PRIVACY POLICY/PERSONAL DATA

The purpose of this Privacy Policy, hereinafter referred to as the "Policy", is to set out the actions undertaken by the owner of KETTLO MOBILE, i.e. Jakub Zielinski conducting business activity under the name MC Jakub Zielinski with registered office in Lublin (Poland), 20 Śliwkowa Street, 20-141 Lublin, NIP: 946-180-70-47 hereinafter referred to as "MC" with respect to protection of Your Personal Data processed through KETTLO MOBILE, as well as within the scope of related services (including Associated Services). The Policy sets out in particular the scope and legal basis for the processing of your Personal Data that we collect in connection with your use of KETTLO MOBILE. We receive your Personal Information from you when you create an Account with KETTLO MOBILE, in connection with activities you perform on KETTLO MOBILE, post, view Offerings including in connection with the purchase of services offered on KETTLO MOBILE and in connection with updates to your Personal Information made by you through KETTLO MOBILE. The controller of the Personal Data of Users/Trainers who are individuals is MC. This means that MC determines the purposes and means of processing your Personal Data. Your use of KETTLO MOBILE, is only possible after you have read this Policy and the KETTLO MOBILE Terms and Conditions. All MC's activities in the operation of KETTLO MOBILE are subject to the laws that apply to the protection of personal data, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council 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 and repealing Directive 95/46/EC hereafter ("RODO").

I. SCOPE OF PERSONAL DATA PROCESSED IN KETTLO MOBILE

The scope of Personal Data processed by MC may vary depending on which services or functionalities provided by KETTLO MOBILE you use. To make it easier for you to understand which of your Personal Data we hold, information about the categories of Personal Data we process, broken down by the purposes of processing, is indicated below. Full access to KETTLO MOBILE requires registration and provision of personal data. Registration with KETTLO MOBILE takes place in two stages. Stage I of KETTLO MOBILE account registration we require the following Personal Data: name e-mail address; dates of birth; create an individual password to be used to log in to KETTLO MOBILE; gender (female/male) Account type; acceptance of the Rules of Procedure and Privacy Policy; consent to the processing of personal data.

The extent of the personal data to be provided in the second registration stage depends on whether it concerns the registration of a User Account or a Trainer Account.

In the second registration stage in the case of registration of a User account, the User should provide: gender nickname, country, training objectives (elective) - optional, exercise venue (home/gym), system of measurements, weight, growth

(3) In Stage II of registration when registering a Trainer's account, the Trainer should provide: nickname; country; system of measurements; languages of the Trainer (at least 1, maximum 3); filling in the ('about me') tab (separately in each chosen language); placement of the Coach's welcome video (separately in each chosen language); indication of the Coach's experience (in years); indication of certificates - optional; link to facebook profile - optional; link to instagram profile - optional; to indicate whether he/she is registering as a trader or as a natural person.

If you do not provide the aforementioned Personal Data, it will not be possible to enter into a contract with you for the use of your KETTLO MOBILE account and consequently you will not be able to use the KETTLO MOBILE services available to Users/Trainers who have registered. Please note that once you have registered your User/Trainer Account and during the course of your use of KETTLO MOBILE's services, you are required to keep any Personal Data you provide up to date if there are any changes in any respect. During your use of KETTLO MOBILE, we additionally collect information about your actions taken within KETTLO MOBILE, including, but not limited to, purchase history, offers issued (only applicable to Trainers), comment content and ratings. When using your User/Coach Account, you may also provide us with other optional Personal Data, e.g. by uploading your photo or a graphic that may depict your image (avatar), thereby consenting to its processing. The provision of such Personal Data is entirely voluntary. In addition, we may obtain your Personal Information in connection with your use of the KETTLO MOBILE login option through third-party authentication services offered by other entities operating independently of MC (e.g., services offered by Google, Apple or services offered within services, including those of a social nature - e.g., Facebook). In this case, we obtain your Personal Data only in the form of your name or username, email address and avatar published on such service or service and we may assign this Personal Data to your Account or process it only for the purposes of such log-in to KETTLO MOBILE. REMEMBER!

1. when using third-party authentication services, please read the terms and conditions of the providers of such services and their personal data processing rules;
2. when using social media on your own, you are using a public profile (i.e. a profile that can be accessed by anyone using the internet), you are sharing your Personal Information based on your own considered and informed decision. You should carefully consider the risks that may be associated with such making Personal Data public, in particular your address or precise location. Such risks may include, for example, the possibility of being identified, loss of some privacy and, in extreme cases, even identity theft. When you make purchases (and sales) through KETTLO MOBILE, including making payments for the purchased (sold) service through KETTLO MOBILE, it may involve the processing of other User/Trainer Personal Data as well, i.e. data contained in the Offer (including in particular the content of the Offer), transaction data (in particular in terms of bank account number, payment method), VAT invoice data and data enabling communication between the parties to the Transaction. As part of the above, MC may also have access to the content of messages sent between the parties to the Transaction (User/Trainer) within the framework of discussions and disputes. In operating the services offered, we may also process Personal Data, including, among other things, the value of turnover, information about the services ordered and information about the quality of the Services offered. REMEMBER! The information posted by you in the Offers and messages exchanged between Users/Trainers does not originate from MC and is not initiated by MC. For these reasons, to the fullest extent permissible under applicable law, MC is not responsible for the information provided in the Offers and messages exchanged between Users/Trainers. In Offers and messages exchanged between Users/Trainers, as far as possible, you should not provide Personal Data. REMEMBER: When you include your Personal Information in Offers or messages exchanged between Users/Trainers, you do so on the basis of your own considered and informed decision. Each time, carefully consider the risks involved in providing such information. In terms of your use of the contact forms, we process such contact data as is necessary to communicate with you (e.g. to answer a question you have asked) and to fulfil your request. This may include such Personal Data as your name, email address or telephone number. As part of the User/Trainer service, we may also make contact with you through the use of Personal Data placed in your User/Trainer Account for this purpose. In connection with your participation in promotional actions, we will process your Personal Data that is necessary for the above events. Depending on the type of event organised, this may include, but is not limited to, your name, contact details (such as telephone number or email address) or any other data necessary to meet the criteria for participation in the promotional actions organised. Within the scope of marketing activities to which you have consented, we may, based on the legitimate interest of MC or the legitimate interest of entities cooperating with MC based on your consent, process information that helps us to tailor advertising and content to your preferences and expectations (including in connection with the display of behavioural advertising). This may include, but is not limited to, your IP address, data derived from cookies, or information about your traffic on the website, including the Offers you view and your preferences in this regard. In addition, based on the above premises, we will also process your contact data, including the data necessary to send you information, including commercial information, to the extent provided by you (telephone number or e-mail address). We may also process your Personal Data for analytical and statistical purposes, including surveys. For these purposes, we will primarily use information about your activity on KETTLO MOBILE, including information related to your use of specific services, as well as Personal Data about your preferences and expectations. By way of surveys sent to Users via email or made available directly through KETTLO MOBILE. Information we collect about you in this regard may constitute Personal Information. We may process Personal Data such as, but not limited to, your IP address, data derived from cookies, the parameters of the software and hardware you use, the configuration of your device (e.g. data on installed plug-ins). We may process your Personal Data in connection with our right to assert or defend against claims. For this purpose, MC processes your Personal Data for as long as the claims arising from the contract you have concluded with MC or related to your use of the services provided by MC are not time-barred in accordance with applicable law. This may include, for example, purchase data, amount of debt, transaction data, or information obtained in connection with your contact with MC and/or Coach. The scope of the Personal Data we process may vary from time to time, depending on the subject matter of the claim.

II. DATA WE COLLECT AUTOMATICALLY WHEN YOU USE KETTLO MOBILE

When you use our KETTLO MOBILE, we automatically collect the following information about you:

Device data - during your use of KETTLO MOBILE we collect information about the device with which you use KETTLO MOBILE, such as operating system version and unique identifiers (e.g. the name of the mobile network you are using, IP address, device language settings, device make and type, operating system and device version, browser type and version, and software information about your device such as fonts, system and browser time zone, available video and audio formats).

Location information - depending on the privacy settings of the device through which you use KETTLO MOBILE , we automatically collect and process information about your current location. We use various technologies to determine your location, including IP address, GPS, Wi-Fi access points and mobile phone stations. Your location data allows us to display and view Offers posted on KETTLO MOBILE in your area. In the event that we need your location data, we will first display a pop-up asking you to allow or deny access to your location data on your mobile device.

Login data - when using KETTLO MOBILE, we collect information about your login (date of Registration, date of last password change, date of last successful login).

III. DATA COLLECTED FROM OTHER USERS (RATINGS AND OPINIONS)

If you use KETTLO MOBILE as a Trainer, we collect and share information provided by other Users on their ratings and feedback regarding their contact with you or the quality of your Services - in accordance with our Terms of Service. This is an element of the services offered within KETTLO MOBILE which is intended to evaluate the Services, ensure competitiveness and provide the best level of communication between Users (Trainers), verify undesirable activities and behaviours and enable us to take appropriate action in this regard to impose high standards on the Services provided within KETTLO MOBILE.

IV. PURPOSES, GROUNDS AND DURATION OF THE PROCESSING OF PERSONAL DATA BY THE MC

Your data will be processed for: to conclude and properly perform the contracts concluded with you, in particular the delivery of the Services ordered through KETTLO MOBILE including for the processing of any complaints - legal basis Article 6(1)(b) RODO and for no longer than until the expiry of claims in connection with these contracts; to monitor your activity on KETTLO MOBILE in order to tailor the content displayed to your needs and to improve the services we provide, which is our legitimate legal interest - legal basis Article 6(1)(f) RODO and for no longer than until you raise an objection, for which purpose we use profiling in some cases, promotion and advertising of the activities, products and services offered within KETTLO MOBILE - only in the case of persons who have given the relevant consent and only to the extent specified in such consent) - legal basis Article 6(1)(a) RODO and no longer than until the consent is withdrawn; dispatch of the KETTLO MOBILE newsletter - subject to subscription to the newsletter - legal basis Article 6(1)(b) RODO and no longer than until the newsletter service is cancelled; make automated decisions in individual cases in relation to you, including decisions based on profiling - only if you have given your consent to do so - legal basis Article 6(1)(a) RODO and no longer than until you withdraw your consent, to ensure the security and proper functioning of KETTLO MOBILE which is our legitimate legal interest - legal basis Article 6(1)(f) RODO and for no longer than the time necessary to fulfil the stated purpose or to object to the processing of the data where the Controller is unable to demonstrate grounds overriding the rights and freedoms of the objector; the pursuit of MC's legitimate interests including the assertion of possible claims by MC, archiving to protect MC's legal interest - legal basis Article 6(1)(f) RODO and no longer than until an objection is raised. REMEMBER: In each of the aforementioned cases, your personal data will be kept for the time necessary for each of the aforementioned purposes.

IV. YOUR RIGHTS/RIGHTS WITH REGARD TO THE PROCESSING OF PERSONAL DATA AND THEIR EXERCISE

Within KETTLO MOBILE, we enable you to fulfil all your rights under the RODO, i.e. the rights described in Articles 15-22 RODO, i.e: Right of access to your Personal Data - we enable you to obtain information about MC's processing of your Personal Data, including, in particular, the purposes and legal basis for the processing, the scope of the data held, the entities to which your data is disclosed and the scheduled deletion date. Right to obtain a copy of your Personal Data - we allow you to obtain a copy of your Personal Data that is processed by MC. Right to rectification of Personal Data - in case you notice that your Personal Data is incorrect or incomplete. In such a situation, upon being informed by you, we undertake to promptly rectify any inconsistencies or errors in the Personal Data processed and to complete it if it is incomplete. Right to erasure of Personal Data - where: a) your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed by MC; b) you withdraw your consent to the processing of your Personal Data or object to the processing of your Personal Data and there is no other legal basis for the processing; your Personal Data is unlawfully processed. REMEMBER: Personal data are deleted when you terminate your contract with the MC and possibly with the Coach. To delete them, first terminate your contract with MC and possibly with the Coach. The right to delete personal data is not an absolute right and MC may refuse to delete your personal data. This is the case if there are circumstances under which we may process your personal data after the termination of the contract. If you have used the services through KETTLO MOBILE, your personal data will be processed for 3 years calculated from the end of the year in which the termination of the contract took place. The legal basis in this situation is MC's legitimate interest (Article 6(1)(f) RODO) in defending MC's rights. After the termination of the contract, we will only process your data for the purposes indicated below, based on MC's legitimate interest, which is: 1) asserting and defending against claims, including debt collection, litigation, arbitration and mediation; 2) conducting statistical analyses; 2) ensuring accountability (demonstrating our compliance with legal obligations). Once these processing purposes have expired, the data will be automatically deleted from KETTLO MOBILE. The right to restrict the processing of Personal Data, which is a right that allows you to ask us to stop the processing of your personal data in the following situations: a) where you want us to check the accuracy of the data; b) where our processing is unlawful; c) where you need the data to establish, assert or defend a claim, even though we no longer need your data for our own processing purposes; d) where you have objected to our processing, but we need to verify that we still have an overriding and legitimate basis to continue processing your personal data. The right to data portability, which is the right to provide you or a third party you have designated with your personal data in a structured, commonly used, machine-readable format. Please note that you only have this right in relation to data processed on the basis of consent or a prerequisite for the performance of a contract you have entered into with us, and the processing itself is carried out by automated means (in IT systems). The right to object to the processing of Personal Data for marketing purposes, which you may exercise at any time if your Personal Data is processed for marketing purposes, without having to justify such objection. The right to object to other purposes for the processing of Personal Data, which you may exercise at any time, on grounds relating to your particular situation, if your Personal Data is processed on the basis of MC's legitimate interests (e.g. for analytical or statistical purposes). An objection in this respect should contain a justification and indicate the grounds for the request in this respect. Right to withdraw consent to the processing of your Personal Data. Where you have given us consent to process your Personal Data, you have the right to withdraw it at any time. The withdrawal of consent does not affect the lawfulness of the processing that was carried out on the basis of consent before its withdrawal. If you have given us consent to receive commercial or marketing information under separate legislation, you also have the right to withdraw it at any time. REMEMBER: The exercise of your rights is, in principle, free of charge: which means that, in principle, you will not have to pay a fee for the exercise of the right of access to your personal data (or for the exercise of any other rights). However, we may charge a reasonable fee if your request is manifestly unjustified or excessive, in particular due to their continuing nature. In such cases, we may also refuse to comply with your request. If you exercise your right to object to the profiling of Personal Data, you should log out of all devices and delete cookies from them (in some cases, the process may take up to 48 hours). REMEMBER: You have the right to lodge a complaint in relation to our processing of your Personal Data to the supervisory authority, which is the President of the Office for Personal Data Protection (address: President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw).

V. RECIPIENTS OF PERSONAL DATA

For the purposes of processing the Personal Data indicated in this Privacy Policy, MC may provide your Personal Data to the following third parties: parties to transactions concluded within KETTLO MOBILE, i.e. Trainers with data of Users who purchased services of a given Trainer, and Users with data of the Trainer whose services were purchased by given Users. NOTE: Upon conclusion of a contract with a given User, the Coach becomes an independent administrator of the User's personal data. In such a situation, the Trainer is obliged to fulfil towards the Users whose data it has obtained through KETTLO MOBILE all obligations under RODO, including the obligation to provide information and ensure that the Users realise their rights under RODO to the extent no less than that resulting from this Privacy Policy, entities that support MC in the provision of electronic services, i.e. those that provide payment services, perform consulting or auditing services, support the service of Users (Trainers), cooperate in marketing campaigns; to other KETTLO MOBILE Users (Trainers) in terms of the image (photo, avatar) and data provided on your KETTLO MOBILE profile; to cooperating entities such as specialised providers of Personal Data storage services, analytical services, debt collection services, in order for these entities to provide services to MC; to public authorities under the law in connection with investigations into possible breaches of the law or combating other possible breaches of the Terms and Conditions (including in connection with investigations into fraud and abuse within KETTLO MOBILE).

NOTE!

REMEMBER: If you use our Services and decide as a Trainer to offer your services and for sale through KETTLO MOBILE, you may decide to disclose certain personal information to other Users (Trainers) of KETTLO MOBILE. This information may include your name, email address, your location and contact number.

REMEMBER: If you use our Services and choose as a User (as part of your User account functionality, to use KETTLO MOBILE) to share personal information with other Users (Trainers) as part of an agreement to provide electronic services. This information may include your name, email address, your location and contact number and other data as you indicate on your KETTLO MOBILE profile.

REMEMBER that any information you disclose to other users may be passed on, so you should be very careful about this. Some information may be made available to the public automatically at the time of publication of an Advertisement - e.g. your rating.

VI. TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE THE EUROPEAN ECONOMIC AREA

In the course of using KETTLO MOBILE, there may be transfers of your Personal Data outside the - European Economic Area - EEA.

In situations where we transfer your personal data outside the "EEA", we ensure that a similar level of protection is provided by putting in place one or more of the following safeguards: We will only transfer your personal data to countries that have been recognised by the European Commission as providing an adequate level of protection for personal data. Detailed information is available here: European Commission: Adequacy of the protection of personal data in non-EU countries When using certain providers, we may use contracts approved by the European Commission that provide personal data with the same protection as it enjoys in the European Union. Detailed information is available here: European Commission: Model contracts for the transfer of personal data to third countries.

Your Personal Data may be transferred outside the European Economic Area to, among others: OneSignal, Inc. a U.S. company located at 2850 S Delaware St Suite 201, San Mateo, CA 94403; Stripe Inc, 354 Oyster Point Blvd, South San Francisco, CA 94080; Stripe Inc, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210. VII. SECURITY MEASURES MC operates at all times with mechanisms and procedures to ensure an adequate level of protection of Personal Data, including through the use of standard contractual clauses for the transfer of Personal Data to processors established in third countries approved by the European Commission. The data we collect about you will be stored and processed both inside and outside the EEA on appropriately secure servers, in order to provide KETTLO MOBILE users with the best possible service. REMEMBER: Despite the measures we have implemented to protect your Personal Data, sharing information via the Internet or publicly accessible networks is never completely secure and there is a risk that unauthorised third parties will gain access to your Personal Data.

VIII. AMENDMENT TO THE PROVISIONS OF THE PRIVACY POLICY

Should it be necessary to amend the provisions of this Privacy Policy, the provisions of the KETTLO MOBILE Regulations, i.e. § 22 of the Rules and Regulations.

IX. CONTACT DETAILS

You will receive more information about the processing of your Personal Data, including answers to questions about the scope of the Privacy Policy, by contacting us via the KETTLO MOBILE contact form or at the following email address: kontakt@kettlo.com. In addition, it is possible to contact the postal address: 20 Śliwkowa Street, 20-141 Lublin, Poland.

X. SUPERVISORY AUTHORITY

In matters related to the processing of Personal Data, the supervisory authority is the President of the Office for Personal Data Protection (address: President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw).