Privacy and Cookies Policy

1. Who We Are

Our Services are owned and operated by EveryGuest (hereinafter, "EveryGuest"). Unless otherwise stated, we are the data controllers for the personal data we collect through the WebApp and related services. By using our platform on any device, you agree to the practices described in this policy.

2. The Service

We operate a technological platform that allows users to:

• Generate and share visual content (UGC) at partner venues.
• Participate in loyalty programs and earn rewards through AI validation.
• Interact with personalized promotions from hotels and restaurants.

3. Information We Collect

To provide our services, we collect information that allows us to identify you (such as your name or email) and information about your activity (such as the photos you upload or your location when scanning a QR at a venue).

4. Information Collected

When you access or use our Services, we collect and process information to provide a personalized experience. Some information is collected passively (cookies) and some actively when you interact with the WebApp.

The information collected includes:

4.1. Use of Location and Fraud Prevention

We collect your location to show you nearby Venues and, fundamentally, to detect fraudulent activity. Validating a Reward depends on you being physically present at the location. If you disable geolocation on your device, you may not be able to complete Interactions or earn prizes.

4.2. Image Processing via Artificial Intelligence

By uploading photos or videos, you authorize EveryGuest to process such content using Artificial Intelligence algorithms. This processing is solely for the purpose of:

1. Validating that the content meets the quality and thematic requirements of the Venue.
2. Detecting inappropriate or fraudulent content.
3. Categorizing content to improve service recommendations.

4.3. Third-Party Information and Location

Information about others: If you include other people in the photos or videos you upload to the Platform, you declare that you have obtained their prior consent to share their image and ensure they have understood how we will process their personal information according to this Statement.

Use of Location and Geolocation: We collect location information if your Device is configured to send it or if you upload photos tagged with location data (metadata).

• Purpose: We use this information to show you nearby Venues, analyze the use of our Services, and, fundamentally, validate your Interactions for the delivery of Rewards.
• Fraud Prevention: With your permission, we process location data to detect fraudulent activities and protect the integrity of your account. This data is kept only as long as necessary to validate the visit to the venue.
• User Control: You can disable geolocation in your Device's privacy settings at any time. Please note that disabling this feature will prevent the validation of your interactions and, therefore, the earning of prizes.

5. Uses of Information

We are committed to providing you with relevant content and respect the privacy laws of the jurisdictions in which we operate. We use your information for the following purposes:

5.1. Account and Service Management

• Register and manage your User account to allow access to the WebApp.
• Rewards Program: Manage the accumulation and redemption of your Rewards.
• Benefit Processing: Facilitate the delivery of products or discounts at partner Venues.
• Conduct promotional programs, contests, or challenges within the platform.

5.2. Validation and Improvement via Artificial Intelligence

• Content Analysis: Use AI algorithms to validate that the photos and videos you upload meet the quality and thematic requirements necessary to earn a Reward.
• Fraud Detection: Analyze activity patterns and real-time geolocation data to prevent the use of duplicate accounts or fake content.
• Optimization: Group users based on their interests and App usage to improve Venue recommendations.

5.3. Communication and Personalization

• Notifications: Inform you about the status of your validations, new available Rewards, or services from our partners that may interest you.
• Tailored Experience: Adapt your experience by making inferences about your tastes based on the content you generate and the places you visit.
• Support: Respond to your inquiries and record interactions with our team to improve service quality.

5.4. Legal Compliance and Security

• Prevent illegal or prohibited activities as per our terms of use.
• Comply with current laws, respond to legal requirements, and protect our rights.
• Resolve disputes or technical issues arising during the use of the Services.

Note on automated decision-making: At EveryGuest, we use automated processes to validate if a photo entitles you to a prize. If you believe a validation has been unfairly rejected by our AI, you have the right to request human intervention to review your case by emailing our support team.

6. Information Sharing

In order to provide some of our Services and processing activities, we use service providers and may need to share information with these providers and certain other third parties under the following circumstances:

• Partner Venues (Hotels, Restaurants, and Other Venues). We may share your information with our partners to allow them to manage the delivery of your Rewards and to handle claims or disputes related to them. For the purposes of validating and monitoring Interactions, we and the Venues are joint controllers of the personal data processed.
• Other Users. Within the social features of the EveryGuest Platform, certain information will be visible to others. Specifically, your name, profile picture, and the content (photos/videos) you publish may be displayed to other users.
• Vendors. We may share information with certain vendors used to facilitate our Services, including data hosting services, Artificial Intelligence analysis for content validation, and payment or credit service providers.
• Business Partners. We may share information about you, your Devices, and your use of our Services with trusted business partners to provide you with relevant content or facilitate sponsored promotions.
• Social Media. When you use our Services and choose to share information with third-party social media websites, the information will be governed by those sites' privacy policies.
• Advertising Networks. We sometimes collect and share information about your interests with advertising networks and data aggregators.
• Fraud Detection Companies. Third parties may assist us by providing their fraud detection technologies, particularly regarding the verification of location and the authenticity of visual content.
• Other Third Parties and Referral Sites. Third parties may assist us in collecting information by operating features on our site or facilitating tailored advertising.
• Cookies. If you consent to the installation of cookies, your data may be processed by third-party companies for the purposes mentioned in the Cookies section.

We may also share your information if we believe, at our sole discretion, that such disclosure is necessary:

• To comply with legitimate subpoenas, court orders, or legal processes; to exercise our legal rights or defend against legal claims.
• To investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect the security of EveryGuest, our customers, or others.
• In connection with a corporate transaction, such as a merger, asset sale, or, in the unlikely event of bankruptcy.

7. Information Choices

You have choices regarding the collection and use of your information. You can access, update, and even close your account by visiting the "Profile Settings" or "My Data" page within our WebApp.

Additionally, you can:

• Manage communications: Choose how we communicate with you and what types of notifications you wish to receive.
• Limit information provided: Choose not to provide certain information, although it may be necessary to take advantage of specific features.
• Control geolocation: Prevent the collection of location data by disabling location services in your device settings.
• Close your account: You may close your account directly from the app. If you close your account, we will deactivate it and remove your profile information from active view. Note on retention: EveryGuest may retain some information associated with your account for internal purposes such as backups, fraud prevention, dispute resolution, our own legitimate business interests, and legal compliance.
• Modify marketing subscriptions: As a registered user, you can modify your marketing preferences at any time within your account settings.
• Unsubscribe from promotional messages: You can opt out of promotional emails through the link provided in any promotional email we send.

8. Information Concerning Minors

Our Services are not intended for minors. For the purposes of these Terms, a minor is defined as: (i) any person under the age of 18 (or the age of legal majority in their jurisdiction) for the purpose of entering into a binding contract and participating in the Rewards Program; or (ii) any person under the age of 13-16 (depending on the jurisdiction) regarding the consent for data processing.

EveryGuest does not knowingly collect or process data from minors. If we become aware that we have processed information from a minor without the required legal basis, we will proceed with the immediate deletion of the account and all associated data.

9. Information Transfers

EveryGuest provides its Services globally. By using our platform, your information may be transferred to and stored on servers located outside your country of residence. In such cases, we implement standard contractual clauses approved by the European Commission (or equivalent mechanisms) to ensure your data receives the same level of protection as described in this Statement.

10. Information Security

We have implemented appropriate administrative, technical, and physical security procedures to protect your information:

• Restricted Access: Only authorized personnel can access personal data and only for permitted business functions.
• Encryption: We use encryption protocols (SSL/TLS) to securely transmit your information and User Content between your device and our servers.
• Perimeter Protection: We employ firewalls and intrusion detection systems.
• Limitation: While we strive to apply best practices, we cannot guarantee absolute security against hardware failures, sophisticated external attacks, or circumstances beyond our control.

11. Information Retention and Deletion

We will retain copies of your personal information and generated User Content (photos and videos) for as long as you maintain your account or as necessary in connection with the purposes set out in this Statement, unless a longer retention period is required by applicable law.

Additionally, we may retain certain information after your account is closed for as long as necessary to:

• Establish, exercise, or defend any legal rights or claims.
• Maintain historical records of redeemed Rewards for audits with partner Venues.
• Prevent fraud and ensure that "one-time use" promotions are respected.

12. Cookies and Tracking Technologies

At EveryGuest, we use cookies and similar technologies (collectively referred to as "cookies" in this policy) to improve your experience, enhance security, show you relevant content, and perform analytics to improve our products.

We inform you about our use of cookies when you first visit our WebApp through a notification banner. You can change your settings and decide whether to accept them or not at any time through our cookie consent tool.

What are cookies and similar technologies?

• Cookies: Small text files automatically placed on your computer or mobile device. They allow the WebApp to recognize your device and remember basic information about your usage and preferences, but they do not identify you personally in a direct way.
• Session vs. Persistent Cookies: Session cookies are deleted when you close your browser. Persistent cookies remain on your device so that when you reopen the App, you don't have to enter your login details again.
• Other Technologies: We also use pixels, server logs, and SDKs, which perform similar functions and are essential for the proper functioning of mobile and web applications.

13. What Types of Cookies Do We Use?

Managing Cookie Settings

• Consent Tool: You can change your choice at any time using the "Change cookie settings" button above.
• Browser Settings: In addition to our tool, you can manage cookies through your internet browser settings (Chrome, Safari, Firefox, etc.).
• Withdrawal of Consent: You have the right to withdraw your consent for the use of non-essential cookies at any time.

Within the EveryGuest WebApp, you can manage these options in your profile under the "Privacy and Security" section. Please note that if you reject or disable certain cookies (especially essential ones), your access to some features may be limited or restricted.

14. Changes to the Privacy and Cookies Statement

We may update this Statement in the future. If we consider any change to be material, we will let you know through one or more of the following actions: sending you a communication regarding the changes, placing a prominent notice on the WebApp, or publishing the updated Statement with the new effective date. At the top of this Statement, we will always indicate when it was last updated.

Contact Us

If you have a data privacy request (such as a request to access, rectify, or delete your data), you can manage this directly from your profile or contact our support team at: info@everyguest.co.