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Angelus Privacy Policy

1 INTRODUCTION

1.1 We are Akwyar, Inc. (FEIN: 38-4070129) (Akwyar, we, us).

1.2 The Angelus Privacy Policy (Privacy Policy) is provided to ensure you understand your rights and obligations when you access and navigate the Angelus software platform including our online software system and/or companion mobile application Umbra (Applications) and when we collect personal information from you by other methods. This Privacy Policy also applies to any of our related entities.

1.3 This policy sets out:

1.4 Akwyar respects the rights and privacy of all individuals and is committed to protecting the personal information we hold.

1.5 We may, from time to time, review and update this policy, including taking account of new or amended laws, new technology and/or changes to our operations. All personal information held by us will be governed by the most recently updated policy and we will give you notice of our revised policy by posting to our website located at angelus.app/policies/privacy.

2 WHAT IS PERSONAL INFORMATION?

2.1 In general terms, and when used in this policy, the term “personal information” is any information that can be used to personally identify you. This may include (but is not limited to) your name, postal code and contact details (including phone numbers and email addresses) and possibly financial information, including direct debit account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

3 WHAT PERSONAL INFORMATION DOES AKWYAR COLLECT AND HOLD?

3.1 We collect the type of personal information required to assist with providing Angelus (including Umbra) services and informing you about them.

3.2 Depending on whether you are an Angelus and/or Umbra user, this may include personal information such as:

3.3 We utilize GPS location services for the purpose of identifying your location so that we can deliver the services that we promise to deliver by your use of the Applications. Your location at any given time on its own does not personally identify you and does not constitute personal information. We will never disclose your location together with your personal information without your express consent. You acknowledge that when using the Applications, you will be disclosing your location as part of our services.

4 HOW AND WHY DOES AKWYAR COLLECT PERSONAL INFORMATION?

4.1 We collect personal information in three limited ways, from:

4.2 We may collect and disclose personal information to third parties for the purposes described in this policy. These purposes include but are not limited to:

4.3 The primary purpose for which we collect information about you is to enable us to perform our activities and functions, to communicate with you and to provide you with an efficient and functional experience in using the Applications.

4.4 Other purposes for which we will collect or use your personal information are:

4.5 We may use your personal information for those purposes, for any other purpose listed on a collection statement at the point of collection, or in any other way if we ask for your consent first. Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

4.6 We will not knowingly collect personal information from a child under the age of 13 without the consent of their parent or guardian (in accordance with the Children’s Online Privacy Protection Act of 1998 (COPPA).

4.7 We may disclose your personal information to:

5 WHAT HAPPENS IF WE CAN’T COLLECT YOUR PERSONAL INFORMATION?

5.1 In some instances, if you do not provide us with required personal information described in this policy, we may not be able to provide you with the services you requested, either to the same standard, or at all.

5.2 As a result, Akwyar may need to suspend, cancel or decline to renew your access to the Applications (subject to our terms and conditions and relevant laws).

6 THIRD-PARTY LINKS AND WEBSITES

6.1 Our websites may contain links to other websites operated by third parties.

6.2 We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website.

6.3 Third-party websites are responsible for informing you about their own privacy practices. We advise you check the privacy policy and terms and conditions of any third-party website or business before using their services.

7 WILL YOUR INFORMATION BE DISCLOSED OUTSIDE OF THE UNITED STATES OF AMERICA?

7.1 Your personal information will be stored in secure, encrypted electronic format on Amazon Web Services (AWS) infrastructure in the U.S. East (North Virginia) region.

7.2 Your personal information may be accessed by Akwyar, our staff, or any of our related entities.

7.3 We will take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

8 HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL INFORMATION?

8.1 You may request access to any personal information we hold about you at any time by emailing us at privacy@angelus.app.

8.2 Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making a request and will not charge for making any corrections to your personal information. If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

8.3 If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

8.4 We request that you keep your information as current as possible so that we may continue to improve our service to you.

9 HOW WILL AKWYAR MAKE SURE YOUR PERSONAL INFORMATION IS SECURE?

9.1 We will take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorized access, including by means of firewalls, password access, and secure servers.

9.2 If you suspect any misuse, loss of, or unauthorized access to, your personal information, please let us know immediately.

9.3 If we suspect any misuse, loss of, or unauthorized access to, your personal information we may inform you of that suspicion and take immediate steps to limit any further access to, or distribution of, your personal information. If we determine that the breach is likely to result in serious harm to you and we are unable to prevent the likely risk of serious harm with remedial action, we will act accordingly.

9.4 If we receive unsolicited personal information that we are not permitted to collect under this privacy policy, or within the confines of the law, we will destroy or de-identify the unsolicited personal information as soon as practicable if it is lawful and reasonable to do so.

9.5 We will destroy or de-identify your personal information if we no longer require it to deliver our services as soon as practicable if it is lawful and reasonable to do so.

10 DOES AKWYAR USE “COOKIES”?

10.1 When you use our Applications or websites, Akwyar or our service providers may obtain information using technologies such as cookies, tags, web beacons, and navigational data collection (log files, server logs, and clickstream data) to better understand your user experience. For example, Akwyar or our service providers may collect information like the date, time and duration of visits and which webpages are accessed.

10.2 When you access one of our websites, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognize your computer and greet you each time you visit our website, without bothering you with a request to register or log-in. It also helps us keep track of products or services you view, so that we can send you news about those products or services.

10.3 We also use cookies to measure traffic patterns, to determine which areas of our websites have been visited, and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online services. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

10.4 We may also log IP addresses (the electronic addresses of computers connected to the internet) to analyze trends, administer websites, track user movements, and gather broad demographic information.

10.5 This information is generally not linked to your identity, except where it is accessed via links in Akwyar (including Angelus) emails or where you have identified yourself. We may also collect anonymous data (which is not personal information) relating to your activity on our websites (including IP addresses) via cookies. We generally use this information to report statistics, analyze trends, administer our services, diagnose problems and target and improve the quality of our services. To the extent this information does not constitute personal information because it does not identify you or anyone else, we may use this information for any purpose and by any means whatsoever.

11 HOW CAN YOU COMPLAIN ABOUT PRIVACY BREACHES?

11.1 If you believe your privacy has been breached by us, have any questions or concerns about our Privacy Policy please contact us using the email privacy@angelus.app and provide details of the incident so that we can investigate it.

11.2 We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

11.3 If you are not satisfied with the outcome of our investigation, then you may request that an independent person investigate your complaint.

12 WHO CAN YOU CONTACT ABOUT YOUR PERSONAL INFORMATION?

12.1 To contact Akwyar about your personal information, concerns or complaints, email privacy@angelus.app or alternatively, write to us at:

Akwyar, Inc.
c/o WeWork
175 Varick St
New York, NY 10014
USA