Released: Jan 28, 2025

Last Update: Feb 27, 2023

• 1.1 Purpose of This PolicyWe respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) in the “Sprize” mobile application (“Mobile Application” or “Service”) and any of its related products and services (collectively, “Services”). It also outlines our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information, as well as the choices available to you regarding our use of your Personal Information and how you can access and update it.
• 1.2 Legal AgreementThis Policy is a legally binding agreement between you (“User”, “you” or “your”) and Cowlabs Ltd (doing business as “Developer”, “we”, “us” or “our”). By accessing and using the Mobile Application and Services, you acknowledge that you have read, understood, and agree to be bound by this Policy.
• 1.3 ScopeThis Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. If you do not agree with the terms of this Policy, you may not access or use the Mobile Application and Services.

• 2.1 Information Collected Automatically
• - When you use the Mobile Application, our servers automatically record information sent by your device.
• - This data may include your device’s IP address, location, device name and version, operating system type and version, language preferences, search queries within the Mobile Application, access times and dates, and other statistics.
• - Information collected automatically is used only to identify potential cases of abuse and to establish statistical information regarding usage of the Mobile Application and Services.
• - We do not collect or store any personally identifiable information through these automated logs.
• 2.2 Information You Provide
• - To make the Mobile Application and Services available to you or to meet a legal obligation, we may need to collect and use certain Personal Information.
• - If you choose not to provide this information, we may not be able to provide you with the requested products or services.
• - Any information we collect from you may be used for the following purposes:
• a) Improve products and services
• b) Enforce terms, conditions, and policies
• c) Protect from abuse and malicious users
• d) Run and operate the Mobile Application and Services

Processing your Personal Information depends on how you interact with the Mobile Application and Services, where you are located, and one or more of the following legal bases:

- Consent: You have given consent for one or more specific purposes.- Contractual necessity: Provision of information is necessary for the performance of this Policy or for any pre-contractual obligations.- Legal obligation: Processing is necessary for compliance with a legal obligation.- Public interest or official authority: Processing is carried out in the public interest or in the exercise of official authority vested in us.- Legitimate interests: Processing is necessary for the legitimate interests pursued by us or by a third party.

We rely on user consent as the primary legal base to collect and process your Personal Information. However, under some legislations, we may be allowed to process information until you object to such processing by opting out, without having to rely on consent.

• 4.1 Sharing with Service Providers

- We may share your information with contracted companies and service providers (“Service Providers”) to assist in operating the Mobile Application and Services.- These Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements.- We do not share personally identifiable information with unaffiliated third parties.

• 4.2 No Third-Party Marketing

- Service Providers are given the information they need only to perform their designated functions.- They are not authorized to use or disclose any of the provided information for their own marketing or other purposes.

• 5.1 Retention Period

We will retain and use your Personal Information for as long as necessary to comply with our legal obligations, enforce our Policy, and resolve disputes, unless a longer retention period is required or permitted by law.

Once the retention period expires, Personal Information is deleted.

• 5.2 Post-Retention Use

We may continue using aggregated data derived from your Personal Information after you update or delete it, but not in a way that identifies you personally.

- Depending on your location, data transfers may involve transferring and storing your information in a country other than your own.

- However, such transfers will not include countries outside the European Union and European Economic Area unless otherwise specified.

- We adhere strictly to the guidelines outlined in our Policy and conform to the applicable legal requirements to ensure the security of your data.

• 7.1 Residents of the EU/EEA and the UKIf you are a resident of the EU, EEA, or UK, you have rights under the GDPR and UK DPA, including:

- Right to withdraw consent- Right to access- Right to rectification- Right to object- Right to restrict processing- Right to delete- Right to data portability- Right to lodge a complaint

• 7.2 Residents of the USAIf you are a resident of certain U.S. states, you may have rights under relevant privacy laws (e.g., CCPA, CPRA, CPA, CDPA, DOPPA, ICDPA, PIPA, UCPA, VCDPA) which may include:

- Right to know/access- Right to correct- Right to delete- Right to opt-out of sale and sharing- Right to consent to or limit the use of your sensitive personal information- Right to non-discrimination

To exercise any of your rights, contact us using the details at the end of this Policy.

- You may submit requests to exercise your rights using the contact details provided below.- We may ask you to verify your identity before responding to such requests.- Your request must provide sufficient information to allow us to verify your identity or authorized representative status.

- Our Mobile Application and Services may use third-party analytics tools (e.g., cookies, web beacons) to gather standard internet activity and usage information.- We use these reports only to monitor performance and improve our Mobile Application and Services.- We do not associate the information gathered with any individual user.

- We do not knowingly collect any Personal Information from children under 18.- If you believe that a child under 18 has provided Personal Information to us, please contact us so we can delete that information.- Parents and guardians are encouraged to supervise their children’s online activities.

- You have the right to choose not to have your Personal Information sold or disclosed.- To opt out, contact us using the details provided below.- Note that opting out of data transfers to third parties may affect some Services we offer.- We reserve the right to reject opt-out requests in certain situations as permitted by the CCPA.

- Our Mobile Application and Services may include Social Media Features (e.g., Facebook, Twitter (X), Discord buttons).- These features may collect your IP address and set cookies to function properly.- Interactions with these features are governed by the privacy policies of their respective providers.

- Our Mobile Application and Services may contain links to resources not owned or controlled by us.- We are not responsible for the privacy practices of these external resources.- We encourage you to read the privacy policies of every resource that may collect your Personal Information.

- While we strive to protect your Personal Information, no data transmission over the internet or wireless network can be guaranteed.

- You acknowledge potential security and privacy limitations of the internet which are beyond our control.

- If we become aware that the security of our Application and Services has been compromised, we reserve the right to take appropriate measures, including investigation and notification to law enforcement.

- We will make reasonable efforts to notify affected individuals if there is a reasonable risk of harm or if legally required.

- We reserve the right to modify this Policy at any time.

- When we do, we will update the “Last Updated” date and post a notification in the Mobile Application.

- Continued use of the Mobile Application and Services after changes become effective constitutes your acceptance of the revised Policy.

- By accessing and using the Mobile Application and Services and submitting your information, you agree to be bound by the terms of this Policy.

- If you do not agree with these terms, you are not authorized to use the Mobile Application and Services.

If you have questions, concerns, or complaints regarding this Policy, please contact us at:

Email: hello@cowlabs.xyz

We will attempt to resolve any complaints and disputes promptly, and honor your requests to exercise your rights within the timescales specified by applicable data protection laws.

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