PRIVACY POLICY

This Privacy Policy for swolemate ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Use the swolemate mobile app, or any platform of ours that links to this privacy notice ("Site")
• Engage with us in other related ways, including any sales, registrations, marketing, or events

BY USING THE SITE OR SERVICES, YOU ARE CONSENTING TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at helloswolemate@gmail.com.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with swolemate and the Services, the choices you make, and the products and features you use. For further detail on the categories of information we collect and share, please see Section 1 below.

Do we process any sensitive personal information? We process financial payment data solely for the purpose of facilitating class bookings, using Stripe as our third-party payment processor. We do not store payment card data on our own systems. We also collect certain information that may be considered sensitive under applicable law (such as gender); please see Section 1 for details.

Do we receive any information from third parties? We may receive information about you from third parties in connection with your use of the fitness application. For example, if you choose to connect wearable devices or health platforms (such as Apple Health or similar services), we may receive activity and workout data, including steps, heart rate, or exercise metrics. We may also receive limited account or profile information from authentication providers (such as when you sign in through a third-party account), transaction confirmations from payment processors for purchases or subscriptions, and analytics or attribution data from service providers that help us understand how users interact with the application.

How do we process your information? We collect, use and store your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with applicable law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Please see Section 3 for a full list of those situations and parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. These rights may include the right to access, correct, delete, or restrict the processing of your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at helloswolemate@gmail.com. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what swolemate does with any information we collect? Review the below notice in full.

We collect personal information that you voluntarily provide to us when you register for an account, create or update your profile, connect with workout partners, log workouts or fitness goals, participate in features of the Services, request information about our products or Services, or otherwise communicate with us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect (and share with studios you book with through swolemate) may include the following:

• Names
• Email addresses
• Phone numbers
• Approximate location (based on IP address)
• Age
• Gender
• Profile photo
• Credit card information (collected, but this information is not stored)
• Fitness preferences and interests (used to match you with other users and relevant classes)
• Usage and in-app activity (e.g., workouts completed, app interactions, and health data from connected devices such as Apple Watch)

Sensitive Information. Certain information we collect may be considered "sensitive personal information" under applicable privacy laws. For example, we may collect profile information such as gender or pronoun preferences that you choose to provide through the Services. We use such information solely for the purpose of providing and improving the functionality of the Services and do not use or disclose sensitive personal information for purposes of inferring characteristics about you or for other purposes that would require a right to limit under applicable law. We do not collect government identification numbers, racial or ethnic origin data, precise geolocation data, or health or medical information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information Collected Automatically. When you use our Services, we may automatically collect certain technical information, including device identifiers, operating system information, IP address, and in-app usage data. This information is collected through log files and similar tracking technologies. Please see Section 3 for more details.

We use Stripe to process payments made through the Services. Payment card information is collected and processed directly by Stripe and is subject to Stripe's privacy policy and security practices. We do not collect, receive, store, or maintain full payment card numbers or card security codes on our systems. We may receive limited transaction information from Stripe, such as payment confirmations, billing status, and transaction identifiers.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of Services to the user. We may process your information to provide you with the requested Service.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To match you with potential gym buddies ("swolemates"). We may use your information to identify and suggest other users who share similar fitness interests and preferences.
• To communicate upcoming events and company updates. We may use your information to share upcoming event information.
• To enable booking of classes and events. We may process your information to allow you to book classes with our partner studios.
• To improve and optimize our Services. We may use aggregated or de-identified data to analyze usage patterns and improve the functionality and user experience of our Services.
• To comply with legal obligations. We may process your information to meet our obligations under applicable law, including responding to lawful requests from public authorities.
• To protect the security of our Services. We may process your information to detect, investigate, and prevent fraudulent activity and other illegal activities and to protect the rights and property of swolemate and our users.

We may share your personal information in the following situations:

• Service Providers. We may share your information with service providers or vendors who help us deliver the Services, such as our platform hosting provider, Mariana Tek and other booking partners, our email provider, application analytics providers, IT services providers, and third-parties who help us improve and execute our marketing efforts.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Partner Studios and Event Hosts. We may share or transfer your information with partner fitness studios and event hosts solely to facilitate your booking and participation in classes and events. These parties may use your information to process reservations or activities, make services available to you, or otherwise as permitted under applicable law. We share only the minimum information necessary for these purposes.
• Other Users. When you share personal information or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services. We recommend that you do not share information you are not comfortable making visible to other users. Other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
• Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of swolemate or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
• Affiliates. We may share your information with our affiliates and related companies, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company, subsidiaries, and any companies under common control with us.
• Advertising and Analytics Partners. We may share certain information with advertising networks, marketing partners, and analytics providers that help us understand how users interact with the Services and help us deliver, measure, and improve our marketing and promotional efforts.
• Payment Processing and Financial Services. Payments made through the Services are processed by our third-party payment processor, Stripe. We may share limited information necessary to facilitate payment transactions, such as billing details and transaction information.
• Professional Advisors. We may share your information with our professional advisors, such as lawyers, accountants, auditors, insurers, and consultants, where necessary to obtain professional services or comply with legal obligations.
• Consent or Direction. We may share your information with third parties when you request or direct us to do so, or when you otherwise consent to such sharing.
• Aggregated or De-Identified Information. We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for research, analytics, product improvement, or other business purposes.
• Safety and Fraud Prevention. We may share information with third parties when necessary to detect, investigate, prevent, or address fraud, security issues, or violations of our terms or policies.

While we require third parties with whom we share personal information to implement reasonable safeguards and use personal information only for authorized purposes, their processing of personal information is governed by their own privacy policies and security practices.

Advertising and Online Tracking

We may allow third-party companies to serve ads and collect certain information when you visit the Site and Services. These companies may use certain information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. Our advertising partners may collect information about your activities on our Sites or mobile applications on your current device and combine it with information about your activities on other websites, mobile apps, and devices. These companies typically use cookies or other tracking technologies (such as web beacons, tags, pixels, mobile advertising IDs and similar technologies) to collect this information. This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices. These third party partners use this information for our and their own advertising, analytics, attribution, and reporting purposes. Our systems do not recognize browser "Do Not Track" signals, but several of our Service Providers who utilize these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us. You can learn about this in the "Managing Your Information Preferences" section of this Privacy Policy. You can disable the sharing of your personal information for cross-contextual behavioral advertising or targeted advertising through online cookies and tracking technology by clicking on the cookie manager on the Site and changing your cookie preferences to ensure that analytics and advertising cookies are disabled.

We retain personal information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, and comply with applicable legal, accounting, or regulatory obligations. The length of time we retain personal information may depend on factors such as the nature of the information, the purposes for which it was collected, and our legitimate business needs.

When personal information is no longer reasonably necessary for these purposes, we will take reasonable steps to delete, anonymize, or de-identify the information. In some cases, we may retain information in secure backup or archival systems until deletion is practicable.

We maintain physical, electronic, and procedural safeguards designed to protect the confidentiality and security of any personal information we process, including account-restricted access. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

The Services are not intended for individuals under the age of 18, and we do not knowingly collect personal information from anyone under 18 years of age. By using the Services, you represent and warrant that you are at least 18 years old. We also do not knowingly collect personal information from children under the age of 13 in accordance with the requirements of the Children's Online Privacy Protection Act. If we become aware that we have collected personal information from an individual under the age of 18, we will deactivate the account and take reasonable steps to delete such information from our records. We rely on users to provide accurate information about their age and do not knowingly permit individuals under 18 to create accounts or use the Services. If you believe that we may have collected information from a person under 18, please contact us at helloswolemate@gmail.com.

The Services may allow users to connect or communicate with one another. You are solely responsible for your interactions with other users, including any interactions that occur outside of the Services. We do not conduct background checks or otherwise verify information provided by users, and we make no representations regarding the identity, safety, or conduct of any user. You agree to exercise caution and good judgment when interacting with others through the Services.

Depending on the country or state where you reside, you may have certain rights regarding your personal information. These rights may include the right to request access to, correction of, or deletion of your personal information, as well as the right to restrict or limit certain processing of your personal information, subject to applicable law.

Withdrawing Your Consent. Where we rely on your consent to process your personal information, you may withdraw your consent at any time, subject to applicable law. You may do so by contacting us using the contact details provided in the section titled "How Can You Contact Us About This Notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by replying "STOP" or "UNSUBSCRIBE" to the messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

If you have questions or comments about your privacy rights, you may email us at helloswolemate@gmail.com.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California residents may have certain additional rights regarding their personal information under applicable California law. If you have questions about your rights or would like to make a request, please contact us using the contact information provided below.

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

NOTICE TO RESIDENTS OF THE UNITED STATES; YOUR PRIVACY RIGHTS

Residents of California or jurisdictions with similar laws (e.g., Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey) have certain additional privacy rights under the applicable privacy laws in such states ("State Privacy Laws"). This section generally describes those rights and how you can exercise them. Note that we allow all users of the Site and Services to exercise the rights set forth in this section in accordance with this Policy.

These rights are not absolute. In some situations we may not be able to process your request. This may include if a legal exception applies. These rights may be offered based on your location. We will let you know when or if a right does not apply to you. You will not be discriminated against for exercising a privacy right. If you disagree with our decision you can contact us as described at the end of this policy. Those rights are:

• Access: to learn the categories of Personal Information we collect, use, disclose and sell; for those in California, the categories of sources of collection, the third parties to whom the Personal Information is disclosed or sold, and the business purpose for such collection or disclosure; for those in Oregon, a list of specific third parties (as defined under Oregon law) to whom we have disclosed the Personal Information
• Portability: a copy of the specific pieces of Personal Information collected;
• Deletion: to have us delete Personal Information we collected from you; and
• Correction: asking us to fix your Personal Information.

We will also maintain a record of your rights requests. Please note that if we delete your Personal Information, some of our services will not work the same. For example, your previous opt out requests will not be saved and saved preferences and information will no longer be available.

Exercising your Rights

To exercise your rights, submit a verifiable consumer request to us by:

• Emailing us at helloswolemate@gmail.com

Your verifiable consumer request must:

• Provide sufficient identifying information (including full name and email address) to allow us to reasonably verify you are the person about whom we collected and retained Personal Information, and/or your authority to make such request on behalf of the data subject, and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Note that we will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request or to review and comply with the request.

You may authorize someone to act as your agent and submit a request on your behalf. Due to the sensitivity of such requests, you must verify the agent's authorization before we will act. Accordingly:

• You or your agent must supply proof that the agent is registered with the Secretary of State to act on your behalf; or
• You or your agent must supply other written permission for a specific agent to act on your behalf; and
• We will use your email address to connect directly with you to verify agent identity and authority.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm with a level of confidence appropriate to the sensitivity of the information that the Personal Information we have collected and retained in our systems and databases relates to you.

Making a verifiable consumer request does not require you to create an account with us, but if you have an account with us, we may require you to log-in to such account in order to verify your identity or authority or to provide or delete your information.

Right to Opt-out of the Sharing of Personal Information

Residents of certain jurisdictions (including those set forth above) have the right to opt out of the "sharing" of their personal data, as such terms are defined under State Privacy Laws.

Under California law, "share" means disclosing your personal information by us to a third party for cross-context behavioral advertising, in exchange for money or anything else of value. Thus, when we use the term "share" under this section, we are using it in the narrow meaning of how it is defined under California law. Other State Privacy Laws do not use the term "share," but describe the concept as using personal information for targeted advertising.

Right to Limit Disclosure of Sensitive Personal Information

Residents of some jurisdictions may have a right to limit the processing of their Sensitive Personal Information (as defined by the applicable State Privacy Law). We do not collect or process Sensitive Personal Information for inferring characteristics or use or disclose Sensitive Personal Information for purposes other than those permitted by law.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last Updated" date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at helloswolemate@gmail.com.

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please reach out to us via email at helloswolemate@gmail.com.

Please print a copy of this privacy policy for your records and please check the Site and frequently for any changes.