Privacy Notice

Introduction

WT PUBLISHING LTD ("Kweeks," "we," and "us") operates the Kweeks website, mobile application, and associated products and services (collectively the "Services"). This Privacy Notice explains how we collect and process personal information through your use of these Services.

You understand and agree that we may store and process your personal information on computers located outside your jurisdiction, including the United States or European Union. By using the Services, you consent to this collection and processing outside your home jurisdiction.

Please review this Privacy Notice carefully before using the Services or providing information to us. By accessing the Services, you agree we may collect and use your personal information according to this Privacy Notice, as revised from time to time. We may modify, amend, replace, or suspend this Privacy Notice at any time.

Contact Information

If you have questions or suggestions regarding this Privacy Notice, or if your personal information requires correction:

WT PUBLISHING LTD
Digeni Akrita, 1, Blue Ocean Building Mezzanine Floor
Limassol, Cyprus 3035

Email: privacy@kweeks.com

Legal Capacity and Agreement

By providing personal data and using the Services, you warrant that you have the right and legal capacity to enter into this Agreement and adhere to its terms and conditions.

Children's Online Privacy Protection Act (COPPA) Compliance

Kweeks complies with COPPA requirements. Minors aged 13-17 may access the Services only with verifiable parental consent. By permitting a Minor to use the Services, parents or legal guardians agree to the collection, use, and disclosure of the Minor's personal information as described in this Privacy Notice and acknowledge responsibility for the Minor's activity.

Kweeks provides parental control features to facilitate oversight of Minors' access and use. Without verifiable parental consent, Minors will be denied access.

You warrant that you are either eighteen (18) years or older, or a Minor with verifiable parental consent. You warrant you are not a bot, script, or other computer or machine, and are not prohibited from assenting to this Agreement by any preexisting agreement. If using the Services on behalf of a third party, you warrant you are the authorized representative with authority to bind that party.

Third-Party Links and Control

The Services may include links to third-party websites and analytics tools owned and maintained by third parties. Kweeks does not control the privacy practices of these third-party providers. You are encouraged to review the privacy practices disclosed in this Privacy Notice and those of all third-party websites or analytics tools.

What Data We Collect, How and Why, and How We Use and Secure It

When you use the Services, we collect personal or personally identifiable information ("PII"). PII includes information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. This excludes anonymized data.

We collect and process the following categories of PII:

Communication Data

Communication data includes communications you send through the Services via email, telephone, text, live chat, or social media. We process this data to:

• Communicate with you
• Provide customer support
• Record communication logs
• Store information to respond to legal claims

Lawful Ground: Responding to communications and pursuing or defending against legal claims.

User Data

User data includes information about how you use the Services and data you post or authorize through the Services, such as name, address, country, phone number, and email address. This includes data stored in persistent cookies upon login and analytics data collected during your use.

We collect and process this data to:

• Operate the Services
• Authenticate you as a user
• Ensure timely and relevant content delivery
• Secure the Services
• Ensure fast and efficient operation
• Maintain backups

Lawful Ground: Legitimate business interests in administering and offering the Services and fulfilling your orders.

Technical Data

Technical data includes information about your use of the Services, such as IP address, login data, phone number, mobile device model, operating system, geolocation, and time zone. We may collect this from your use of the Services and from advertising IDs or pixels.

We process this data to:

• Analyze your use of the Services
• Route traffic
• Administer and secure the Services
• Provide location-relevant content
• Troubleshoot problems

Lawful Ground: Legitimate interests in administering and offering the Services and growing our business and marketing strategy.

Marketing Data

Marketing data includes information about your actions and preferences regarding Kweeks' advertisements or content on the Services or third-party websites or applications. We collect this from your use of the Services and from third-party advertising IDs created through advertising programs and pixels (such as Google Advertising IDs and Facebook Advertising IDs).

Important: Kweeks does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs.

Lawful Ground: Legitimate interests in administering and offering the Services and growing our business and marketing strategy by providing advertisements, including remarketing advertisements.

Use of Personal Information

Kweeks uses your PII only for the purpose for which it was collected. If we need to use your PII for an unrelated, new purpose, we will provide notice of this new use and explain the lawful ground for such processing. We may process your PII without your knowledge or consent where required or permitted by law. Where consent is required by applicable law, we will request and rely on your affirmative consent before collecting or using your data for marketing or tracking purposes.

How Do We Collect This Information?

We collect PII through various means:

Direct Collection

We may collect PII when you:

• Purchase Services
• Register a User Account
• Contact us through the Services, live chat, social media, telephone, or email
• Respond to a survey
• Submit a review or feedback
• Opt-in to receive marketing emails

Third Party Tracking Tools

We use third-party tracking tools, such as pixels, web beacons, and cookies, to automatically collect PII when you open, view, or click pages, links, emails, or advertisements. These third-party tracking tools are disclosed below in this Privacy Notice.

Business Partners and Service Providers

We may obtain PII from business partners or service providers. When we obtain PII from these parties, we ensure they have obtained your consent to transfer such PII to us for its intended uses.

Social Media Networks and Other Platforms

We may obtain PII when you interact with our social media accounts or content posted on third-party platforms such as Facebook, X, or YouTube.

Analytics Providers

We may obtain PII through third-party analytics providers, such as Google Analytics or Amplitude.

What Information Do We Collect From Third Parties?

Kweeks may collect data about you through cookies and other technologies to understand how you use the Services and patterns associated with that use. This helps us develop or improve our Services and marketing communications in response to your needs or wants.

Cookies

Session Cookies: Session cookies are stored on your computer or mobile device only during your use of the Services and are automatically deleted when you close your web browser.

Persistent Cookies: Persistent cookies are stored as a file on your computer or mobile device and remain even after you close your web browser. Persistent cookies can be read by the Services that created the cookie when you revisit.

Kweeks may use persistent cookies to:

• Authenticate you when you return to the Services so you don't need to login again
• Utilize Google Analytics or other analytics providers to track the origin and behavior of traffic to the Services

Tracking Pixels

Kweeks may use tracking pixels to:

• Track how often a specific page of the Services is visited
• Capture IP addresses, browser types and versions, device types, and geographic locations
• Identify when a user submits a form or purchases Services
• Measure impressions, clicks, or post-click conversions for analyzing advertising campaigns

Analytics Providers

Kweeks uses the following analytics providers (review their respective privacy policies):

• Amplitude: https://amplitude.com/privacy
• Google Analytics: https://support.google.com/analytics/answer/7318509?hl=en

Opt-out of Google Analytics: https://tools.google.com/dlpage/gaoptout

How We Use Pixels on Our Site

We want to be transparent about how we collect and use data when you visit our website. Like many websites, we use tracking technologies (pixels) to help us understand how visitors interact with our site and improve our marketing efforts.

What Are Pixels?

A pixel is a small piece of code added to our site. When you visit, this code helps us track actions you take, such as:

• Clicking on a link
• Viewing a page
• Making a purchase

Pixels send this information back to the pixel provider, which helps us:

• Show you more relevant ads
• Measure the effectiveness of our ads by seeing if people who click on them engage with our site
• Improve your experience by understanding what content and features are most useful

Important: These pixels do not collect personal details like your name, email, or phone number. They track actions and behaviors only.

Your Consent

By using our website, you consent to the use of pixels as described above. If you don't want pixels to track your activity, you can:

• Adjust your privacy settings on third-party websites to limit ad tracking
• Use browser settings or extensions that block tracking technologies
• Opt-out through the Digital Advertising Alliance or your device's privacy settings

Opting Out

We respect your privacy. If you have concerns or questions, contact us at privacy@kweeks.com.

How Do We Use Your Information for Marketing Communications?

Kweeks's lawful ground for sending marketing communications is either consent or legitimate business interests, such as growing our business by advertising products and services to you. We may send marketing communications if you have asked for information about our services or agreed to receive marketing communications and have not opted out.

Opting Out: You may ask Kweeks to stop sending marketing messages at any time by:

• Logging into the Services to adjust marketing preferences in your User Account
• Following the opt-out link in any marketing message

If you opt out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.

When Do We Disclose Your Information?

Kweeks may share your PII with the following parties:

• Service providers that provide information technology, software as a service, cloud storage, or other administrative services
• Kweeks's accountants, auditors, insurers, or attorneys
• Law enforcement agencies upon receipt of a subpoena or court order or where necessary to protect Kweeks's personnel or property
• Government bodies that require Kweeks to report its processing activities

Business Transfers: Kweeks may transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.

How Do We Protect Your Information?

We implement a variety of security measures to maintain the safety of your personal information. However, no security measures are impenetrable and security risks always exist. We will notify you and any regulatory body of any breach of your PII or our security measures if legally required to do so.

Kweeks allows access to your PII only by employees and service providers who have a need to know or access your PII on our instructions.

Do We Use Cookies?

Yes, as stated above, we may use persistent and session cookies. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enable sites or service providers' systems to recognize your browser and capture and remember certain information.

We may use cookies to:

• Help us remember and process items in your shopping cart
• Understand and save your preferences for future visits
• Compile aggregate data about site traffic and site interaction to offer better experiences and tools

Important: We never use cookies to store sensitive customer information such as names, addresses, passwords, or credit card information.

For How Long Do We Retain Your Data?

We will retain your PII only as long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for satisfying any legal, accounting, or reporting requirements.

With respect to location data, technical data, usage and interaction data, and marketing data, we may retain this data for so long as it is relevant to the uses disclosed in this Privacy Notice.

We may retain account data, public data, and communications data for so long as you maintain a User Account with Kweeks, and we may retain this data for longer periods where there is a need to comply with Kweeks's legal obligations, such as preservation of electronic evidence or compliance with a preservation order.

Email Marketing – User Consent

By opting into email marketing, you consent to receive promotional messages, including e-newsletters. You can opt out at any time by:

• Clicking the "Unsubscribe" link in an email
• Emailing us at privacy@kweeks.com

Your Privacy Choices

Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact our Privacy Officer.

You do not need to pay a fee to access your PII or exercise your rights. However, we may charge a reasonable fee if your request is unreasonable or excessive.

To confirm your request, we may request specific information from you as a security measure to ensure PII is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

Rights of European Citizens

European citizens have the following rights:

• The right to access and correct the information that Kweeks processes about you
• The right to transfer all or part of the information collected about you to another data controller, where technically feasible
• The right to erasure of data concerning you, subject to Kweeks's rights of retention under law
• The right to object to the processing of Personally Identifiable Information and Personal Data where you dispute the accuracy of the data, the processing is not lawful, Kweeks no longer needs the information for processing purposes, or you have raised an objection for personal reasons
• The right to revoke your consent to data processing
• The right to object to the processing of your Personally Identifiable Information and Personal Data for marketing purposes
• The right to object to the processing of Personally Identifiable Information and Personal Data for direct marketing or for personal reasons arising from your particular situation
• The right to file a complaint with a data protection authority

Exercising These Rights: You may exercise these rights by:

• Opting out of receiving communications by unsubscribing from our emails
• Emailing us at privacy@kweeks.com

You do not need to pay a fee to exercise these rights, however, we reserve the right to charge a reasonable fee if your request is unreasonable or excessive. To confirm your request, we may request specific information from you as a security measure to ensure personal data is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

California Privacy Rights

The following rules apply solely to California residents.

California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. We collected the following categories of PII as defined in the California Consumer Privacy Act within the last twelve months:

• A. Identifiers: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• B. Personal information (Cal. Civ. Code § 1798.80(e)): Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
• D. Commercial: Records of products/content or services purchased.
• F. Internet or similar network activity: Browsing history, search history, information on a consumer's interaction with Services, application, or advertisement.
• G. Geolocation data: Physical location or movements.

We obtain the categories of PII directly from California residents when they complete forms through our Services or provide it as part of a transaction or inquiry concerning our Services. We also obtain these categories indirectly while observing their actions on our Services and from third parties or service providers that they have authorized to receive and share PII.

California Rights: California residents have a right to request that we disclose:

• What PII we collect from you
• Whether, and how, we disclose or sell that PII

California residents may also request that we delete any personal information collected or maintained by us from you.

Opt-Out of Sale: California residents may have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. This link or icon may state "Do Not Sell My Personal Information."

However, even if you opt out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, visit optout.aboutads.info.

Submitting Requests: To submit a request for a list of categories of personal information collected from you or to request deletion of your personal information:

WT PUBLISHING LTD
Digeni Akrita, 1, Blue Ocean Building Mezzanine Floor
Limassol, Cyprus 3035

Or email: privacy@kweeks.com

Other U.S. State Disclosures

Colorado

Kweeks does not conduct business in Colorado, control or process the personal data of 100,000 or more consumers during a calendar year, or derive revenue or receive a discount on the price of goods or services from the sale of personal data.

Connecticut

During the preceding calendar year, Kweeks did not control or process the personal data of at least 100,000 consumers or derive more than 25% of our gross revenue from the sale of personal data.

Florida

Kweeks does not control or process the personal data of 100,000 or more Florida residents during a calendar year, nor do we derive 50% or more of our gross annual revenue from the sale of personal data. The Florida Digital Bill of Rights does not apply to our data practices.

Montana

Kweeks does not control or process the personal data of 50,000 or more Montana residents during a calendar year or derive over 25% of its revenues from the sale of personal data and control or processing of personal data of 25,000 or more Montana residents. The Montana Consumer Data Privacy Act does not apply to our collection or use of PII.

Nevada

If you are a Nevada resident, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use.

To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, contact us at privacy@kweeks.com and include in the message field, "Nevada Do Not Sell Request," along with your name, address, and user account information.

Oregon

Kweeks does not control or process the personal data of 100,000 or more Oregon residents during a calendar year or derive over 25% of its gross revenue from the sale of personal data. The Oregon Consumer Privacy Act (OCPA) does not apply to our collection or use of PII.

Tennessee

Kweeks does not exceed $25 million in annual revenue, control or process the personal information of 175,000 or more Tennessee consumers, or control or process the data of 25,000 consumers while deriving more than 50% of its gross revenue from the sale of personal information.

Texas

Kweeks is considered a small business as defined by the Small Business Administration and is therefore exempt from the Texas Data Privacy and Security Act. However, we generally collect and process PII only to the extent that it is adequate, relevant, and reasonably necessary for the purposes disclosed in this Privacy Policy.

The categories of PII collected by Kweeks are disclosed within this Privacy Policy, particularly in the California disclosures above. Texas residents may request, free of charge, information of the PII collected from them twice annually.

Utah

Kweeks does not have annual revenues of $25,000,000 or more and control or process the PII of 100,000 or more consumers. The Utah Consumer Privacy Act does not apply to our collection and use of PII.

Virginia

Kweeks does not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of its gross revenue from the sale of personal data. The Virginia Consumer Data Protection Act (VCDPA) does not apply to Kweeks's collection and use of PII.

Future Updates: If Kweeks becomes subject to one or more of the above State's privacy laws other than California's privacy laws, we will update this Privacy Notice to reflect your rights under those laws.

Third Party Links

Kweeks's Services may include links to third-party websites and applications. By clicking on third-party links, you may allow third parties to collect or share data about you. Kweeks does not control these third-party links and you are advised to review their respective privacy policies.

Responding to Do Not Track Signals

You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI Services and DAA Services.

Our Services is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what "do not track" means in this context. However, you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at http://optout.aboutads.info/

Children's Online Privacy Protection Act Compliance

We comply with the requirements of COPPA (Children's Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age, and our products and services are aimed at individuals 13 years of age or older.

If you believe that we have collected PII from someone under the age of 13, you are directed to notify us immediately at privacy@kweeks.com.

Changes to our Privacy Notice

Whenever we change our Privacy Notice, we will post those changes to this Privacy Notice on the Services and other places that we deem appropriate and, if necessary, provide you with notice via email. Your use of our Services following these changes indicates your consent to the practices described in the revised Privacy Notice.

Contacting Us

If you have any questions about this Privacy Notice or the manner by which we collect or use Personal Information about you, contact us at privacy@kweeks.com.