1. INTRODUCTION

Kiqro INC. ("Kiqro", "we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Notice explains how we collect, use, and disclose personal information in connection with your use of our platform and mobile applications.

Kiqro INC. is a Delaware corporation with its registered office at 407 E Ayre St #1489 Wilmington, DE 19804, USA.

2. NOTICE AT COLLECTION: CATEGORIES OF PERSONAL INFORMATION COLLECTED

Within the last twelve (12) months, we have collected (and will continue to collect) the following categories of personal information from users:

Identifiers

• Specific Examples Collected: Real name, IP address, email address, account name, and mobile device identifiers (IDFA/GAID).

• Sources: Directly from you; Automated tracking via SDKs.

Biometric Information

• Specific Examples Collected: Facial geometry, selfies, and images processed for identity verification via Didit. Verifications completed before July 2026 were processed by Veriff.

• Sources: Directly from you (via identity verification process).

Internet / Electronic Activity

• Sources: Automated tracking via SDKs and Cookies.

Commercial Information

• Specific Examples Collected: Kiqro Points (KP) balance, earning history, task completion records, and redemption history.

• Sources: Generated through platform usage.

Geolocation Data

• Specific Examples Collected: Precise physical location (GPS and IP-based) to prevent fraud.

• Sources: Automated via mobile app and browser.

3. SOURCES OF PERSONAL INFORMATION

We collect personal information from the following sources:

• Directly from You: When you register, complete tasks, or request a redemption of KP.

• Automated Technologies: Via cookies, web beacons, and SDKs (including Adjust and AppsFlyer).

• Third Parties: From our offerwall partners, survey providers, and risk management services like MaxMind.

4. PURPOSES FOR PROCESSING PERSONAL INFORMATION

We use your information for the following business and commercial purposes:

• Attribution and Rewards: Tracking app installs and task completions to credit Kiqro Points (KP) to your balance via our MMPs (Adjust).

• Fraud Prevention & Security: Using MaxMind, Didit, and Veriff to detect emulators, VPNs, and multiple accounts attempting to exploit KP rewards.

• Redemption Fulfillment: Processing the exchange of KP for rewards via Tremendous.

• Platform Improvement: Analyzing usage data via Google Analytics and Facebook Pixel.

• Legal Compliance: Complying with tax obligations (IRS) and anti-money laundering (AML) laws.

Legal Bases for Processing (EEA, UK, and Türkiye)

Where data protection law requires us to identify a legal basis for each purpose, we rely on the following:

• Performance of a contract: Creating and operating your account, crediting KP, and fulfilling redemption requests.

• Legitimate interests: Fraud prevention, platform security, and product improvement, balanced against your rights and freedoms.

• Legal obligation: Tax, anti-money laundering, and record-keeping requirements.

• Explicit consent: Biometric data (facial geometry, selfies, and liveness images) processed during identity verification is a special category of personal data. We process it on the basis of your explicit consent, which is requested before the verification session begins. You may withdraw that consent at any time by emailing contact@kiqro.com. Withdrawal does not affect processing carried out before it, and because identity verification is a condition of redeeming CG, we may be unable to process redemptions without it.

5. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We share your information with the following service providers and third parties:

• Offerwall & Advertising Partners:Ayet Studios, Torox, AdscendMedia, Monlix, Lootably, TimeWall, AppSamurai, CashyGo and Klink.

• Survey & Market Research Partners: CPX Research.

• Measurement & Attribution (MMPs): Google Analytics and Firebase Analytics.

• Security & Identity: MaxMind (Fraud scoring), Didit (Identity verification — see Didit's Privacy Policy), and Veriff (Identity verification, used for verifications completed before July 2026).

• Financial Services: Tremendous and Xoxoday Plum (Reward fulfillment).

• Communications: OneSignal (push notifications) and SendGrid (email delivery).

• Analytics & Advertising Measurement: Google Analytics, Google Ads, and Meta (Facebook) Conversions API.

• AI Support Assistant: Anthropic process the messages you send to our in-app assistant, together with the account details needed to answer them. Please do not enter identity or payment document numbers into the assistant.

• Cloud Infrastructure: Hetzner Online GmbH.

6. SELLING AND SHARING OF PERSONAL INFORMATION

Kiqro INC. does not sell personal information for monetary payment. However, sharing identifiers with advertising partners to attribute KP rewards for "cross-context behavioral advertising" may be considered "sharing" under California law. You have the right to opt-out of this by contacting contact@kiqro.com.

7. NOTICE OF FINANCIAL INCENTIVE

We offer Kiqro Points (KP) as an incentive for completing tasks. This includes a one-time Welcome Bonus and various task rewards. The amount of the Welcome Bonus and of individual task rewards is shown in the app and may change from time to time.

• Data Value: The value of the personal information we collect is reasonably related to the value of the KP rewards provided.

• Participation: Participation is voluntary. You may withdraw at any time by deleting your account.

8. DATA RETENTION

We retain personal data, including KP transaction history and identity records, for as long as your account is active. Financial and Identity records (including data processed by Didit and Veriff) are retained for 5 to 7 years to satisfy legal, tax, and regulatory requirements. Biometric data collected during identity verification is retained by our verification provider only for as long as is necessary for the purposes described in this Notice, and never longer than applicable biometric privacy law allows where that law prescribes a shorter period. You may request deletion of your biometric data at any time by emailing contact@kiqro.com.

9. YOUR RIGHTS (CCPA / GDPR / KVKK)

Depending on your jurisdiction, you have the right to request access, deletion, or correction of your personal information. You may also opt-out of the "sharing" of your data. To exercise these rights, please email contact@kiqro.com.

10. CHILDREN'S PRIVACY

Our services are not intended for anyone under 18 years of age. You must be at least 18 to register an account, as set out in our Terms and Conditions. We do not knowingly collect personal information from anyone under 18; if we learn that we have, we delete it and close the account.

11. CONTACT INFORMATION

Kiqro INC. 407 E Ayre St #1489 Wilmington, DE 19804, USA

Email: contact@kiqro.com

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