Privacy Policy

Updated on 10/20/2021

Kwit, a SAS with a capital stock of €50,010, registered at the Strasbourg Trade and Companies Register under number 819 528 597 with its headquarters at 3, place de Haguenau 67000 Strasbourg, France, represented by Mr Geoffrey KRETZ, as Chairman. (below-mentioned “Kwit” or “we”), are committed to protect and respect your privacy when using its mobile applications (“Application” or “the App”) and its website (“Website”) https://kwit.app (grouped in “ Platform”).

We have established this privacy policy (below-mentioned the “Policy”) to straightforwardly inform you of how the personal data that identifies you directly or indirectly (The “Personal data”) is processed by Kwit as Data controller.

1. Personal Data Processing:

We collect three categories of information:

1. The information you directly provide;
2. The data we collect when you use the Platform;
3. Data collected through cookies.

a. The information you directly provide:

By using our Platform, you may be asked to provide us with information that is considered Personal Data.

• When you create your account with an email address, you give us your email address and a password so that we can authenticate you and secure your data. We do not store this password, which is used only to create the account.
• When you register via our Applications, we ask you to provide us with your prior smoking habits to create your user profile, the application theme you choose, as well as the pseudonym under which we can address you.
• When you use our Applications, we save each motivation card drawn, each achievement unlocked, each cigarette smoked and each craving resisted with for each of them, the date, intensity, feeling and trigger. You may also have to modify the price of a package in the application settings so that the savings made are the most accurate. We then record a history of these different prices. You can also change your nickname in the application settings at any time, and we will save your choice.
• By contacting us, the data entered will be sent to us, such as the email address used, the content of the message, the technical identification of your account or any other data you may need to send us.
• By using the contact form “Company” on our Site, you provide us with a contact name, email and/or telephone number to reach you, the company you represent and the number of people employed by it, followed by a comment if you wish to send us a message.
• We offer subscriptions on our Platform. When you make a payment on the Platform we manage your payment via third-party payment services such as application stores available on mobile platforms or Stripe on our Site. The platform used may collect certain financial information required for payment on behalf of Kwit, such as your name, email address, postal address and other billing information.
• When you write your feedback on Kwit either through the application stores or directly in the Platform, we reserve the right to feature it by displaying your nickname, comment and given rating. By the way, we would like to thank you very much for your feedback, which helps us to improve our services.

b. The data we collect when you use the Platform:

When you use our Platform, we collect information about how you use it to enable the platform to operate and to continuously improve your experience.

• When creating your account through Facebook, we collect the strictly necessary data for your authentication, such as an email address if it is provided on the social network.
• When creating your account with Google, we collect the bare minimum necessary for your authentication, i.e. your email address.
• When creating your account with Apple, we collect the bare minimum necessary for your authentication, which is your email address. In this case, you can choose to use an anonymized address.
• When you register via our Applications, we record technical data on the device used (model, operating system version and preferred language set). We also store the version of the installed application and the date the account was created. We store this data to be able to compile technical statistics on the use of the Platform, to know in which language to talk to you and to help us to assist you in case of need. The account then created is associated with a unique technical identifier. The authentication mode (via email, Facebook, Apple or Google) is preserved for possible troubleshooting by the user. Another unique technical identifier associated this time with the device used is also stored to save the theme chosen by the user on the same device or to define your preference for push notifications for this device.In some cases, we ask you to tell us the main reason why you want to change, your motivational state, your marker, your age, your gender, when you started smoking, how many quit attempts you have made. Some questionnaires can be proposed to you, these measure: your type of motivation, your level and type of dependence, your brakes in relation to quitting smoking and your fears in relation to quitting smoking. This data is kept because it is necessary to personalize your cessation program. If you answer the questionnaire about your breath, we keep the date you answered the questionnaire, if you are at risk (COPD), if you are over 40 years old or not, your gender and if you went to see a doctor in case the questionnaire identified you at risk.
• In case the App crashes, a report is automatically sent to notify us of the new bug. This report provides us with your unique technical identifier, the technical information of the device and the version of the software used. This data helps us to reproduce and correct any errors in the Platform's software.
• Each time you log into the Platform, we update the technical data of the software used as well as the technical data of the device used. This update is done to be able to compile technical statistics on the use of the Platform, to know in which language to write to you and to help us to assist you in case of need. Each new session is recorded in a user-specific history.
• When you decide to restart your withdrawal, we save the history of the data you have entered (old smoking habits, previous quit date, history of smoked cigarettes and resisted cravings, technical information about the software and device used) so that we can restore this data in case of handling errors on the one hand, and for future features to better evaluate the user's progress in his/her cessation of tobacco use, on the other hand. If you delete your account, this data will be deleted, of course.

c. Information gathered through cookies:

Each time you use the Platform, we may collect, following the relevant legislation, information about the devices on which you use our Platform or the networks from which you access it. For example, your IP addresses, connection data, types and versions of web browsers used, operating systems, data about your browsing experience on the Site and our Applications, the content you access or view, or the advertising ID of your device to help us measure the effectiveness of our advertising campaigns. To do this, we use cookies in particular.

A cookie is a small text file stored and/or read by your browser or application, stored in the cookie directory on your device's hard drive (PC, laptop or smartphone), and stored by the websites you visit. It contains a unique and anonymous identifier.

The cookies we use are:

• The authentication cookies that allow you to access your personalised content and avoid the need to provide your username and password each time you log in to our Platform
• The security cookies that will manage the payment process on our Site.
• The analysis and performance cookies that allow us to identify and count the number of visitors to our Site and Apps and to collect information about how these are being used. This data collection enables us to improve the way our Site and Apps work and the overall content of our Services. These cookies also allow us to measure the effectiveness of our marketing efforts.

These cookies come from third-party services that we do not control. The Site uses Google Analytics to measure its audience. You can get more information about this by following this link: www.google.com/analytics^[1]. The use of Google Analytics cookies is subject to your consent and may be disabled at any time on the Site itself and in your browser settings.

We also use third parties in our Applications such as Firebase Authentication to allow you to stay connected without having to enter your usernames and passwords each time you log in. Firebase Analytics, Flurry Analytics and Facebook Analytics are used to measure the use of the Applications and the effectiveness of our marketing efforts. We finally use SendinBlue to send you informational emails.

2. Purposes of personal data processing

Several purposes justify personal data processing and rely on the following legal bases:

1. Contract
2. Legitimate interest
3. Consent
4. Legal obligation

a. Contract

The main reason why we may use your Personal Data is that without it we would not be able to provide our services, as described in our Terms of Use and in particular we would be able to allow you to self-assess your smoking cessation and evaluations of the evolution of this cessation and manage, if necessary, the operations relating to the management of payments.

b. Legitimate interest

Another important reason why we need to process some of your information is that we seek to provide you with the best possible service, to improve it continuously, to protect your Personal Data, to solve technical problems, to establish statistics or to respond to your support requests.

c. Consent

In some cases, we ask for your consent before processing specific data.

Therefore, the processing of personal data that is carried out only after obtaining your consent (which can be withdrawn at any time) is as follows:

On our Site, you choose whether or not to allow the use of analysis and performance cookies. You can change this option in your browser and on the Site.

In our Applications, we ask you if we can send you push notifications to keep you informed of your progress or new features.

On the platform generally, we ask you if we can use your email address to send you personalised offers and the Kwit newsletter.

Each choice can be viewed and modified ( respecting your right to object) in the settings of the application, mobile device, browser, Site or via a link in the emails sent.

d. Legal obligation

Finally, we may need to use your information to comply with the law, for example in the event of a valid judicial requisition, or when we need to take measures to protect our users, or just to respond to your request for a right of access, rectification and opposition or to your other rights regarding your Personal Data.

3. Storage, protection, sharing, possible transfers of your Personal Data and storage period

1. Storage and protection
2. Sharing
3. Possible data transfers outside the European Union
4. How long your data will be kept

a. Storage and protection

Since the security of your information is of fundamental importance to us, we require an adequate and sufficient level of security according to the RGPD criteria for the storage of your data.

b. Sharing

As far as sharing your data is concerned, it is very simple: we do not share any of your Personal Data with anyone! Only Kwit's authorised personnel will have access to your information and only for support purposes or to improve the services offered by our Platform.

If you use Kwit for a scientific study, only the person in charge of that study will know your identity to preserve your anonymity. You will use an email address provided by the study supervisor to create your account, and we will not be able to identify you in any way. In this specific case, we may share this anonymous data with the study supervisor so that the study can proceed as agreed, under the conditions you have agreed with this supervisor.

c. Possible transfers of your data outside the European Union

Your data is not transferred outside the European Union, except for data transferred and stored on Firebase servers, a platform maintained by Google which is located in the United States of America and which complies with the Privacy Shield, in compliance with our criteria.

d. How long your data will be kept

We keep your data only during the applicable limitation periods.

This way, we preserve your data as long as you use our Platform. If you no longer use it for 12 months, we will delete all information about you in our possession after this period, except the data strictly necessary to defend our rights during the time of limitation of any action against KWIT.

In the same way, any information that we have been able to anonymise can be preserved indefinitely.

Finally, cookies on your devices are stored for a maximum period of 13 months.

We remind you that you have the right to request the modification and/or removal, for valid reasons, of your information at any time. For more details on this subject, please refer to section 4. Your rights.

4. Your rights

For us it is a priority that you keep control over your Personal Data. We would like to remind you that you have the right to access, rectify, object to, define directives concerning the fate of your personal data after your death and delete your data, as well as the right to limit their processing and the portability of the data.

A dedicated section in our Applications and on our Site allows you to modify your choices as to the processing subject to your consent. A link is present in each email that we send you to allow you to unsubscribe from our newsletter. Finally, we respond to all requests concerning your Personal Data when you contact us by email at hello@kwit.app or by post to the address: 3, place de Haguenau, 67000 Strasbourg, France, addressed to Mr. Geoffrey KRETZ.

Finally, we would like to remind you that, if after contacting us you consider, that your rights in regards to your data are not respected, you have the possibility to file a complaint, in the event of a violation of the regulations applicable to the protection of Personal Data, before an authority such as CNIL^[2] the French supervisory authority.

5. Children's privacy

Our services are designed for people over 18 years of age. Children aged over 15 and below the age of majority in their country of residence must at least remain under the supervision and consent of their legal representatives. Otherwise, please do not attempt to use our Platform or services.

If you think we may have processed information from minors, please let us know at hello@kwit.app for the removal of it.

6. Changes to the Privacy Policy

We may change this Privacy Policy at any time. We will send you an email or notify you directly via our Applications when we do so. Any changes will take immediate effect after they are posted. The publication date will be updated at the beginning of this Policy.

7. Questions?

If you have any questions about this Policy, do not hesitate to contact us, we would be pleased to answer any request at hello@kwit.app.

• [1] http://www.google.com/analytics
• [2] https://www.cnil.fr