PRIVACY POLICY

This Privacy Notice for Willma development ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (WILLMA), or any other application of ours that links to this Privacy Notice.
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at Info@willma.life.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some information may be considered "special" or "sensitive," such as your health data. We may process sensitive personal information when necessary with your consent or as permitted by law.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes in place to protect your personal information. However, no electronic transmission or storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on your geographical location, you may have certain rights regarding your personal information.

How do you exercise your rights? The easiest way is by submitting a data subject access request or by contacting us.

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
12. DISPUTE RESOLUTION AND GOVERNING LAW
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
16. NUTRITION DATA SOURCES & METHODOLOGY
17. REFUND POLICY & CUSTOMER SUPPORT

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us.

Personal Information Provided by You: This includes names, phone numbers, email addresses, and passwords.

Sensitive Information: With your consent, we process health data.

Application Data:

Geolocation Information: We may request access to or permission to track location-based information from your mobile device to provide certain location-based services. You may change our access or permissions in your device's settings.

Mobile Device Data: We automatically collect device ID, model, manufacturer, operating system, IP address, and other device information.

Push Notifications: We may request to send you push notifications regarding your account or certain features of the application. You may turn these off in your device's settings.

All personal information must be true, complete, and accurate. You must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to:

• Facilitate account creation and authentication and otherwise manage user accounts.

• Save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

We process your information based on valid legal reasons.

For EU or UK Residents (GDPR):

Consent: You have given us permission. You can withdraw consent at any time.

Legal Obligations: To comply with the law or cooperate with law enforcement.

Vital Interests: To protect someone's safety.

For Canadian Residents:

Express or Implied Consent: You have given us specific or inferred permission. You can withdraw consent at any time.

Exceptions may include investigations, fraud prevention, business transactions, witness statements, and publicly available information as specified by law.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your information in the following situations:

Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Offer Wall: Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Yes, we may use cookies and similar tracking technologies (like web beacons and pixels) to collect and store your information for security, preferences, analytics, and advertising. Third parties may also use these technologies on our Services. You can opt out as described in the section on US resident privacy rights.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information only as long as necessary for the purposes outlined in this notice, or as required by law (e.g., for tax or accounting). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us. Afterward, we will delete or anonymize it.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We use appropriate and reasonable technical and organizational security measures to protect your data. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Transmission of your personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your region (e.g., EEA, UK, Switzerland, Canada), you may have the right to:

• Request access to and a copy of your personal information.

• Request correction or erasure.

• Restrict the processing of your data.

• Data portability.

• Object to processing and automated decision-making.

You can withdraw your consent at any time by contacting us. To review, change, or terminate your account, you can log in to your account settings and update your user account.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT signals.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of certain states (e.g., California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia), you have rights regarding your personal information, including the right to know, access, correct, delete, and obtain a copy of your data.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future. You have the right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data.

California's "Shine The Light" Law: California Civil Code Section 1798.83 permits California residents to request, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes.

To exercise your rights, you can contact us by submitting a data subject access request, by emailing us, or by using the contact details at the bottom of this document. We will need to verify your identity before processing your request.

11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

Republic of South Africa: You have the right to request access to or correction of your personal information. You can contact the office of the Information Regulator (South Africa) if you are unsatisfied with how we handle any complaint.

General enquiries: enquiries@inforegulator.org.za

Complaints: PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

12. DISPUTE RESOLUTION AND GOVERNING LAW

This Privacy Notice and your use of the Services are governed by and construed in accordance with the laws of the Arab Republic of Egypt, without regard to its conflict of law principles. Any dispute, claim, or controversy arising out of or relating to this Privacy Notice or the breach, termination, enforcement, interpretation, or validity thereof, shall be determined by the competent courts of Cairo, Egypt.

13. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The "Last updated" date at the top of this Privacy Notice will indicate the latest version. If we make material changes, we may notify you by posting a notice of such changes or by directly sending you a notification.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

You can email us at developer@willma.life or contact us by post at:

Willma development
5th settlement, new Cairo, Egypt
New Cairo, Cairo
Egypt

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

16. NUTRITION DATA SOURCES & METHODOLOGY

Data Sources: Willma's macro- and micro-nutrient values come exclusively from established public food-composition databases. A machine-readable file with every item-level URL is refreshed monthly and hosted at https://nutrition-data-sources.willma.life