• (b) information about your device (such as your IP address, device identifier, device type, model and manufacturer); and
• (c) information about your usage patterns (such as how often you use the Service and your language settings)

3.2 We use this information to provide you the features and functionality of the Service, to monitor and improve the Service and to develop new products and services.

3.3 The table at Annex 2 sets out in detail the categories of personal information we collect about you automatically and how we use that information. For EEA-based users, the table also lists the legal basis which we rely on to process the personal information and recipients of that personal information.

3.4 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

3.5 We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Service and developing new products and features. We may also share such anonymized and aggregated information with others.

4. HOW LONG WILL WE STORE YOUR PERSONAL INFORMATION

4.1 We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in Annexes 1 and 2, in accordance with our legal obligations and legitimate business interests.

4.2 We may, however, need to retain your personal information for longer if we are required to do so by law

5. RECIPIENTS OF PERSONAL INFORMATION

5.1 We may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):

• (a)Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services. We have listed examples of specific service providers that we use in Annexes 1 and 2.
• (b)Third parties at your request. For example, you may have the option to share your activities, such as maps created on the Service, with your friends through email.
• (c) Business partners: we may share your information with third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the Official Rules of the contest or sweepstakes;
• (d)Affiliates. Other companies owned by or under common ownership as Ubiquity6, including our subsidiaries (i.e., any organization we own or control) and our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.
• (e)Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
• (f)Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the right property, or personal safety of Ubiquity6, its users or others

6. MARKETING AND ADVERTISING

6.1 From time to time we may contact you (by email or via push notifications) with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

6.2 For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

6.3 If you are an EEA-based user, we will only send you marketing emails if you have given us your consent to do so.

6.4 You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences via the App settings. You can also disable push notifications via the App settings

7. PROTECTING, STORING, AND TRANSFERRING YOUR PERSONAL INFORMATION

7.1 Keeping Your Information Safe. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

7.2.International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party Service providers have operations, including in the United States.

8. YOUR CONTROL OVER YOUR INFORMATION

8.1 Profile and Data Sharing Settings. You may update your profile information, such as your user name and profile photo, and may change some of your data sharing preferences (e.g., your visibility settings) by accessing the "Settings" in the App.

8.2 Access to your Device Information. You may control the App’s access to your device information through your “Settings” on your device. For instance, you can withdraw permission for the App to access your location, photo/video library, and camera

8.3 How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

8.4 Modifying or deleting your information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.

9. DISCLOSURES FOR EEA USERS

9.1 Your rights with regard to your personal information.

9.2 If you are accessing the Service from the EEA, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold

• Right of access. The right to obtain:
  • confirmation of whether, and where, we are processing your personal information;
  • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  • information about the categories of recipients with whom we may share your personal information; and
  • a copy of the personal information we hold about you
• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person
• Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
• Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
• Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.

9.3You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

9.4 If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

9.5 You also have the right to lodge a complaint to your local data protection authority. If you are based in the EEA, information about how to contact your local data protection authority is available here.

9.6 Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document

9.7 International transfers of your personal information

9.8 If you are accessing our Service from the EEA, your personal information will be processed outside of the EEA including in the United States

• (a) In the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission
• (b) Ubiquity6 complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States. Ubiquity6 has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
• (c) In compliance with the Privacy Shield Principles, Ubiquity6 commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. In the event that you are concerned about how personal information you have provided to Ubiquity6 has been used, EU and Swiss individuals should first contact Ubiquity6 at [email protected]. Ubiquity6 takes all concerns about privacy and use of personal information very seriously and shall endeavor to reply to you within 45 days of receiving a complaint. If we fail to respond within that time, or if our response does not adequately address your concerns, you may submit your complaint free of charge to JAMS, our designated Privacy Shield dispute resolution provider, by clicking here. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1.
• (d) With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Ubiquity6 is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, Ubiquity6 may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• (e) With respect to personal data transfers to third parties acting as an agent on our behalf, Ubiquity6 shall remain liable under the Privacy Shield Principles if the agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless Ubiquity 6 proves that it is not responsible for the event giving rise to the damage.

9.8 If you have any questions about this Statement or the information that we collect from you in reliance on Privacy Shield, please contact us using the details set out at the end of this Privacy Policy.

10. COOKIES

10.1 Our Service uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") to distinguish you from other users. This helps us to provide you with a good experience and allows us to monitor and analyze how you use and interact with our Service so that we can continue to improve our Service. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements

10.2 Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time

10.3 We use the following types of cookies:

• (a) Strictly necessary cookies. These are cookies that are required for the operation of our Service. They include, for example, cookies that enable you to log into your account.
• (b) Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Service when they are using it. This helps us to improve the way our Service works, for example, by ensuring that users are finding what they are looking for easily.
• (c) Functionality cookies. These are used to recognize you when you return to our Service. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org. For more information about tracking technologies, please see Section 11 below

10.4 Please see Annex 3 for more information about the specific cookies we use on the Service.

10.5 The cookies we use are designed to help you get the most from the Service but if you do not wish to receive cookies, most browsers and devices allow you to change your cookie settings. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Service. These settings will typically be found in the "options" or "preferences" menu of your browser.

10.6 For mobile users, you have controls in your device Operating System that enables you to choose whether to allow cookies or share your advertising ID with companies like Ubiquity6 orour advertising service providers. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’ To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest-based ads’.

10.7 Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

11. TRACKING TECHNOLOGIES USED IN OUR EMAILS

11.1 Our emails may contain tracking pixels that identify if and when you have opened an email thatwe have sent you, how many times you have read it and whether you have clicked on any linksin that email. This helps us measure the effectiveness of our marketing email campaigns, makethe emails we send to you more relevant to your interests and to understand if you have openedand read any important administrative emails we might send you

11.2 Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generallygive you the option of choosing whether emails will display "remote images", "remote content"or "images" by default

11.3 Some browsers also give you the option of downloading and installing extensions that blockpixels and other tracking technologies

12. LINKS TO THIRD PARTY SITES

12.1 The Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites

13. OUR POLICY TOWARDS CHILDREN

13.1 The Service is not directed at persons under 13 and we do not knowingly collect personal information from any persons under 13. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us

14. CHANGES TO THIS POLICY

14.1 We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the "last modified" date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page

15. NOTICE TO YOU

15.1 If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by a notification within the App. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy

16. CONTACTING US

Please contact [email protected] if you have any questions, comments and requests regarding this Privacy Policy.

This Privacy Policy was last modified on March 24, 2020.

ANNEX 1 – PERSONAL INFORMATION YOU PROVIDE TO US

Category of personal information	How we may use it	EEA legal basis for the processing	Recipients of personal information
Profile information such as your name, make and model of your mobile device, phone number, birth date and profile picture	We may use this information to set up and authenticate your account on the App.	The processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you, namely our Terms of Service.	We may share this information with cloud service providers including Amazon Web Services, Inc . and Google LLC (in respect of the Firebase cloud). Note that Amazon Web Services, Inc . is the only recipient in respect of your profile picture.
	We may use this information to communicate with you, including sending service-related communications.	The processing is necessary for the performance of a contract with you, namely our Terms of Service
	We may use this information to send you unsolicited marketing communications in accordance with your preferences.	We will only use your personal information in this way to the extent you have given us consent to do so
	We may use this information to deal with enquiries and complaints made by or about you relating to the Service	The processing is necessary for our legitimate interests, namely administering the Service, and for communicating with you effectively to respond to your queries or complaints
Data collected through the use of the Service . We collect information about how you use the Service, your actions on the Service, and content you post to the Service, including the groups you belong to, your interaction with your friends and with others on the Service, and photos and videos you post to the Service, and any content you provide through in-app messages, chat, or other functionality	We may use this information to facilitate your use of the Service, and to communicate with you, including sending service-related communications.	The processing is necessary for the performance of a contract with you, namely our Terms of Service.	We may share this information with cloud service providers including Amazon Web Services, Inc .
	We may use this information to deal with enquiries and complaints made by or about you relating to the Service.	The processing is necessary for our legitimate interests, namely administering the Service, and for communicating with you effectively to respond to your queries or complaints
Address Book Information. With your permission, Ubiquity6 may access your contact list available on your mobile device so that you can locate your friends and contacts on the Service and invite your friends and contacts to connect with our Service	We may use the information to locate your friends and contacts on the Service and, on your behalf, invite them to connect with our Service	We will only use your personal information in this way to the extent you have given us consent to do so.	We may share this information with cloud service providers including Amazon Web Services, Inc.
Location Data.	We use GPS technology to determine your current location in order to provide you with content of other users that is more relevant to you based on your location.	The processing is necessary for our legitimate interests, namely administering the Service. We will only use your personal information in this way to the extent you have given us consent to do so	We may share this information with cloud service providers including Amazon Web Services, Inc . and Google LLC (in respect of the Firebase cloud).
Content you record by using the camera on your device. When you choose to record content by using the camera on your device, we will receive the images and/or videos as a result of that recording.	We use this information to create precise 3D reconstructions, in order to provide you with the features and functionality of the Service	We will only use your personal information in this way to the extent you have given us consent to do so	We may share this information with cloud service providers including Amazon Web Services, Inc.
Information received from third parties. If you register with the Service using your Facebook, Google or Apple SSO details, we may receive information from the relevant third party (such as your name, user ID and email address) in accordance with the authorization procedures determined by those third parties	We may use this information to allow you to register with and access the Service	The processing is necessary for the performance of a contract with you	We may share this information with cloud service providers including Amazon Web Services, Inc
Your preferences , such as preferences set for notifications, marketing communications, how the Service is displayed and the active functionalities on the Service	We use this information to provide notifications, send news, alerts and marketing communications and provide the Service in accordance with your choices. We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.	The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications, and that this is displayed in accordance with the user's preferences. The processing is necessary for compliance with a legal obligation to which we are subject.	We may share this information with cloud service providers including Amazon Web Services, Inc.
All personal information set out above	We may use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to communicate with you, to monitor and improve the Service and business, and to help us develop new products and services.	The processing is necessary for our legitimate interests, namely to administer and improve the Service.	As described above and in section 5.

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information	How we may use it	EEA legal basis for the processing	Recipients of personal data
Information about how you access and use the Service. For example, how frequently you access the Service, the time you access the Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, and other actions you take on the Service	We may use information about how you use and connect to the Service to present the Service to you on your device	The processing is necessary for our legitimate interests, namely to tailor the Service to the user	We may share this information with cloud service providers including Amazon Web Services, Inc . and Google LLC (in respect of the Firebase cloud)
	We may use this information to determine products and services that may be of interest to you for marketing purposes	The processing is necessary for our legitimate interests, namely to inform our direct marketing.
	We may use this information to monitor and improve the Service and business, resolve issues and to inform the development of new products and services.	The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Service and to improve the Service generally
Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect to the Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Service through the device, your mobile network, your IP address and your device’s telephone number (if it has one)	We may use information about how you use and connect to the Service to present the Service to you on your device. We may use this information to determine products and services that may be of interest to you for marketing purposes	The processing is necessary for our legitimate interests, namely to tailor the Service to the user. The processing is necessary for our legitimate interests, namely to inform our direct marketing
	We may use this information to monitor and improve the App and business, resolve issues and to inform the development of new products and services	The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Service and to improve the Service generally

ANNEX 3 – COOKIES

Type of cookie	Third party	Persistent / session	Purposes / Additional information
Analytical / performance	Google Analytics	Persistent	We use Google Analytics to gain insights into how users use our Service, and to improve the functionality of the Service. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
Advertising	Google DoubleClick	Persistent	Doubleclick is Googles real time bidding advertising exchange; DoubleClick cookies are used to for serving targeted advertisements that are relevant to users across the web. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt- out options at https://tools.google.com/dlpage/gaoptout
Analytical / performance	FullStory	Session	FullStory sets a cookie to better understand how visitors use our Site (pages visited, links clicked etc.). This helps us know how to improve our Site and our Service. You can learn more about the data collected by FullStory here https://www.fullstory.com/resources/fullstory-gdpr-you/