PRIVACY POLICY

1. WHO ARE WE?

WAVE APP, S.L. (hereinafter, “WAVE”), a Spanish company with Tax Id. Number B-86942901, registered office at Calle Galgo, n. 1, 28223 Pozuelo de Alarcón (Madrid), duly registered in the Companies Register of Madrid, Volume 31.946, Folio 150, Section 8, Sheet n. M-574.944, Inscription 1, is the owner of the website located in the domain namewww.waveapplication.com (the"Website"), as well as the mobile application "Wave Let's Meet App" (the "Application"), hereinafter referred jointly as the “Service”.

WAVE is the data controller of the data you have provided us. We have developed this privacy policy because we want you to feel confident about the privacy and security of your personal information. WAVE takes all reasonable care to prevent any unauthorised access to your personal information.

This privacy policy is applicable to the Website, understood as all the pages and subpages included in it, as well as to the Application, and WAVE declines any responsibility for the different privacy policies that may contain the websites to which can be accessed through hyperlinks located on the Website or in the Application and not managed directly by WAVE.

With your freely given, specific, informed and unambiguous consent, we will process your data in a lawful, fair and transparent manner, committing ourselves to comply with the obligations imposed by Regulation (EU) No. 2016/679, 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 ("General Data Protection Regulation") and current Community and Spanish development regulations (hereinafter, the "data protection regulations”).

2. WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU?

All the data requested at the time of your registering as User of the Application are mandatory. Likewise, the data that we can request as data subject through the forms on our Website are also mandatory. If you do not provide us with this information, we will not be able to offer you the registration and / or use of the Service. On the other hand, once you have registered as a User of the Application, WAVE will also collect certain necessary information, regarding your use of it, to allow you to enjoy its features.

We may collect and process the following personal information about you:

— Your identification details information (such as your name and surname, or username and password);

— Your contact information (such as your email address or your telephone number);

— The data of your phonebook, to access the contacts of your phone only to inform you of who are also users of the Application;

— The identification data of your device (specifically, the push token key of your mobile phone);

— Your real-time location data, for you to be able to share it with other users or groups of your choice, so they can be able to locate you in a map in real-time;

— The contents of the chat that we offer you in our Application, only to operate the service. Such contents are stored as a unitary block of information, without we are able to access them;

— Biometric data (i.e. your user profile picture). Have in mind that when you upload your picture you authorize us to use it only for that purpose, and give us all the necessary rights related to that purpose. Also, you guarantee that the picture you provide us does not infringe any third party rights, and in any event, you will remain WAVE harmless of any claim by any third party arising out of its use;

— Your professional data (for example, your academic and professional experience published in your Curriculum vitae, only in the case of you applying in our job offers).

3. DATA PROCESSING OF UNDER AGE USERS

In order to be able to download the Application and use WAVE’s services you must be at least 14 years old. If you are between 14 to 18 years old, WAVE recommends you to inform yourself and check with your parents/legal guardians when transmitting information to other users whom you have contacted through our Service.

It remains expressly prohibited for anyone under 14 years of age to register as a user. If you are under 14 years old, please do not try to register or request information through our Website or Application. If we discover that we have obtained data from someone under 14 years of age, without his parents or legal guardian’s consent, we will delete that data immediately.

4. WHY DO WE PROCESS YOUR DATA?

WAVE collects and processes manually and automatically all the data that you provide us solely for the purpose reported in each case. Amongst these purposes, we can dispose and process your data in order to:

— Manage your WAVE user account, in order for you to be able to use our Application;

— Enable you to send “Waves” to your contact list, being able to show them your real-time location, as well as to store the link of your last shared location via url registry;

— Receive customised notifications based on your use of the Application;

— Identify what people of your contact list are also users of the Application, as well as letting you invite those contacts who are not users of the Application;

— Upload your picture in your user profile in the Application and so as to display it to the rest of the users on your contact list;

— Create and identify the groups you have created in the Application or those where you are a part of, putting at your disposal a private chat to be able to communicate with other users;

— Only if you have authorised us to, we will process your data in an automated way to enable the creation of user profiles, based on the data you have provided when signing up and during your use of the Application, with the purpose of sending you personalized customer communications adapted to your profile;

— Solve all your informative enquiries and answer the requests that you make us via our Website or our social media profiles;

— Send you informative communications about the range of services we offer you in WAVE;

— Should you send us your CV or you subscribe in one of the different job offers that we may post, we will process your data for the purpose of manage your application and when applicable, perform the necessary tasks in the selection and recruitment process.

5. FOR HOW LONG DO WE STORE YOUR DATA?

We store your personal data only during the time period reasonably necessary, during the time period in which you maintain your registered Application user account and until you decide to unsubscribe, or during the time necessary to attend your request, until you request to not receive our informative communications about our services.

We can preserve your personal data only for a reasonable length of time, even after you stop using our service, and only when required to do so by law, under a court order or in response to lawful demands of public bodies, officials or courts require so, your personal data will be duly stored, protected and kept of all WAVE systems, to prevent its access and processing. Once the actions prescribe in each case, we will proceed to the removal of your personal data.

6. WHAT DOES LEGITIMATE US TO PROCESS YOUR DATA?

WAVE’s legitimation for the processing of personal data collected via our Website or the Application is based in the freely given, specific, informed and unambiguous consent given by the users for the processing of his data with the following purposes:

— The data processing to manage your user account is necessary for us to be able to enable your login and use of the Application. Our lawful ground for processing this data is your consent and that our processing is necessary to deliver our service.

— The processing of your location data is necessary so that the Application allows you to share your location in real-time with your contacts. As a User you consent WAVE to access your location and to store it. You are the one who decides in every moment who do you want to share with your location, so only those Users that have been specifically selected by you are going to have access to such information. Under no circumstance, the information related to the User’s location will be shared by WAVE with any other third parties different from those that the User has selected.

Likewise, you will be able to stop sharing your location with other users at any time. For that purpose, you will have to delete all opened individual or group channels group channels. This option will be always available for the Users. Our lawful ground for processing this data is your consent and that our processing is necessary to deliver our service.

— The processing of your data for enabling us to send you notifications is necessary so that you are properly informed about how to optimize the use of our Application. Our lawful ground for processing this data is your consent and that it is in our legitimate business interest to do so.

— The processing of your contact data in your phonebook is necessary so that you are able to locate your contacts in our Application and enable your communication with them. Our lawful ground for processing this data is your consent and that our processing is necessary to deliver our service.

— In the event of you uploading a picture in your user profile, our processing of such data is necessary to enable your identification to your contacts and WAVE users, and to allow you to communicate with them through the Application. Our lawful ground for processing this data is your consent.

— The processing of your data with the aim to create and identify groups is necessary so that you are able to communicate with your contacts in accordance with your personal interests. Our lawful ground for processing this data is your consent and that our processing is necessary to deliver our service.

— The processing of your data with the purpose of user profiling is necessary so that you are able to get a better and personalized user experience of the Application, in an adequate manner for your needs. Our lawful ground for processing this data is your consent and that it is in our legitimate business interest to do so.

In any case, you have the right not to be subject to a decision when it is based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you, by following the instructions of section 10, “What are your rights when you provide us with your data?”.

— The processing of your identifying and contact data is necessary for us to be able to solve your enquiries via our Website or social media and to be able to provide you information about our service. We process your data on the grounds of our legitimate corporate interest.

— The processing of your identification details and contact data is necessary for us to be able to send you informative notifications and to keep you updated about our services. Our lawful ground for processing this data is your consent and that it is in our legitimate business interest to do so.

— The processing of your professional data as a job applicant or as a collaborator for WAVE is necessary for us to be able to manage your application and in the event of, your recruitment. Our lawful ground for processing this data is your consent and in the event of, your employment contract with us.

7. DO WE SHARE YOUR DATA WITH ANYONE ELSE?

We may need to share your personal data with third parties, only if such shared accesses are necessary to provide you with our services. When we do so, such third parties will be able to access only if they perform in accordance with the instructions we give them and they must meet the requirements of applicable data protection legislation when processing your personal data.

In particular, your personal data may be provided to IT service providers, who provide us with data and storage management technological services, which are essential for the maintenance of our Service, and to business consultancy companies, in order to them being able to provide us with the services we agree with them.

Also, we may share your data in response to lawful requests, for the purposes of prevention and detection of crime, and to take the necessary measures to conform the information about asset solvency and credit information, through a prior unsatisfactory default notice of payment. In particular, WAVE may share your data with the following entities:

— Public entities and institutions, judges and courts when required by tax, labour or any other applicable law;

— Data processors: IT service providers, who provide us with data and storage management technological services, via cloud computing services, as well as business consultancy companies that provide us with accounting, billing, human resources and other services related to business management, for which services WAVE has entered into data processing agreements.

8. TRANSFER OF DATA OUTSIDE OF THE EEA

In order to offer our services, WAVE uses service providers from the United States of America. For that matter, and with our compliance of the rules in applicable data protection legislation in terms of international data transfers, your data may be sent to the United States of America. By your mere use of the Website or the Application, you will acknowledge, understand and authorize such international data transfer.

9. HOW DO WE PROTECT YOUR DATA?

We are serious about guarding the security and protection of you personal data. WAVE guarantees you that we have taken appropriate organisational and technical security measures required by law and adequate to our Service, by installing and/or adopting all the technical, personal and organisational means and measures to be able to guarantee the confidentiality, integrity and quality of your data, prevent its loss, improper use, modification, theft and unauthorised disclosure or processing of the personal data.

We use various security measures to protect the information we collect, as appropriate to the type of information, including encryption and access controls. We also make sure that our employees and managers are suitably qualified to be able to protect your personal data and guarantee its confidentiality.

WAVE will immediately notify any kind of security breach in your personal data to the supervisory authority (the “Agencia Española de Protección de Datos”).

10. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

WAVE is committed to protect your privacy and confidentiality of your personal data. For such reason we will give you the appropriate answers when you request the exercise of your rights. You can exercise your rights via sending an e-mail to our address [email protected] whether you identify yourself properly and you indicate clearly of the subject of your application.

You have the following rights in relation to the personal data we process:

— Your right of access: you have the right to request access to the data we are processing, and to ask whether we’re processing your personal information and, if so, inform you about the processing we are doing.

— Your right to rectification: if the personal information we hold about you is inaccurate, incomplete or outdated, you are entitled to have it rectified.

— Your right to erasure: you can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent.

— Your right to restrict processing: you can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it.

— Your right to data portability: you have the right, in certain circumstances, to obtain personal information you have provided us with, in a structured, commonly used and machine readable format, and to reuse it elsewhere or ask us to transfer this to a third party of your choice (like other processing managers.

— Your right to object: you can ask us to stop processing your personal information, and we will do so, if we are relying on our own or someone else’s legitimate interests to process your personal information, or we are processing your personal information for commercial purposes.

— Your rights to oppose to automated decision-making and profiling: you have the right not to be subject to a decision when it is based on automatic processing, such as profiling, and it produces a legal effect or similarly significantly affects you.

— Your right to lodge a complaint with the supervisory authority: if you have a concern about any aspect of our privacy practices, you can report it to the “Agencia Española de Protección de Datos”, through the website http://www.agpd.es , by calling to the number 901 100 099, or via certified mail to the address of the Agencia Española de Protección de Datos, C/Jorge Juan nº 6, 28001 Madrid.

11. USE OF COOKIES

Our Website uses cookies in order to provide you specific services and features, as well as helping users to improve their navigation experience. You can find further information thereon in our Cookies Policy.

12. LINKS TO THIRD PARTY WEBSITES

We may link websites that are not operated or controlled by us. Also, all interested parties or third parties may provide with links that direct to the website content, whenever its provided that they link to a different site from the one those links are sited. WAVE is not liable for the content of third party websites, neither does have control on how those third parties gathered and used their personal information, neither provide with any statement about any of them.

13. PRIVACY POLICY MODIFICATIONS

WAVE reserves the right to modify this Privacy Policy complying with the rules in applicable legislation in all time. Thus, WAVE may inform you about such modifications when they are made, which are going to be binding once published. We encourage you to periodically visit this Privacy Policy to acknowledge about how we process and protect the personal data you provide with us.

COOKIES POLICY

This Cookies Policy takes part in the Privacy Policy of the website hosted under the domain www.waveapplication.com (the “Website”) and under any subdomains or websites dependent on it. We use cookies to improve our services.

1. WHAT IS A COOKIE?

A cookies is a small information file created by the website you are visiting, which keeps information in the User’s computer to provide access to different features.

2. WHY DO WE USE COOKIES?

We use cookies to be able to obtain more information about the way Users use our content and help us improve their experience when visiting our Website.

3. WHAT KIND OF INFORMATION DO COOKIES PROVIDE WITH?

In particular, our cookies provide us with the following information:

(i) The provider’s domain name number, which grants you Internet access. For example, if your provider is XXX we are only going to identify him as xxx.es. By doing this, we can elaborate statistics about the countries and servers that visit our website more frequently.

(ii) The date and time of access to our Website and the amount of time every User spends on it. That allows us to find out the hours of most user influx, and make the necessary adjustments to avoid saturation problems.

(iii) The Internet address that provided the link to our Website. Thanks to this information, we can find out the effectiveness of the different banners and links that redirect to our server, with the purpose of boosting those that offer better results, and to satisfy the information needs of our Users.

(iv) The amount of daily visitors to every content. That allows us to know which areas the most successful areas and lets us to be able to boost and improve its content, with the purpose of giving more satisfactory information to the Users. The information obtained is totally anonymous, which means that it cannot be linked to a particular or identified User.

(v) The chosen language for every User during his first visit to the Website and to the restricted areas.

(vi) Security elements that intervene in access controls to restricted areas.

(vii) User’s activity in the Website: links and places where he clicks, pages visited, what he searches, etc. That allows us to improve the website features and to make it more attractive and useful for the User.

The information to which we have access through cookies lets us customize our content based on User’s interests, but in any case, our cookies do not let us obtain personal data, neither read data or other cookies existing in the User’s computer.

4. TYPES OF COOKIES

We use the following types of cookies in our Website:

According to the entity in charge to manage them:

(i) Own cookies: cookies sent to the User’s terminal devices from an device or domain managed by the editor which is the one that offers the services requested by the User.

(ii) Third party cookies: cookies sent to the User’s terminal device from a device or domain managed by the editor, or from another entity that is in charge of the processing the obtained data from cookie traces.

According to the time that they remain active:

(i) Session cookies: cookies designed to gather and store data while the User accesses a website. They expire once the User leaves the website.

(ii) Persistent cookies: cookies designed to gather and store data. The stored data are kept in the terminal, and are accessible and processed during the period of time defined by the cookie manager, it being such period of time may last from minutes to years.

According to their purpose:

(i) Technical cookies: these cookies let the User navigate throughout the Website and use its different options and services.

(ii) Analysis cookies: these cookies allow to quantify the amount of Users and their connection time, in order to develop appropriate statistical analysis and measurements about the usage of the offered services for the purpose of being able to improve the services provided to the Users.

In particular, the cookies we use, its owner, their duration (whether are session or persistent cookies) and their role are specified in the following chart:

COOKIE

OWNER

DURATION

ROLE

_utma

Google Analytics

Persistent

It collects anonymous information about users who navigate throughout the Website to collect information about the source of those visits and other related statistics.

_utmz

“”

“”

“”

_ga

“”

“”

“”

How do you reject cookies?

You can stop the installation of cookies in your computer at any time by using the pertinent option in your browser (using the help feature), in such case we will not be able to guarantee the correct functioning of the different features on our Website.

Here is a list links related to the administration and blocking of cookies, depending of the browser you are using: