OPENWIP – Key Elements of the Privacy Policy

1. Data Controllers

WERLEN IPSUM SAS is responsible for processing personal data. The company processes this data to ensure efficient delivery of its Services in compliance with applicable laws.

2. Data We Collect

The following personal data is collected as part of the Services:

3. How We Use the Data We Collect

We may use the data collected above for the following purposes:

[For Users and Creators]

• Identify and authenticate you and manage your account
• Provide a Service or feature you request, including to respond to your requests, questions and instructions entered via the Services
• Conduct surveys and analyses required for Service improvement
• Send you data and prizes as part of campaigns and events
• Process payment and billing when a user purchases a product or uses a Service that is not free
• Provide you with adapted features, such as recommendation based on your age and/or on your usage information such as the most visited web pages, and additional content adapted to your interests recognized by the Interest tab
• Provide you with advertisements which may include personalized or targeted advertisements (or based on interests)
• Send you email communications or in-product notifications (e.g. pop-up notification, push notification) in connection with our Services, in accordance with the communication preferences you set
• Track and analyze trends, usage and activities in connection with our products and services
• Create unidentified, anonymized or aggregated data
• Provide and protect Digital Content
• Verify your age and provide an age-appropriate experience
• Ensure data security as part of our Services
• Identify, prevent and guard against fraud and other criminal activities, claims for damages and other cases of liability engagement
• Generate statistical data on the use of the Services
• Ensure and monitor the effectiveness and availability of services to improve website and application performance
• Comply with and enforce applicable legal requirements, our legal obligations (particularly tax matters), applicable industry standards as well as our policies, including this Privacy Policy
• Validate transactions and prevent fraud and abuse
• Respond to your information requests and send users important notifications when necessary
• Perform any other activity that was described to you when the data was collected

4. Data Sharing

WERLEN IPSUM shares data to provide Services efficiently and in compliance with applicable laws. We disclose or share personal data about you via the Services as described in the sections that follow:

• Publicly accessible data. Data for which you have voluntarily agreed to be shared with the public, may be viewed by anyone, including those without an account. This data may include your username, profile picture, brief biography, links to social networks, your website, other data present on your public profile as well as any information or content you share with the public.
• Service providers. We may disclose your data to companies providing Services on our behalf, such as companies that help us develop and operate systems for the Service with customer contact centers, as well as customer service and advertising activities (including personalized advertising on our websites, third-party websites or online platforms), to conduct customer satisfaction surveys and billing operations or to send emails on our behalf. These entities are contractually limited in their ability to use your data for purposes other than providing Services at our request.

By acting as service providers in accordance with applicable laws, these suppliers may have access to your personal data in order to provide services and/or comply with obligations arising from the legal relationships that exist between the aforementioned third parties and us. In all cases, we have signed the corresponding confidentiality and data protection agreements with these service providers, in full compliance with current data protection legislation.

• Payment partners. Our payment partners collect and process data related to payments and purchases for payment processing and fraud prevention purposes.
• Advertising Partners. We may share your information to provide you with more targeted advertising and help measure their effectiveness.
• Marketing Partners. We may share your information to allow you to participate in our promotions, promote our Services on other platforms, and measure the effectiveness of our Marketing activities.
• Our Affiliated Companies. We may share your personal information with our subsidiaries for purposes described in this Privacy Policy.
• Other parties in case of legal requirement or necessity for the protection of our Services. In certain cases, we may disclose your data to other parties:
  • to comply with laws or mandatory judicial procedure (for example search warrant or other court injunction);
  • to verify or enforce compliance with the policies that govern our Services; and
  • to protect our rights, property or safety or, in accordance with data protection laws, any of our respective subsidiaries, business partners or customers.
• Other parties in connection with transactions. We may disclose your data to a third party in the context of a merger or assignment, an acquisition or a sale, or in case of bankruptcy.
• Other parties with your consent or at your request. In addition to the disclosure cases described in this Privacy Policy, we may share data about you with third parties when you separately agree to or request this sharing.
• Links to other websites, devices, applications and functions. The Service may give you the possibility to connect to other websites, devices, applications and functions, the operation of which may be independent of us and subject to their own statements or privacy policies, which we strongly advise you to consult. To the extent that any other linked website, device, application or other function is not our property or is beyond our control, we are not responsible for its content, use or privacy practices.

5. Personal Data Retention

We take appropriate measures to ensure that we process and retain data about you according to the following logic:

• for the minimum duration during which the data is used to provide you with a service;
• in application of laws, a contract or in connection with our legal obligations (for example in tax matters); or
• only for the duration required for the purposes for which the data was collected, is processed, or longer in application of a contract, applicable laws, or in anonymized form, for statistical purposes, with appropriate safeguards.

We therefore only retain your personal data as long as we need it for the purposes for which we collect it and to comply with legal, financial, commercial or reporting requirements.

When we no longer need personal data, we delete or destroy it securely. Once these purposes are achieved, your personal data will be deleted or destroyed securely.

We nevertheless continue to store the data collected after this date until the expiration of any legal obligation arising therefrom.

6. Your Rights

Your personal data belongs to you. Depending on the territory in which you reside, you may request detailed data about the data we have collected and ask us to correct any inaccuracies. More specifically, your rights are as follows:

7. Exercise Your Rights and Choices

If you wish to exercise the above rights or make a request, please contact us as indicated in the Contact Us section (section 10 of this Privacy Policy). However, if the law allows it, we may charge you a certain amount to make this possibility available to you. In compliance with applicable laws, we may refuse to process requests that are unreasonably repetitive, require disproportionate technical efforts, endanger the privacy of others or whose access is not required by local laws.

You can access your personal data stored by us or correct it at any time via the "Account" or "Creator Profile" page.

You can ask us to delete your personal data by deleting your account at any time. If you have series published on CONTENT CREATOR, you must first delete them before deleting your account. After deleting your account, your account profile and subscription history will be permanently deleted and cannot be recovered. Any tax information you have sent us will be kept for a certain period, in accordance with tax laws and regulations.

If you wish to modify your communication preferences (including marketing communications), you can make these modifications from the "Account" or "Settings" page. You can also unsubscribe from our communications and commercial solicitations by email at any time by clicking on the "Unsubscribe" button at the bottom of the email.

8. How We Protect Your Personal Data

We take the protection of your data seriously and implement security measures to protect the data we collect in connection with the Services. Data transmission over the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of the data you transmit to us. Within the limits authorized by applicable laws, we reject any form of responsibility in case of disclosure of your data caused by transmission errors, unauthorized access by third parties or other causes beyond our control.

You play an important role in maintaining the security of your data. You should not share your username or account password with other people. If you have reason to believe that your account is no longer secure, please contact us immediately.

9. Personal Data of Minors

The Services are designed for a general audience. If parental consent is required to process a minor's personal data in accordance with applicable laws, we process such data after obtaining parental consent, in compliance with the required legal procedure.

10. Contact Us

You can send any questions, concerns or requests regarding your personal data processing policies to our personal data management service at the following address: contact@werlenipsum.com

11. Reporting and Moderation

Reporting

Users can report any inappropriate content or behavior to: contact@werlenipsum.com

Moderation

OPENWIP reserves the right to moderate, modify or delete any content that does not comply with these Terms of Use, without notice or justification.

Sanctions

In case of non-compliance with these Terms of Use, OPENWIP may take the following measures:

• Warning
• Content removal
• Temporary or permanent suspension of access
• Reporting to competent authorities if necessary

12. Suspension and Termination

Suspension

OPENWIP may suspend access to the Site in case of:

• Non-compliance with these Terms of Use
• Technical maintenance
• Force majeure

Termination

Users may stop using the Site at any time. OPENWIP may also terminate a User's access in case of serious breach of these Terms of Use.

13. Force Majeure

OPENWIP cannot be held responsible for non-performance or delays in the performance of its obligations due to force majeure events, as defined by French case law.

14. Links to Other Websites

You will find hyperlinks on our websites or in the content we provide you (through promotional emails or during events) to access other organizations' websites. Please note that this Privacy Policy does not govern how other companies process your personal data. We recommend that you read the privacy policies that apply to other websites.

15. Updates to Our Privacy Policy

This Privacy Policy may be updated to reflect changes in our personal data management practices related to the Service, or any evolution of applicable laws. We will post a notice on our Service to notify you in advance of significant changes to our Privacy Policy and will indicate in the header of the notice the date of the last update.

International Data Transfer

Additionally, your use of the Services may involve the transfer, storage and processing of your personal data in other countries. These include, but are not limited to, the countries of the European Economic Area, the United States, Japan, Thailand, Indonesia, Taiwan, the Philippines and the Republic of Korea. We will take all appropriate measures, in accordance with applicable laws, to ensure the protection of your personal data. These measures include, for example, the use of standard contractual clauses of the European Commission, when these are applicable, in order to secure the transfer of data outside the EEA and the request for your explicit consent. Furthermore, the European Commission recognizes that certain countries and territories outside the EEA ensure an adequate level of protection of personal data – through decisions referred to by the expression "adequacy decisions". When we transfer personal data from the EEA to third countries that have obtained these adequacy decisions, we are not required to implement alternative mechanisms to legitimize the transfer (such as standard contractual clauses).

Your Rights

When French data protection law is applicable, you also have the right to define directives for the retention and communication of your personal data after your death.