Updated: March 2023

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1. PROLOGUE. REGIONAL FRAMEWORK (CALIFORNIA)

UNITEDREAMS Inc. (herein referred to as “we,” “us” or “our”) regards your privacy as paramount. This Privacy Policy (“Privacy Policy”) clarifies our data protection guidelines and elucidates the kinds of information we may process when you install and/or utilize the “Owlkeyboard” mobile device software application (referred to as the “App” or "our App").

When we refer to personal data (or personal information), we mean any form of data that pertains to an identifiable individual, who can be discerned, directly or indirectly, particularly through such data.

This individual can be identified directly or indirectly, especially in reference to an identification number or to one or more elements specific to his or her physical, physiological, mental, economic, cultural, or social identity.

Our Privacy Policy is applicable to all users and others who access the App (“Users”).

In terms of the GDPR, we are the data controller unless otherwise specified.

WE EMPHASIZE THAT YOU READ THE FOLLOWING PRIVACY POLICY CAREFULLY FOR DETAILS ON HOW YOUR PERSONAL INFORMATION MAY BE PROCESSED. BY USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND CONSENT TO BE BOUND BY THESE TERMS.

IF YOU ARE A RESIDENT OF CALIFORNIA, PLEASE READ THE FOLLOWING CRUCIAL NOTICE

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), residents of California are entitled to request:

• the categories of personal information being processed;
• the categories of sources from which personal information is derived;
• the intent for processing user personal data;
• the categories of third parties with whom your personal information may be shared;
• the specific pieces of personal information we may have collected about a particular user, provided that the data provided in the request is reliable enough to identify the user.

Please use the navigation links to guide you through this Privacy Policy:

PERSONAL INFORMATION

Details pertaining to the categories of information, their sources, and processing objectives >>

Please note, according to the CCPA, personal information does not encompass de-identified or aggregated consumer data.

SHARING

Details on the potential sharing of your information >>

Be aware that all third parties involved in processing user data are service providers who utilize such data based on contractual agreements and for specific business purposes.

OPT-OUT OPTIONS

If you wish for us to cease processing your personal data, please reach out to us via the [contact form]. In most instances, our App's continuous operation is not possible without functional data; hence, you may need to uninstall the App from your device.

If you prefer that we not share device identifiers and geolocation data with service providers, please adjust your device settings to opt-out as described below >>

REQUESTS

To place a verifiable consumer request for access, portability, or deletion of personal data, contact us through the [contact form]. Please incorporate the phrase "Your rights to maintain confidentiality in the state of California" in your appeal.

When making a verifiable request, you should be prepared to:

• Supply adequate information that allows us to reasonably confirm you are the individual we collected personal data about, or an authorized representative. This information may include: name, address, city, state, zip code, and email address. We may use this information to present a sequence of security questions to verify your identity. If your request is being made through an authorized agent, this agent must provide written authorization or a power of attorney, signed by you.
• Explain your request with sufficient detail that allows us to properly comprehend, assess, and respond.

We will be unable to fulfill your request or provide personal data if we cannot: (i) confirm your identity or authority to make the request; or (ii) verify that the personal data pertains to you. We may require additional information or documents to verify your identity. We might also conduct checks, including with third-party identity verification services, to validate your identity before proceeding with your personal data. This is a preventative measure against fraudulent requests. We assure that personal data provided in a verifiable consumer request will be used solely to verify the requester’s identity or authority and for no other purpose. We will retain it for a reasonable period necessary for the described purpose and delete it once the purpose is accomplished. We strive to respond to verifiable consumer requests within forty-five (45) days of receipt. If additional time is required, we will provide a written explanation for the delay and extension period. Please note we are only obliged to respond to two requests per customer each year.

EQUAL RIGHTS

Our handling of your request shall not be construed as discriminatory. We will not alter pricing, products, or the level or quality of services based on your exercise of rights. However, under certain circumstances, we may be unable to provide services if you opt to erase your personal data from our records.

• SALE OF DATA
• We do not sell any of your personal data to third parties.
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• II. INFORMATION WE PROCESS
• We process various categories of information.
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• Functional Information and Information that You Submit
• We process specific personal data about you when you use the App. This data is essential for adequate performance of the contract between you and us. Without this data, we cannot provide complete functionality of the App or deliver the requested services.
• •       Activity Information directly related to your use of the App: Once you permit access to your keyboard, we may see your messages as you type them. However, we never collect, store, or use this information.
• •       Contact Information (name, email address, as well as any other content included in the email) which you provide when you contact us via email or the support form. This information is collected, stored, and processed by our cloud storage provider (Amazon.com, Inc.). We use this information to respond effectively to your inquiries, fulfill your requests, and send you communications that you request.
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• Information That Is Processed Automatically
• Based on your permission, we use third-party automated data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices). Some integrated advertising or analytics tools (refer to Section IV for the list) initiate automated processing of your personal data, including profiling. Profiling refers to any form of automated processing of personal data used to evaluate certain personal aspects relating to you, particularly to analyze or predict aspects concerning your personal preferences, interests, behavior, location, or movements (see the list of data described below). The processing of information through automated data processing technologies begins automatically once you permit our App to track your activity. You can withdraw your permission at any time - please see opt-out options in Section VIII below.

We may process some information about your device and your user behavior based on our legitimate interest. This information falls within the categories of data described above in the Subsection "Information That Is Processed Automatically". It is generally non-personal, i.e., it does not, on its own, permit direct association with any specific individual, and we access it only in an aggregated form. We use this information to improve our App and provide our users with the best experience.

Device Details: When you access our App via a mobile device (tablet, phone, smartwatch), some details about your device are reported, including "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not you personally). These identifiers enable third parties to provide generalized reporting or personalized content and ads. Data that can be processed includes:

• Device information: Type of device, operating system type and version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
• Internet connection information: Mobile carrier, network provider, network type, IP address, session timestamps and duration, speed, browser.
• Location-related information: IP address, country code/region/state/city associated with your SIM card or device, language setting, time zone, neighboring commercial points of interest (e.g., "coffee shop").
• Device identifiers: Identity For Advertisers for iOS devices/Advertising ID or Android ID for Android devices, user identifiers.

Information about Applications: Name, API key (application identifier), version, properties of our App can be reported for automated processing and analysis. Some services also record the list of applications and/or processes installed or running on your device.

Cookies and Similar Technologies: When you use the App, cookies and similar technologies (pixels, web beacons, scripts) may be used. These technologies allow us to operate the App more effectively. For instance, we will know how many users access specific areas or features within our App and which links or ads they clicked on.

Log File Information: Log file information is automatically reported each time you make a request to access the App or when the App is installed on your device. Analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.

Ad-Related Information: Data about the ads you view may be reported, including the date and time an ad is served, whether the ad was "clicked" or shown as a "conversion" event, the ad's content, its type (e.g., text, image, or video), the ad placement, and whether you responded to the ad.

In-App Events: When you use our App, analytics tools automatically record your activity information, including tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, methods of limiting the processing of user data.

Information Provided Automatically: The information provided automatically to advertising or analytics tools is generally beyond our control, thus we cannot be responsible for its processing. Some services may engage in personal data profiling using technologies that we do not control. If your user ID is linked to your Facebook account, for example, Facebook may use your device information in association with their already recorded categorized data (like your age, gender, etc.). We do not control or supervise how third parties process your personal data. Any information requests regarding the disclosure of your personal information should be directed to these third parties (see Section IV).

Payment Information: Our e-commerce provider (Apple) is responsible for billing, processing, and securing in-app purchases. We do not have access to your credit or debit card information. You can access the applicable "in-app" purchase rules and policies directly from the app stores.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

We use your information for the following purposes:

(a) To provide our service: We use functional information, information you submit, and automatically processed information to deliver all requested services.

(b) To improve our App: We use automatically processed information to understand user behavior and trends, detect potential outages and technical issues, and to operate, protect, improve, and optimize our App.

(c) For Interest-based Advertising: We may use automatically processed information for marketing purposes to show ads that may be of interest to you based on your preferences.

(d) To communicate with you: We use the information we have to communicate with you through newsletters, send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e) To prevent fraud and enforce the law: We use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks, and enforce our Terms of Use.

If any new purposes for processing your personal data arise, we will update this Privacy policy accordingly before we start processing information for that purpose.

1. SHARING OF YOUR INFORMATION

We only share your information with third parties as described in this Privacy Policy. We follow the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment. While we partner only with third parties that assure us of the necessary technical and organizational measures to protect your personal data, we cannot guarantee the security of any information transmitted from the App directly to such a third party. We are not responsible for any accidental loss or unauthorized access to your personal data caused by third parties.

We will not rent or sell your personal data to any third parties. However, we may share information from tools like cookies, log files, and device identifiers and location data with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties' tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, among others, to deliver targeted advertisements that they believe will be of most interest to you.

We may engage the following third-party service providers to help us deliver and improve our services:

1. INTERNATIONAL DATA TRANSFERS

We operate in a cross-border area and provide our App to users worldwide. We and third-party organizations that provide automatic data processing technologies for the App, or our third-party advertising partners, may transfer automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means your personal information can be transferred to a third country, territory, or one or more specified sectors within that third country, or to an international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

We strive to ensure that any recipient of personal data provides adequate protection for the personal data received, in accordance with current legislation protecting such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

For data storage purposes, we use the services of hosting organizations. We take your privacy seriously and therefore, where possible, encrypt your personal data before sending it to the hosting organizations for storage. Please note that we only work with hosting organizations that have passed our security and reliability checks.

1. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary to provide the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (such as taxation, accounting, audit) or to maintain safety and data backup settings, prevent fraud, or other malicious acts.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

• Data Access and Portability: You can request copies of your personal information.

• Change or Correct Data: Where you cannot update data by yourself through your account, you have the right to ask us to correct, change, update, or rectify your data.

• Data Retention and Deletion: User data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on the context of the processing we perform. You have the right to ask us to delete all or some of the personal data that we hold about you.

• Restriction of Processing: Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us through [contact form]. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

When your personal information is processed automatically, you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. To exercise your right, please contact the third-party services listed in Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API, or other options.

If you are located in the European Union, you may address our representative, Konrad Gutowski at [email protected], with any questions on privacy issues.

VIII. HOW TO OPT OUT

Opt-out of marketing tracking:

If you do not want third-party service providers to display personalized ads based on your interests, please follow the instructions below:

• Choose the "Limit Ad Tracking" option on your iOS device in Settings > Privacy > Advertising. Find additional information here: https://support.apple.com/en-us/HT202074.
• You can also visit https://youradchoices.com for the same purpose.

Please note that when you opt out of interest-based advertising, you may still receive contextual ads based on other non-personal information, such as ads related to the content of the digital products you are using.

Opt-out of Location Data Processing:

If you do not want third-party service providers to use your precise location data or street-level location information, please follow the instructions below:

• For iOS 11 or later: turn off Location Services for the applicable Product via the menu "Settings > Privacy > Location Services". Then select the applicable App and set the "Share My Location" status to "Never". See additional information here: https://support.apple.com/en-us/HT203033.

1. SECURITY

Your personal information's security is of utmost importance to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

Despite our best efforts, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. If your personal information is compromised as a result of a security breach, we will notify you promptly in compliance with applicable law.

If you have any questions about our App's security, you can contact us through the email or contact form provided.

1. CHILDREN’S PRIVACY

Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. If we learn that we have collected personal information from a child under age 18 without parental consent verification, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

1. CHANGES TO THE PRIVACY POLICY

This Privacy Policy is updated regularly. Whenever we make changes, we will post those changes to this Privacy Policy and other places that we consider appropriate.

XII. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us via [support form].

Copyright © 2023 UNITEDREAMS Inc.