SHAREgo Privacy Policy

Effective Date: June 23, 2025

Your privacy is important to us. This Privacy Policy ("Policy") explains how SHAREgo ("we," "our," or "us") gathers, uses, and safeguards your personal information when you use the SHAREgo mobile application (the "App" or "Services"). It also outlines your rights regarding your data.

If you have any questions about this Policy or our data practices, please refer to the "Contact Us" section below.

This Policy may be available in multiple languages. In case of any discrepancy, the English version of this Policy will take precedence where legally permissible.

1. Information We Collect

"Personal information" refers to data, or a combination of data points, that could reasonably identify you. We collect personal information from various sources: directly from you (e.g., when you interact with us), data we generate during our relationship, and information from other sources like public databases and third-party services (such as social media, advertising, and analytics partners), where legally allowed.

We may also collect certain personal information as mandated by law or our contractual agreements. Failing to provide such information might hinder or delay our ability to fulfill these obligations. We will inform you at the time of collection if certain data is mandatory and explain the consequences of not providing it.

When you use or interact with our App, we may automatically collect the following categories of personal information:

• Device Details: Such as your device ID, advertising ID (GAID), and approximate location data.
• Network Information: Including your IP address.

2. How We Use Your Information and Our Legal Basis

We may use your personal information for the following purposes:

• Account Management: To create user accounts and provide support for App usage.
• Service Enhancement: To offer operational and maintenance support and improve our Services.
• Advertising: To display non-personalized advertisements and measure their effectiveness.
• Sharing Functionality: To facilitate the core sharing features of the SHAREgo app, allowing you to share content with other users.

Our legal basis for processing your personal information, as required by applicable laws, generally falls into one of the following categories:

• Your Consent: When you provide your explicit consent for specific processing activities, as outlined in this Policy. You can withdraw your consent at any time by contacting us.
• Contractual Necessity: To fulfill our obligations to you, such as providing the Services you request.
• Legal Compliance: To adhere to legal requirements, for example, to verify your identity for fraud prevention.
• Legitimate Interests: Where permitted by applicable laws, to pursue our legitimate business interests, provided your privacy rights are protected. This includes:
  • Understanding how you use our Services to develop new offerings.
  • Performing data analysis to ensure the stability and security of our Services and prevent fraud or misuse.
  • Delivering non-personalized advertising, which helps keep many of our services free.
  • Improving the overall user experience.
• Other Legal Grounds: As otherwise permitted by relevant laws.

When we process personal information based on legitimate interests, we implement robust safeguards to protect your privacy.

3. How and When We Share Your Information

We may share your personal information in the following circumstances:

• With Advertisers and Measurement Partners: To demonstrate how many App users have interacted with advertisements.
• During Business Transfers: With potential transaction partners, service providers, advisors, and other third parties in connection with a corporate transaction (e.g., acquisition, merger, sale of assets). If such a transfer occurs, we will make reasonable efforts to ensure the receiving entity uses your information in a manner consistent with this Policy.
• With Other SHAREgo Users: To enable the sharing functionalities central to the App. For example, if you choose to share content, certain information (like your username or profile picture) may be visible to the recipients.

4. International Data Transfers

Your personal information will be stored in Singapore.

Where permitted by applicable laws, your personal information may be transferred to and processed in countries outside your jurisdiction. If you are an EU or UK-based user, this could include countries not deemed to provide an adequate level of data protection under EU or UK law.

We have implemented appropriate safeguards (such as standard contractual clauses) in line with legal requirements to ensure adequate protection for your personal information during international transfers. For more details on these safeguards and to obtain a copy, please contact us using the information below.

5. Data Security and Retention

We employ technical and organizational measures designed to provide a level of security appropriate to the risks associated with the personal information we process. These measures are regularly evaluated to maintain the integrity and confidentiality of your data.

We retain your personal information for the duration of our relationship with you. After our relationship ends, we keep your information for as long as required by law. We may also retain records to investigate or defend against potential legal claims, address complaints or official inquiries, or for business analysis and auditing purposes.

6. Your Data Rights

Subject to local law, you have certain rights concerning the personal information we hold about you. These rights may include:

• Access: Request a copy of your data and information about how it's processed.
• Rectification: Request corrections to any inaccuracies in your data.
• Erasure: Request that we delete your data from our records.
• Restriction: Request that we limit the processing of your data as specified in this Policy.
• Object: Object to certain ways we process your data.
• Portability: Request that your data be shared with a third party.
• Withdraw Consent: If we rely on your consent for processing, you can withdraw it at any time.

We encourage you to contact us to update or correct your information if it changes or if your personal data with us is inaccurate. Please note that we may require additional information to fulfill your requests.

To discuss or exercise any rights you may have under law, please contact us using the details provided below.

7. Children's Privacy

The Services are not intended for children. We do not knowingly collect personal information from children under the age of 13 (or the legal age of consent in your jurisdiction to use a mobile application) or knowingly allow such individuals to register for our Services. If we are informed that we have collected personal information from a child under 13 (or the legal age of consent) without parental consent, we will suspend the account and delete the relevant information as quickly as possible. If you believe we might have any information from a child under 13 (or the legal age of consent), please contact us using the details below.

8. Contact Us

We are the data controller responsible for the personal information collected and processed by our Services. If you have questions or concerns about how your personal information has been used, or wish to exercise any of your rights, please contact us at: [[email protected]]

We are committed to working with you to resolve any privacy-related complaints or concerns fairly. However, if you believe we have not been able to assist you, you may have the right to lodge a complaint with the data protection authority in your country of residence.

9. Changes to This Policy

You may request a copy of this Policy from us using the contact details above. We may update or modify this Policy periodically.

If we make significant changes to this Policy, we will notify you. Where changes will fundamentally impact the nature of data processing or have a substantial effect on you, we will provide sufficient advance notice, giving you the opportunity to exercise your rights (e.g., to object to processing) or to terminate your use of the Services.