PRIVACY POLICY

At FRESHR, protecting your personal data is our priority.

When you use the application AI Voicer (the "Application"), we may collect personal data about you.

The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").

1. Who is the data controller?

The data controller is FRESHR, joint stock company, registered with the Registry of Trade and Companies of Rouen, under the number 832 905 327 and whose head office is located at 27 Rue Alfred Kastler, Mont Saint Aignan, 76130, France (“Us” or “We”).

1. What personal data we collect?

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

• Identification data (full name, birth date, gender, telephone number associated to a user number, your photo, contact names, contact phone number);
• Data relating to your preferences and tastes (depending on what you tell us);
• Data relating to your credits orders;
• Browsing data (IP address, device information (IDFA), browser type and settings, operating system, and information about your activity in the application (such as timestamps associated with your use, pages and files viewed, searches, and other actions you take, such as features you use), information about one-time events on the device (such as system activity, error reports and hardware settings);
• Any information you wish to send us as part of your contact request.

For Ambassadors only**:**

• Data relating to your professional experiences (university name, experience in marketing and/or communication, LinkedIn URL).

We inform you, when collecting your personal data, whether some of these data are mandatory or optional.

1. On what legal basis, for what purposes and for how long do we keep your personal data?

| Objectives | Legal basis | Data retention period | | --- | --- | --- | | To provide you with our services available on our Application | Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract | All personal data associated to your user number are retained for as long as you use the services. If you are not using the services for 2 years, we will delete all personal data.

In addition, personal data may be archived for probationary purposes for a period of 5 years. | | To propose our Ambassador’s program to our users | Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract | Personal data are retained for the duration of our business relationship.

In addition, personal data may be archived for probationary purposes for a period of 5 years. | | To perform operations related to contracts, orders, invoices, and customer relationship management | Performance of a contract to which you are party | Personal data are retained for the duration of our business relationship.

In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years.

The data related to your credit card is exclusively processed by Apple.

| | To create a database of customers and prospects | Our legitimate interest in developing and promoting our business | For our customers: their personal data are retained for the duration of our business relationship.

For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action). | | To send newsletters, requests and direct marketing mailings | For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news

For our prospects: your consent | Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action) or until you withdraw your consent. | | To answer to your information request and other inquiries | Our legitimate interest in responding to your inquiries | Personal data are retained during the processing of your request and is deleted once the request has been processed. | | To comply with our legal and regulatory obligations | Legal and regulatory obligations | Invoices are archived for a period of 10 years.

In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years. | | To organize contests and promotional operations | Our legitimate interest in winning clientele loyalty and offering them gifts | The personal data is kept for the duration of the contests or promotional operations and may be archived for 5 years for evidential purposes. | | To elaborate analytics (audience, navigation, preferences) | Your consent | The personal data are retained by our analytics tool for 25 months. | | To process data subjects’ requests to exercise their rights | Our legitimate interest in responding to your requests and keeping records of them | If you exercise your right to object to direct marketing: we keep this information for 3 years. |

1. Who are the recipients of your personal data?