This Privacy Policy applies to your use of the Lucky Walk mobile application (the “App”), any website operated by Lucky Walk and the services we provide that are accessible to our users. This privacy Policy describes the way we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our applications (the “App”) and/or websites (collectively, the “Services”). Please note that you must be aged 13 years or older to use the Services. Please do not use the Services or provide us with any personal information if you are under 13 years of age.

By using the Services, you are expressing your agreement to this Policy and the processing of your data in the manner provided by this Policy. If for any reason you do not agree to these terms, please do not use the Services.

We reserve the right to change this Privacy Policy at any time. We will notify you of any such changes we may make to this Privacy Policy by updating the “Last updated” date at the top of the Privacy Policy page. Please check the Privacy Policy available on the Lucky Walk application and Lucky Walk website(s) from time to time. In the event of any such change, by continuing to use the Lucky Walk application and/or Lucky Walk website(s) you agree to the relevant change(s).

1.Information We Collect

When you access or use our Services, we may collect information about you as described below. Our primary goal is to limit the information we collect to the minimum, especially personal information, but some information is required to be able to provide you with a customized experience and to deliver and improve our Services.

1. Account Information: When you first launch the App, we assign you an anonymous Account ID, but we do not require you to provide your name, email address or phone number. In addition, you may be required to create a nickname to use some of the features of our Services. We strongly advise you not to choose a handle that contains personally identifiable information such as your name.

2. Device Information: We may collect certain information such as your device or mobile device identifiers, device name, hardware model, operating system and version, mobile network information, country, IP address, language information and any other information you choose to provide.

3. Content and Usage Information: We collect any content you submit to the Services as well as information about the content, such as the time it was submitted. We also collect information about your use of the services, including app activity, app statistics and interactions with other user contents.

4. Other Information you Provide to Us: When you interact with our Services or otherwise communicate with us in any way, we will collect the information you choose to share with us. Any questions that are sent to our Customer Service team or any support tickets that are filed may be stored for service improvements.

5. Information Collected by Tracking Technologies: We and our marketing and outsourcing partners use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. You can disable cookies at any time, although you may not be able to access or use features of the Service. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We use mobile analytics software to allow us to better understand the functionality of our Services on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you may submit within the mobile application.

6. Other Information Collected with Permission: Our mobile applications that are distributed through various "app" stores (including iOS and Android) may also request permission to automatically collect other information from your mobile device. We may only collect this information with your authorization in accordance with your device operating system's permission process.

2. Use of Information

We may use your personal data to:

• provide the Services (using our own systems and those of appropriate third-party service providers);

• verify your physical movement and location and reward StepCoins on the basis of this verified data;

• analyze the usage of, and improve, the Services;

• communicate with you, including without limitation to inform you of updates to the Lucky Walk application, Lucky Walk Website(s), our Terms & Conditions and/or this Privacy Policy;

• perform market and customer research;

• market our services to you;

• correct errors and problems with the Services;

• investigate and/or prevent suspected fraud or other criminal activities;

• populate user stories on your Lucky Walk feed;

• ship the items that you have redeemed from our rewards page;

• operate the Lucky Walk application; and/or

• investigate disputes between users.

Additionally, we and/or our trusted partners may contact you from time to time with offers that may interest you and/or to inform you of other products and services. Certain of your personal data may be shared with other users of the Lucky Walk application as part of the normal operation of the Services (for example we may publish your total verified steps, or other movement, during a particular period to other users from time to time). Further, we may, from time to time, expand or reduce our business which may involve the transfer of certain divisions or assets of our company to other parties, and the data we store and use, where relevant, may be transferred to such third parties.

Your personal data will be kept only for as long as is necessary. We take reasonable industry-standard care in keeping all our data secure and in preventing any unauthorized access or unlawful use of it. **All personal data we store and process is handled strictly in accordance with applicable data protection legislation.

3. Analytics, Advertising and Other Third Party Services

We may allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as rewards programs and tournaments. These third parties may use cookies, web beacons and other technologies to collect information about you on our Services and other websites and online services, such as your IP addresses, device manufacturer and operating system, identifiers associated with your mobile device or applications on the device, browser types and user activity. This information may be used by us, and these other companies and their customers and clients, to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage. Some of these third-party analytics and advertising services offer you a choice to opt out the collection of and/or sharing of this information; links to the opt-out mechanisms for the third parties that offer such a choice can be found in the "Your Choices" section below. This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies.

4.COOKIES

We use cookies to distinguish you from other users of the Lucky Walk application and website(s) and obtain certain information about your usage and behavior. A cookie is a small file of letters and numbers that we put on your computer when you use the Lucky Walk application or website(s). This helps us to provide you with a better experience when you use the Lucky Walk application or browse the Lucky Walk website(s) and also allows us to improve the Services. We will use both persistent cookies, which could remain on your device until their expiration (which, in some cases, is up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.

The types of cookies we may use include:

• Analytical/Tracking Cookies, which allow us to recognize and count the number of visitors and analyze use of the Services, as well as to verify transactions; and

• Advertising and Retargeting Cookies, which allow us to generate appropriate advertising directed to you on the Lucky Walk application as well as on Lucky Walk website(s) and other third-party websites.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You may block cookies by activating the appropriate setting on your browser but, if you do so, you may not be able to use all functionalities of the Services.

We use a number of industry-standard data analytics tools, such as Google Analytics and Facebook Analytics. These collect certain information about you, such as your device’s IP address and browsing and usage behavior, and are used to allow us to track and monitor the traffic visiting the Lucky Walk application and website(s).

5.Storage and Protection of Information

We take reasonable technical, physical and administrative measures to safeguard your personal information against loss, theft, and misuse, as well as from unauthorized access, disclosure, alteration, and destruction. Furthermore, our trusted vendors and business partners are not authorized to use such information for purposes beyond those specified by us and are required to preserve the confidentiality with which we treat such information.

However, while we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure, and there may be factors beyond our control that may result in disclosure of personal information. In particular, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.

As a consequence, we disclaim any warranties or representations relating to maintenance or nondisclosure of any personal information collected from users.

6.Your Choices

a.Access to Personal Information

You have a right to request access to any personal information that we hold in relation to you. You may also review, update, correct or delete your personal information collected by the Services. You may also correct factual inaccuracies. To access the personal information that we hold in relation to you or to review, update, correct or delete your personal information collected by the Services, please contact us at hi@mobo.ai.

In order to have access to your personal information, you must provide a proof of identification such as full name, address, account ID and/or information about your recent activity on the Services. We reserve the right to deny access to any user if we believe there is a doubt about your identity. And if the burden or expense of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still retain your information in our files to resolve disputes, enforce the Terms of Service, and for technical and legal requirements and constraints related to the Services. However, we will not use such personal information for any other purpose.

b.Opting Out of Push Notifications

We may occasionally send you push notifications to your. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings or by changing your App settings.

c.Special Note to Parents

Our Services are not intended for children under the age of 13 in principle and we do not knowingly or solicit personal information from anyone under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have inadvertently gathered personally identifiable information from children under the age of 13 without their parents' consent, we will take reasonable measures to promptly erase such information from our record.

7.Contact

If you have any questions, complaints, or comments regarding our Privacy Policy, or have other questions or suggestions about our Services, please contact us via e-mail at hi@mobo.ai.