Contents

1. General Information

2. Processing of Personal Data during Your Use of Our ShareSpace Platform

3. Marketing

4. Data Recipients

5. Retention Period

6. Transfers of data outside the EU / EEA

7. Security

8. Your Preferences

9. Your Rights

10. How to contact us

11. Changes to this privacy policy

1. General Information

ShareSpace Limited (hereinafter referred to as the “Company” or “ShareSpace”, “we” or “us”) is aware and strives to comply with its legal obligations under all applicable laws and regulations regarding the protection of personal data which are applicable to it and takes steps to ensure that all information is kept confidential and secure and to otherwise protect and respect your privacy.

This Privacy Policy applies to the access and use of the Share.Space mobile Application (for Android ver. 4.4+, Android beta 4.1+, IOS - 9.0+), the ShareSpace website hosted at https://sharespace.health website, as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the “ShareSpace Platform”) which is operated by us.

ShareSpace Platform is an online communication platform for all people to share and discuss what they are going through in life. Our mission is to give people opportunities to open up, support and uplift each other. We want to make the world a better place by thriving on compassion, mutual understanding, and respect.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

All enquiries in respect of this Privacy Notice or any requests to exercise any of the rights set out above should be directed to [email protected] or though using the relevant Contact Us Support Form which can be accessed within the ShareSpace Platform in your private profile by clicking on the blue information sign and selecting "Support" from the menu.

2. Processing of Personal Data during Your Use of Our ShareSpace Platform



We collect personal information about you when you access our ShareSpace Platform, register an account, and create a profile with us, when you communicate with us through our ShareSpace Platform, when you post material and comments to our ShareSpace Platform and generally when you interact with our ShareSpace Platform. We collect this personal information from you either directly, such as when you register an account, or indirectly, such as your browsing activity while using our Platform (see ‘Cookies’ below).

The personal data that we collect from you are the following:

• Account and Profile Information: When you create an account and profile on the ShareSpace Platform, we may collect your name (or your nickname), email address and other information you may provide, such as specific topics of interest or profile photo. When you select to upload your own photo on your profile, we will require to collect images and other information from your device’s camera and photos based on your explicit consent. The name you select, photo, and any other information that you choose to add to your public-facing profile will be available for viewing by the public and other users of the ShareSpace Platform. Once you create a profile, other users will be able to access certain information in your profile about your activity on the ShareSpace Platform, such as, your friends, topics of interest to you and the number of comments and publications you have contributed. Within your profile, you can find information such as the history of publications you have contributed within the ShareSpace Platform and history of comments posted to your own or other user’s Publications on our ShareSpace Platform.
• User Generated Content: We collect and store the information and content that you post to the ShareSpace Platform, including your comments to your own or other users’ content, the topics that you have selected from our available topics pool and any articles you may create or share within the ShareSpace Platform (your “Content”). In any case, your Content, date and time stamps, and all associated comments are publicly viewable on the ShareSpace Platform, along with your name or nickname. For any questions about your privacy preferences, please contact us through our in-app support function which can be accessed within the ShareSpace Platform in your private profile by clicking on the blue information sign and selecting "Support" from the menu.
• Communications: When you communicate with us (via email, through the ShareSpace Platform or otherwise), we may maintain a record of your communication.
• Linked Networks: You can elect to sign in or sign up to the ShareSpace Platform through a linked network (i.e., Twitter or Google), and you can connect your existing ShareSpace account with certain third-party networks like Google and Facebook (each a “Linked Network”). If you elect to sign up through or connect a Linked Network, we receive certain profile and account information about you from the Linked Network to facilitate your account creation and subsequent log-in. The specific information provided to us by Linked Networks is determined by you and such Linked Networks and may vary by network. In all cases, the permissions page for the Linked Network will describe the information being shared. You should consult their respective privacy policies for information about their practices. You may elect to use information from the Linked Network to populate your profile on the ShareSpace Platform such as your Linked Network profile picture, your name and email address. For any questions about your privacy preferences, please contacting us through our in-app support function which can be accessed within the ShareSpace Platform in your private profile by clicking on the blue information sign and selecting "Support" from the menu.
• Automatically Collected Information About Your Activity: To make your experience on our Platform more pleasant and to enable the use of certain functions, we may use “cookies” on various pages. Cookies are small text files that are stored on your terminal device. Some of the cookies we use are deleted after the end of the browser session. Other cookies remain on your device and enable us or our partner companies to recognize your browser on your next visit. You can set your browser in such a way that you are informed about the setting of cookies separately and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. For more information, see the help function of your Internet browser. If cookies are not accepted, the functionality of our ShareSpace Platform may be limited. To find out more about how we use cookies you can access our “Cookie Policy”.
• Usage and Engagement: The IP address currently used by your device and your device’s unique ID, date and time, the browser type and operating system of your device and model may be recorded. This data is collected for the purposes of optimizing and improving our ShareSpace Platform. The processing is legally based on our legitimate interest to protect our ShareSpace Platform and to improve the quality of our services and to be able to send push-notifications and warnings.

We collect and use this personal data to provide our services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing our services to you.

Our ShareSpace Platform is not intended for use by children under the age of 16 and we do not knowingly collect or use personal information relating to children.

When we use your personal information, we are required to have a legal basis for doing so. There are various legal bases upon which we may rely, depending on what personal information we process and why. Further, your information can only be processed pursuant to specified, explicit and legitimate purposes. Please see the below section for more information:

When we use Legitimate Interest as the basis for the processing of your personal data, we generally do so for the following purposes :

1. Provision of our services and ShareSpace Platform. To provide you with our services and to make ShareSpace Platform publicly available, create and manage your account with us, verify your identity and to generally improve the provision of our services.
2. Protection against fraud and other harmful activity. We want to make sure our Sharespace Platform is secure and protects users against fraud when transacting on the ShareSpace Platform. We may conduct security investigations, risk assessments and other actions in this connection.
3. Compliance with legal obligation. To establish, investigate or defend against claims in connection with conducting dispute proceedings, proceedings before public authorities and other proceedings and to comply with any and all legal obligations.
4. Personalization. To tailor the content and information that we may send or display to you in the ShareSpace Platform, to suggest followers and content, to help others find your profile, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the ShareSpace Platform.
5. Analytics. To gather metrics to better understand how users access and use the ShareSpace Platform; to evaluate and improve the ShareSpace Platform and to develop new products and services.
6. Performance and Service Improvement. Processing of most device data (including the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information) to improve performance of the ShareSpace Platform, troubleshoot bugs, and for other internal product needs. Further We process personal information for improving our Service and our users’ experience with it. For this, we may send to users service or support messages, updates, security alerts, and account notifications or users may send us a feedback
7. Marketing. Sending informational or promotional emails to market our services to existing and former subscribers based on our legitimate interests to promote our business and client engagement and to third parties who have previously expressed an interest in our services, or third parties based on their adequate consent. You may opt-out from receiving such marketing communications by unsubscribing through the relevant communication or by contacting us through our in-app support function which can be accessed within the ShareSpace Platform in your private profile by clicking on the blue information sign and selecting "Support" from the menu.
8. Communications and Push Notifications. We may also contact you via email and in-app support function to provide you with system updates and notifications and information about similar products and services such as to inform you about changes to your account information, profile and preferences pursuant to our contractual obligations with you and based on our legitimate interests to provide our services and the enable the smooth and continuous use of our ShareSpace Platform. If we have your adequate consent, we may also send push notifications through our Platform. In most cases, you can opt-out of receiving push notifications by going to your device "Settings" and clicking on "Notifications" and then changing those settings for some or all of the apps on your device.

3. Marketing

We may use your personal data to send you updates (by email) about our services, including exclusive offers, promotions or new similar products or services offered by our ShareSpace Platform.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at via email at [email protected];
• using the ‘unsubscribe’ link in emails; or
• using our in-app support function which can be accessed within the ShareSpace Platform in your private profile by clicking on the blue information sign and selecting "Support" from the menu.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to other organizations for marketing purposes.

4. Data Recipients

Within our Company, your personal data is accessible only to those who need to and only for the purposes mentioned in paragraph 2 above.

We may disclose Your information to our affiliates, in which case We will require these affiliates to comply with this Privacy Notice. Outside our Company, recipients of your personal data may be any subcontractors or third parties who cooperate and/ or provide services to our Company in the context of its business, such as companies that provide email services, web hosting services, information technology services, legal representatives, auditors etc.

We choose our associates very carefully, after the necessary checks have been carried out and sufficient guarantees have been provided to implement appropriate technical and organizational measures in such manner that processing will meet the requirements of the GDPR and the relevant laws and ensure the protection of your rights.

We may also need to:

• share personal data with external auditors, e.g. in relation to the audit of our accounts;
• disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
• share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

5. Retention Period

Personal data provided to us via our ShareSpace Platform will only be stored until the purpose for which they were processed has been fulfilled or – in the case of consent – until you withdraw your consent. Insofar as retention periods under commercial and tax law must be observed, the storage period for certain data can be up to 7 years. However, storage periods may also be amended due to our legitimate interest (e.g. to guarantee data security, to prevent misuse or to prosecute criminal offenders).

6. Transfers of data outside the EU / EEA

If your data will be transferred to entities or other third parties whose headquarters or place of data processing is not located in a member state of the European Union or the European Economic Area, we ensure before forwarding the data that, outside of legally permitted exceptional cases pertaining to the recipient, either an appropriate level of data protection exists (e.g., through an adequacy decision of the European Commission, through suitable guarantees, or the agreement of EU standard contractual clauses between us and the recipient), or your sufficient consent exists.

7. Security

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. These measures include, but are not limited to, encryption, access control, internal audit etc. Furthermore, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

8. Your Preferences

You may choose not to provide the personal data we ask for, however if you do so it may delay or prevent us from providing our services to you, or certain areas within the ShareSpace Platform might not be available for you. You may also control the way and reasons where we could contact you, limit which information is made available in public and otherwise amend certain privacy settings. Here is some further information about some of your choices:

Your Content. The comments that you have posted can be deleted at any time. Further, you may create, edit, share or delete the Publications that you have posted at any time. When you make edits to your Content, other users may be able to see that the Content has been edited.

Communication and Notifications. We may also contact you via email and in-app messaging to provide you with system updates and notifications and information about similar products and services such as to inform you about changes to your account information, profile and preferences. If you opt-out of receiving emails or other notifications about recommendations or other information we think may interest you, we may still send you transactional emails about your account or any services you have requested or received from us.

Profile Discoverability. You can adjust your settings to block others from discovering your account by searching for your name or using your contact information, including when another user imports their contacts from a third-party service.

Account Termination. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirement.

9. Your Rights

As a data subject, you may contact us at any time to make use of your rights. These rights are the following:

• The right to receive information about the data processing and a copy of the processed data;
• The right to demand the rectification of inaccurate data or the completion of incomplete data;
• The right to demand the erasure of personal data;
• The right to demand the restriction of the data processing;
• The right to receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to request the transmittance of these data to another controller in certain situations;
• The right to object to the data processing;
• The right to withdraw a given consent at any time to stop a data processing that is based on your consent; and
• The right to complain to a competent supervisory authority.

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below)

If you still feel that your personal data has not been handled appropriately according to the law, you can submit your complaint with the Office of the Commissioner for Personal Data Protection, at 1 Iasonos Street, 2nd Floor, 1082 Nicosia, tel. +357 22 818456, email address

[email protected]

10. How to contact us

You can contact us by post, email or through the In-app support function, which can be accessed within the ShareSpace Platform in your private profile by clicking on the blue information sign and selecting "Support" from the menu, if you have any questions about this privacy policy or the information, we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

[email protected]

+33677994428

11. Changes to this privacy policy

This privacy notice was published on [19.03.2021] and last updated on [19.03.2021].

We may change this privacy notice from time to time and when we do, we will inform you via our ShareSpace Platform or other means of contact.

Cookie Policy

Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our Platform. This policy should be read together with our [https://sharespace.health/privacy-policy] which sets out how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.

This Cookie Policy applies to the access and use of the Share.Space mobile Application (for Android ver. 4.4+, Android beta 4.1+, IOS - 9.0+), the ShareSpace website hosted at https://sharespace.health website, as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the “ShareSpace Platform”) which is operated by Sharespace Ltd.

The ShareSpace Platform is an online communication platform for all people to share and discuss what they are going through in life. Our mission is to give people opportunities to open up, support and uplift each other. We want to make the world a better place by thriving on compassion, mutual understanding and respect. For more information please visit [https://sharespace.health].

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Platform. We use cookies on our Platform. These help us support our security features i.e. detect for malicious visitors, recognize you and your device and store some information about your preferences or past actions.

For example, we may monitor how many times you visit the Platform, date of your first and most recent visit, which pages you go to, device data (such as browser type, operating system and flash version), IP and network data, traffic data, location data and the originating domain name of your internet service provider. This information helps us to identify trusted web traffic, verify your account, generate statistical and analytical data on how our visitors use our website, our reach and click on links as well as display relevant and engaging ads for you. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.

For further information on cookies generally, including how to control and manage them, visit the [http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/All/71B32C48C08B5AC1C22582780040F80E] guidance on cookies published by the Office of the Commissioner of Personal Data Protection in Cyprus, or www.allaboutcookies.org/ .

Consent to use cookies and changing settings

We will ask for your permission (Consent) to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (enabling basic functions like page navigation and access to secure areas of the website).

For more information on how you can change your preferences please see ‘How to turn off all cookies and consequences of doing so’ below. It may be necessary to refresh the page for the updated settings to take effect.

Our use of cookies

The table below provides more information about the cookies we use and why:

Third party access to the cookies

The cookies we use will only be accessed by us and those third parties named in the table above for the purposes referred to in this cookie policy. Those cookies will not be accessed by any other third party.

How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our Platform.

For further information on cookies generally, including how to control and manage them, visit [http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/All/71B32C48C08B5AC1C22582780040F80E] guidance on cookies published by the Office of the Commissioner of Personal Data Protection in Cyprus, or www.allaboutcookies.org/ .

How to contact us

Please contact us if you have any questions about this cookie policy or the information, we hold about you.

If you wish to contact us, please send an email to [email protected], contact as through our in-app support function which can be accessed within the ShareSpace Platform in your private profile by clicking on the blue information sign and selecting "Support" from the menu, or call +33677994428.

Changes to this policy

This policy was published on [19.03.2021] and last updated on [19.03.2021].

We may change this policy from time to time, when we do so we will inform you via System Notifications.