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Last updated: October 8th, 2021

1. INTRODUCTION

Motimate AS (“Motimate“) are committed to protecting your information and being transparent about
how we process information that identifies or can be used to identify an individual directly or indirectly
(“Personal Information“). This privacy policy (the “Privacy Policy“) describes how we process your
Personal Information when you use our applications Motimate Pulse and/or Motimate Training ( the
Applications”).

The Applications are services for internal communication and training of employees within
organizations. When using our Applications, our when we otherwise collect and process Personal
Information on behalf of our users, Motimate acts as a data processor for your Personal Information.

2. PERSONAL INFORMATION WE PROCESS

The Personal Information we process depends on the context of your interactions with Motimate and
the Applications, your account settings and applicable law. However, the Personal Information we
process broadly falls into the following three categories:

1) Personal Information obtained from your organization: When onboarding users onto
the Applications, we ask your affiliated organization to provide us with some information
about you. This is generally only applicable when you are employed within the organization.

Such information include:

  • Your name, phone number, employee ID and email address; and
  • Information about your employment, such as your role in the applicable organization.

2) Information you provide to us: You may provide certain Personal Information to us when
you use the Applications, consult with our customer service team, send us an email or when
you interact with our website.

Such information may include:

  • If not obtained from your organization, contact details such as your name, e-mail address and telephone number;
  • Account log-in credentials such as your e-mail address or username and password when you sign up for an account with us;
  • Troubleshooting and support data, which is data you provide or we otherwise collect in connection with support queries we receive from you.
  • Communication data. Certain features of our Applications let you share information with other people, and you have control over what you share and with whom you share. For example, when signed in and using the Applications, you may disclose Personal Information to us and other users of the Applications through, for example, comments. We strongly advise that you limit the disclosure of Personal Information through, for example, comment sections within the Applications and our website.

3) Information we collect automatically: In some, but not all, countries, including countries
within the EEA, the following information is considered Personal Information under applicable
data protection laws.

  • Browser or device information which is collected through your device, such as operating system, screen resolution, device manufacturer and model and the version of the Applications you are using.
  • Usage data which is collected whenever you interact with our Applications. This may include the dates and times you access the Applications and your browsing activities (such as what portions of the Applications you used). We also collect information regarding the performance of the Applications and information on how often you use the Applications. This information allows us to improve the functionality of the Applications.
  • Log data whereby our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP-addresses and your activity in the Applications (such as the date/time stamps associated with your usage, pages and files viewed). We may also access metadata and other information associated with the files you upload into our Applications.
  • Cookies which allow us to collect information such as browser type and other anonymous traffic data. Please see our Cookie Notice for more information on our use of cookies.
  • Pixel tags (also known as web beacons and clear GIFs) may be used on our website in order to, among others, track the actions of our users, measure the success of marketing campaigns and compile statistics about usage of the Applications and response rates.

3. USE OF PERSONAL INFORMATION

We may use your Personal Information we collect for the following purposes and legal bases:

  • Providing the Applications: This means using your Personal Information in order to provide the Applications’ functionality to you, such as arranging access to an account, responding to your inquiries, and to allow you to utilize our various Application features. We engage in these activities in order to manage our contractual relationship with you.
  • Enable you to use certain features. We may automatically process your Personal Information, in reliance of our legitimate interest, in order to enable you to use certain features of our Applications, for example when you comment on a post or join a group. If you want to remove your Personal Information in such cases, you can normally do this yourself through your account.
  • Communicate with you: We may use your Personal Information to communicate with you about your account and provide you with costumer support in order to perform our contractual duty in relation to your use of the Application. For example, we may ask you if you want to receive push notifications about activity on your account. If you have opted in for such push notifications and no longer wish to receive them, you may turn them off through your operating systems. We may also send you system alert messages in reliance on our legitimate interests in administering the Applications. For example, we may inform you about temporary or permanent changes to our Applications, such as planned outages, security or compliance notifications, information about new features, version updates, releases, abuse warnings and changes to the Privacy Policy.
  • Support and improve the Application. Your Personal Information may be used to provide, support and improve the Applications in order to perform our contract with your affiliated organization for the use of the Applications.
  • Prevent abuse and misuse of the Applications. In order to protect against misuse or abuse of our Applications, protect the rights of our users, ensure compliance with our terms and conditions and applicable law, and pursue available remedies, we may use your Personal Information as is reasonably necessary.
  • Comply with legal obligations. We may use your Personal Information in order to comply with requests by public authorities, court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms. This includes Personal Information necessary to provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests, and Personal Information necessary to prosecute and defend a court, arbitration, or similar legal proceeding.
  • Data analytics: We may use your Personal Information in order to analyse how the applications are used in reliance on our legitimate interest in improving the Applications.
  • Aggregated and anonymised data. User’s Personal Information may be used to combine and anonymize data about our users and our users’ use of the Applications in order to create aggregated, anonymized statistics which we may use to provide certain features within the Application and improving the Applications in reliance on our legitimate interests.

We do not sell Personal Information and we do not share Personal Information with third parties for
marketing purposes.

4. YOUR DATA PROTECTION RIGHTS

Know your rights
If you are an EEA/EU citizen, you have the following data protection rights:

  • The right to access, correct, update, delete, restrict or object to our processing of your Personal Information;
  • If Personal Information processed based on your consent, or if you have, for example, consented to receiving marketing emails from Motimate, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent;
  • The right to lodge a complaint regarding our processing of your Personal Information with your applicable data protection authority. Please contact your local data protection authority for more information. Contact details for data protection authorities within the EEA and the UK are available here and Switzerland are available here. Contact details for the Norwegian data protection authority is available here.

Please note that the above rights may be subject to exceptions and limitations. We cannot, for
example, provide Personal Information if it would violate our duty of confidentiality or we have a legal
obligation to retain such data. Motimate will respond to your request to exercise your data protection
rights consistent with applicable law.

Exercise your rights

You can manage your individual account and profile settings through your Motimate account, including
contact information, preferences or you can always contact us directly by emailing us at
support@motimateapp.com. Motimate takes reasonable steps to ensure that the data we collect is
reliable for its intended use, accurate, complete and up to date.

We respond to all requests we receive from individuals wishing to exercise their data protection rights
in accordance with applicable data protection law. We may ask you to verify your identity in order to
help us respond efficiently to your request.

5. SHARING YOU PERSONAL INFORMATION

We do not share your Personal Information with third parties, except in the following circumstances:

  • Affiliates. We may share and disclose your Personal Information with the companies in the Kahoot Group based on our legitimate business interest or to provide services that may include one or more of our group companies.
  • Service Providers. We may share Personal Information with our trusted service providers who perform services on our behalf, such as hosting services, strictly for the purpose of carrying out work on our behalf as described in this Privacy Policy. For example, companies we’ve hired to help us provide and support our Applications or assist in protecting and securing our systems and services and other business-related functions.
  • If Motimate is involved in a sale, merger, liquidation or acquisition, we may disclose your Personal Information. You will be provided with a notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.
  • Public institution(s). We may disclose your Personal Information to third parties if required by law, or if we believe that such disclosure is necessary in order to comply with the applicable law or regulation. We may also disclose your Personal Information at the request of law enforcement, or to protect the security and integrity of our Applications or those of any other person.
  • Any other person with your consent.
  • We may also share anonymized and/or aggregated information with selected third parties for statistical purpose.

We are responsible for the data privacy of the service providers we may share Personal Information
with. Motimate only uses service providers that have data protection and security standards consistent
with our own. Our service providers are not permitted to use Personal Information they process on our
behalf for any other purposes than as needed to carry out their work for us. We enter into written
agreements with all of our services providers restricting the use of Personal Information and imposing
the same level of privacy, confidentiality and information security that apply to Motimate.

6. INTERNATIONAL TRANSFERS

We do not transfer any Personal Information to countries located outside the EU/EEA.

7. HOW LONG WE STORE YOUR INFORMATION

We do not retain Personal Information longer than necessary for the purposes for which Personal
Information was collected. We retain Personal Information where we have an ongoing legitimate
interest or legal obligation to do so.

Our retention periods vary depending on the type of data involved, but, generally, we refer to the
following criteria in order to determine retention period:

  • Whether we have a legal or contractual need to retain the data;
  • Whether the data is necessary to provider our Applications;
  • Whether our users have the ability to access and delete the data within their Motimate accounts; and
  • Whether our users would reasonable expect that we would retain the data until they remove it or until their Motimate accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, it will be
deleted or anonymized as soon as possible and in accordance with applicable law.

8. HOW WE PROTECT YOUR INFORMATION

Motimate strive to protect the privacy and confidentiality of your Personal Information. Therefore, we
adopted proper technical and organizational measures designed to protect the Personal Information
we process. By way of example, we limit access to the information to authorized employees and
contractors who need such access to operate, develop or improve our Applications.

9. CHANGES TO THE PRIVACY POLICY

We may update our Privacy Policy in order to keep it up to date and accurate. We will provide you with
prior notice if any material changes to this Privacy Policy were to occur.

Please review this Privacy Policy periodically for any changes.

10. HOW YOU MAY CONTACT US

If you have any inquiries, complaints or questions regarding how we process your information, or have
questions about our practices, please contact us at: support@motimateapp.com

You can also make a complaint with the relevant supervisory authority if you believe our processing of
your Personal Information infringes applicable law. Contact details for the Norwegian DPA
(Datatilsynet) can be found at: https://www.datatilsynet.no/om-datatilsynet/kontakt-oss/. Contact details for all EU data protection authorities can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

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