Summary of Weople Service Terms and Conditions

Weople is a service offered by Hoda that provides you with an APP platform to achieve the following results:

  1. Weople helps you exercise one of the most important rights granted by the GDPR (General Data Protection Regulation 679/2016), namely the right to data portability, and is committed to safeguarding and protecting your data, always in anonymous form and with the highest guarantee for your privacy.
  2. Weople is committed to helping you recover the maximum possible value from your data through investment and enhancement methods that respect your privacy, without ever transferring your personal data to third parties, and recognizing you up to 25% of the revenue generated from the sale of advertising and e-commerce spaces within the Weople app. This will be constantly communicated on a transparency page in the App.
  3. After creating your profile, you can deposit and invest in Weople all the data you wish to include in your data account by activating, with your free choice and without any obligation imposed by the App, the safes available and explained in your personal vault. As you will see, these are consumption data from your loyalty cards, usage data from digital channels such as Social Media, Google, Amazon, etc., your interests, and your self-description. Weople does not collect any other data about you beyond what is indicated here and what you freely decide to invest.

To achieve the indicated objectives, you, if you wish, can decide to:

  1. independently import your data, also using the direct functions provided by Weople.
  2. in cases where there are no direct import functions, authorize Weople to represent you in exercising your right to data portability by granting a specific delegation in our favor. You can always request updates on the activities carried out or revoke this delegation.
  3. allow us to perform profiling operations on the data you have deposited in your Weople data account to send you personalized communications and commercial offers in the Gain&Relax section of the App, which is the main way Weople creates and shares value with you. Profiling activities will always and only generate aggregated statistical data, i.e., groups of unidentified or unidentifiable people who share characteristics statistically and probabilistically. Weople will speak with potentially interested companies about sending these commercial offers to convince them, based on aggregated data, to buy communication spaces and to direct personalized communications and offers to statistical groups, of the type just described, in which you may also be included. The offers will only be sent by Weople, and as mentioned, the data you invest will always be processed in anonymous and aggregated form and will never be transferred or indicated at an individual/personal level to any of these companies. This method of data investment will allow you to earn and receive a portion of the sums paid by advertisers. Earnings will be deposited by Weople directly into your piggy bank in the app and can take the form of spendable values in various circuits, such as points, tokens, Amazon vouchers, or other e-commerce vouchers, etc.
  4. allow us to process your data together with others and generate general statistical models, therefore not referable to you personally. The models will then be used to enrich third-party databases always, with respect to you, in a completely neutral, anonymous, protected form, guaranteed by Weople, and without transferring your data at an individual/personal level to third parties. This will allow you to participate in the generation of further value, in which you will always share because the improvement of the models, through the growth of know-how, will improve Weople's growth opportunities and its commercial proposition.
  5. The general statistical models may also allow Hoda to produce further benefits for you, this time expressed in terms of data-driven personal services. By way of non-exhaustive examples, with a significant number of app users who have downloaded Amazon archives and purchase data from other sources, Hoda could produce price comparators or spending pattern analyses that could suggest ways to optimize spending. Furthermore, users may wish to use their archives to train a Personal Artificial Intelligence Agent not oriented by the business logic of large companies but genuinely protective of the individual user.
  6. Finally, Hoda will work, in compliance with the law, to protect, for everyone, the right to portability established by the GDPR and to take other initiatives to protect and develop the conscious and active participation of people in the Data Economy.

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General Terms and Conditions for the Use of Weople

Preamble

This Contract must be interpreted in light of the following principles.

Ethics Your personal data has value, also economic. We believe this value belongs to you, not just to some distant and barely controllable entity. Weople adopts a system that allows you to retrieve the maximum possible value from your data, in a simple and intuitive way.

Control over data and security We believe it is up to you to decide which and how much data to invest. For this reason, Weople offers scalable settings that allow you to define your investment profile. All data is processed in compliance with the most rigorous technical and organizational security standards.

Fairness Hoda operates inspired by principles of fairness, social sustainability, and sharing economy: the company always operates in such a way that the proceeds from activities supporting communication and e-commerce are shared with users. These, in fact, can receive up to 25% of the revenue generated from the sale of advertising and e-commerce spaces according to the development model described on the redistribution agreement page.

Transparency The Weople account is free for the user, but not for Hoda. The user, if they wish, invests their data, and Hoda bears the costs related to maintaining the service, both technically and commercially. To demonstrate the seriousness of our intentions, we have decided to adopt an approach that allows you to know the main aspects related to the management of the Company. In other words, details regarding revenues, costs, prizes, and money distributed through Weople will always be consultable on the website weople.space and on the transparency page of the application.

Section I: Description of Weople, Object of the Contract, and Registration

Art. 1 – Description of the Service Offered Through Weople

The Weople service is designed to allow each User to acquire, deposit, and invest their personal data in a controlled and protected manner ("Service").

The data investment operations we propose involve different remuneration systems according to the methods indicated in this document.

Art. 2 – Object of the Service

This agreement ("Contract") governs the relationship between you ("User") and Hoda S.r.l. ("Provider"), in relation to the use of the Service offered through the technical platform called Weople ("Weople" or "Application"). The Service includes the functionality of investing personal data ("Main Service") and other accessory functionalities as per Section III of this document ("Accessory Services").

The Service is offered without any economic burden on the User, also thanks to the existence of any association agreements, capital participation, and sponsorship with companies interested in supporting the initiative ("Partners", the first two, and "Sponsors" the latter).

Art. 3 – Registration and Account Creation

To use Weople, we ask you to register and (1) provide the requested information accurately, truthfully, and correctly, (2) confirm your registration intention by entering the verification code you received via SMS, and (3) keep your information updated if it changes during the use of the Application. At the end of the registration procedure, you will become the holder of a personal account on Weople ("Account").
We ask you to carefully protect the Account access details, passwords, and any other relevant elements for using the Service. If you encounter a security breach of your Account, we ask you to report it immediately by writing to support@weople.space.

Section II: The Main Service Offered by Weople

Art. 4 – Logic and Operation of the Main Service

The Main Service allows you to gain an economic advantage, and in terms of data-driven services or services connected to data, from the controlled and secure use of your personal data. This objective is pursued according to the following scheme:

  1. Weople provides you with a personal vault with various safes that you can "fill" with data relating to different areas of your digital life (social networks, purchase information from various e-commerce sites, loyalty cards, etc.);
  2. After registration, you can decide to provide your personal data by activating one or more safes;
  3. By activating the safe, you consent and authorize Hoda to process, cross-reference, and enrich the personal data you have deposited using statistical analysis tools and profiling algorithms. The profiles created (devoid of any identifying element) contain information relevant to interested companies ("Companies");
  4. Hoda offers Companies two types of services ("Investment Activities"): (a) preparation of advertising campaigns and commercial offers within the Gain&Relax area of Weople, and (b) statistical and probabilistic integration of Companies' databases with anonymized and aggregated information held by Weople;
  5. As a result of activity (a), Companies pay Hoda a fee (also based on results), a portion of which is returned to the User in the form of points, discounts, vouchers, etc.

Art. 5 – Creation of the Personal Account

The objective of Weople is to enhance the personal data deposited in the safes to redistribute to the User the proceeds from the Investment Activity. To use the services provided by Hoda, you must first create your account.

Art. 6 – Provision of Personal Data

The User can provide their personal data by activating one or more safes. The safes can be filled with data according to the following methods:

  1. Direct insertion of data. Data can be inserted directly by the User (for example, by filling out specific interest questionnaires, or according to other methods specified during the use of the Application).
  2. Insertion by transfer. If the data is held by third parties (e.g., social networks or large-scale distribution companies), the activation of the relevant safe can take place through the free initiation of the data portability procedure as per Art. 13 and 14 of these Terms and Conditions.

Art. 7 – Profiling

If you decide to activate a safe, you provide consent for the processing of your data, deposited in the safe itself, for their processing by Hoda to allow us to create anonymous and statistical profiles, for homogeneous aggregation classes, as indicated in the service's privacy policy.

The profiling activity is carried out through the study and use of variables, technical characterizations, multivariate statistics, and algorithms, possibly also artificial intelligence, which allow increasing the value of the deposited personal data and therefore the possible gain by the User.

Starting from personal data, these are de-identified—i.e., identifying data that allows associating other information with who you are is removed—then summarized by homogeneous classes or cohorts: essentially, we create profiles based on your information and consumption habits, but then we associate them with those of other people with similar or overlapping characteristics, to obtain a typical user model that no longer has the information of a single person, but the statistically most probable information of a group of people. This process allows us to create interesting models for companies, without providing them with personal data or profiles of unique individuals. We protect your privacy by creating a high-value product for companies. If you then wish to share your personal data with other subjects or companies, you will always be free to do so by providing specific consents or exercising your right to portability.

Therefore, Hoda does not directly market users' data but aggregates and processes it to obtain statistical samples that, while maintaining or increasing their commercial appeal to third parties, in any case guarantee anonymity and thus make it materially impossible for third-party recipients of these processes to carry out any profiling/filing operations on identified individual consumers/users to whom the data refers. The objective of the activity is to create statistical paradigms that are then made available to other organizations that may eventually use them, for their own strategies or marketing campaigns, including targeted communication and/or personalized e-commerce opportunities sent based on the statistical aggregates mentioned above, within Weople or on other apps/sites that use Hoda's tools.

To clarify, consider this example: a Weople client company wants to know if men between the ages of 25 and 30 are likely to buy at least two pairs of running shoes per year. The input values that Hoda processes would therefore be: "men", "age group". If Hoda's database contains the same characterizations, together with the number of running shoes purchased in a year, Hoda will evaluate in aggregate form —starting from known data (age, gender, number of running shoes purchased in a year)— and can generate a probabilistic value that the client can use for their purposes, which may include the development of theoretical marketing strategies and/or the sending of advertising communications and/or various e-commerce opportunities in Weople or on other platforms that use Hoda's tools.

The User will always be free to revoke consent to the creation of these profiles in relation to the content of the various safes and to permanently delete their data. Alternatively, instead of deletion, if they wish, the user can keep the deposited data, with the cessation of any activity on their data other than storage.

Only with your further and explicit consent can we profile you to offer you goods, services, or advertising in line with your interests.

Art. 8 – Data Investment

Following the profiling activity as described above, Hoda carries out commercial and offering activities in favor of Companies potentially interested in purchasing the following services:

  1. Creation of advertising campaigns targeted at Weople Users.
  2. Integration and enrichment of Companies' databases.

Art. 9 – Advertising Campaigns

Weople offers client Companies the possibility to convey advertising and other commercial offers to Weople Users ("Advertising Campaign"). The Advertising Campaign is carried out exclusively within the Gain&Relax area of the Application, and the related promotional messages are addressed to Users ("Recipients") based on the interests expressed or discretionarily appreciated by Hoda through profiling activities based on your consent as per the previous Art. 7.

Up to 25% of the revenue from Advertising Campaigns is redistributed to Recipients according to the rules provided for in the following Art. 11.

Art. 10 – Integration and Enrichment of Databases

The information contained in the safes, together with the knowledge and technologies present in Hoda, allows offering Companies a service of integration and enrichment of their databases.

The enrichment operations, carried out in anonymous, protected, statistical form and guaranteed by Weople, take place through the application of anonymous profiles and statistical analyses in aggregated form. Hoda will not disclose the User's identity to client Companies, Partners, and Sponsors, unless specifically requested by the User.

The proceeds from the enrichment activity are distributed among Users according to the rules provided for in the following Art. 11.

Art. 11 – Revenue

The implementation of the activities referred to in the previous Art. 9 and 10 is subject to remuneration by the Companies ("Revenue").

Recipients receive up to 25% of the revenue generated by Hoda from the sale of advertising spaces and e-commerce spaces in the Weople app. Earnings will be deposited by Weople directly into your piggy bank in the app and can take the form of spendable values in various circuits, such as points, tokens, Amazon vouchers, or other e-commerce vouchers, etc. The commercial development of these earnings, i.e., the support for the sale of communication spaces in the app, actively contributes to the statistical data processing activities described above (Art. 7 and 10) to which you may eventually consent: in fact, the improvement of models, and in general, the growth of know-how, will improve Weople's growth opportunities and its commercial proposition. Furthermore, the personalization of offers and discounts as much as possible, according to the protective mechanism of your data described above, is itself a form of advantage for the Recipient.

The statistical models may also allow Hoda to produce further benefits for you, expressed in terms of data-driven personal services. By way of non-exhaustive examples, with a significant number of app users who have downloaded Amazon archives and purchase data from other sources, Hoda could produce price comparators or spending pattern analyses that could suggest ways to optimize spending. Furthermore, users may wish to use their archives to train a Personal Artificial Intelligence Agent not oriented by the business logic of large companies that today, or tomorrow, offer or will offer these Agents but genuinely protective of the individual user.

Hoda undertakes to make every reasonable effort to maximize Revenue. However, the User acknowledges and accepts that the economic result of the service sales activity can vary significantly depending on multiple factors, also interconnected, including, by way of example and not exhaustively, market trends, number of Weople subscribers, quantity and quality of data provided by the User, type of interests expressed, visualization of proposals made as a result of using Weople, and, in general, results obtained from the Advertising Campaign referred to in Art. 9.

In particular, the User acknowledges and accepts that, in the absence of reaching 100,000 active Weople users, Hoda will not be able to activate advertising campaigns within the App and thus generate the desired value, while, upon reaching that number, Hoda can begin its commercial activity, the outcome of which is variable as indicated above.

Finally, Hoda will work, in compliance with the law, to protect, for everyone, the right to portability established by the GDPR and to take other initiatives to protect and develop the conscious and active participation of people in the Data Economy, something it has already demonstrated it can do and bring to completion.

Art. 12 – Assignment of Wecoin and Distribution of Prizes

The activation of the safes entails the recognition, in favor of the User, of a virtual score ("Wecoin") as indicated in the Application.

The recognition of Wecoin is understood to refer to the activation of the safe including all the data contained within it. The User is free to reduce at any time the number of activated safes by withdrawing consent to the use of data. In this case, however, the amount of Wecoin will be reduced proportionally.

The sum of the Wecoin held overall allows assigning the User a certain investor category, according to the following investment brackets:

  1. Start from 1 to 100 Wecoin;
  2. Bronze from 101 to 200 Wecoin;
  3. Silver from 201 to 300 Wecoin;
  4. Gold from 301 Wecoin onwards.

The investment categories progressively increase the appeal of the segments and possible communications in the app, according to the logic: more data = more opportunities to be in more interesting segments for communication. Furthermore, Hoda, at the start of communication activities in the app, will study a methodology to attribute returns to Recipients in a differentiated manner based on the User's investment category, according to the logic: the higher the category = the greater the gain. Finally, the investment categories allow the User to participate in any prize draws according to the methods indicated in the Weople Draw Regulations published every time. The prizes from any draw activities will result from the database enrichment activities of potential third-party clients.

Section III: Accessory Services

In Weople, investment activities are supported by some accessory functionalities ("Accessory Services") that facilitate data acquisition and maximize the profitability of the investment.

Art. 13 – Exercise of Rights

The User can use Weople to contact their data controller and exercise the right to data portability to obtain the direct transfer of their data to another data controller, in this case, to Weople, operated by Hoda (Art. 20 of the GDPR). The user can decide to transfer data independently within the safes, exercising their right to portability in person. Alternatively, Weople can facilitate the exercise of the right to portability and manage transfer operations, on behalf of the user, in two ways: through their specific delegation or, when made available by the data controller companies, by activating automatic connection technologies for data transfer (server-to-server transfer).

When the User activates a safe with reference to a specific data controller that does not provide automatic server-to-server data transfer technologies (non-exhaustive example: supermarkets), after the User has given consent to data processing (function visible in the app and explained in the Privacy Policies), they can choose to automatically generate a delegation, stored within the App in the "delegations" section, viewable, printable, suspendable, cancellable, lasting one year and renewable in the app. The delegation is to Hoda and allows Hoda to make, on behalf of the User, the request for data portability of the data held by the data controller to which the safe activated and consented by the user refers. This request can be made up to a maximum of 6 times for the duration of each delegation (1 year). Hoda, based on the delegation, will send a message to the data controller to which the individual activated safe refers, asking to transmit the data directly to Weople-Hoda. For greater clarity, it is specified that delegations for data portability will be one for each safe activated and consented by the user, so, in the example above, a delegation, valid for one year, will be generated for each supermarket or, better, for each supermarket chain.

The delegation loses effectiveness if the user, in the meantime, alternatively, revokes in the app the consent to the investment of the specific safe, communicates in the app that they want to delete the data, deletes their account, or revokes the delegation with a specific function in the app.

When the data controller company provides digital server-to-server data transfer technologies (e.g. Google, social networks), Weople takes care of informatically developing the connection. In this case, normally, it is the Weople user who, from the app, authenticates directly in the environment of the data controller company and directly exercises the transfer of data to Weople. No delegation is therefore necessary. According to the rules imposed by the data controller, the transfer may be recurring and require periodic renewal: Weople will take care of informing and guiding the user as best as possible. The transferred data will no longer be used and usable if the user, alternatively, revokes consent to the investment of the specific safe, deletes their account, or communicates in the app that they want to delete the data. Some companies that could implement server-to-server portability may be delayed in making the appropriate IT procedures available, or may never make them available. In these cases, Weople may present the user with a guide, facilitated as best as possible, to the company's own self-service procedure.

Art. 14 – Request for Further Information During the Use of Weople

The exercise of the right referred to in the previous Art. 13, for cases where the user's delegation is necessary, may require further identification measures by the data controller to whom the request is forwarded.

Therefore, Hoda reserves the right to request, at any time, further information relating to the User to allow the correct operation of the delegation. In particular, Weople will ask the User to upload their identity document within the "My Document" section of the Application to generate one or more delegations and enforce them at the request of the data controller. We ask for an identity document because, based on past experience, the contacted controllers have always requested to view a copy of the delegator's identity document to follow up on the delegation, and therefore the request for data portability.

When the User uses direct authentication and data transfer services from third parties, possibly integrated into the Application via digital server-to-server data transfer procedures (API or other suitable procedures), specific integrations may be required by the current data controller (e.g., Google or Amazon) to correctly carry out the portability of such data.

Art. 15 – Data Deposit

The Data provided during registration and those acquired following the exercise of the right to portability as per the previous Art. 13 and 14 deposited in the safes are the exclusive property of the User, and, based on these terms and conditions of service, the User does not grant any usage rights except what is necessary for the provision of the Services.

It is possible to use a mere deposit service if the user revokes the authorization for data profiling for their investment. Once the safe is activated with consequent authorization for data profiling for their investment, the User can decide at any time to revoke consent. For this purpose, they can select the options: revoke consent or delete data. If the User wants to keep their data in Weople, they will choose the "revoke consent" option; otherwise, they can choose the "delete data" option, and all data will be deleted from the safe. The data stored following the revocation are processed solely for storage purposes. If the User does not access Weople for more than one year, we will send a notification to remind the User of their active services. In case of no activity for a further 6 months, Weople reserves the right to delete the deposited data.

Section IV: Prohibited Use, Account Cancellation, and Liability Limitations

Art. 16 – Prohibited Use of Weople

The User will not use, copy, adapt, modify, prepare derivative works based on, distribute, license, sell, transfer, publicly display, publicly perform, transmit, broadcast, or otherwise exploit the contents present in Weople, the Weople Service, or any part of it, unless expressly permitted by these terms and conditions.

The User cannot perform, attempt to perform, or encourage or assist others in performing any of the following actions during access or use of the Service: (1) use, mirror, or frame the Service or any single element within the Service, the name of Weople, any Weople or Hoda trademark, logo, or other proprietary information, the layout, and design of any page or form contained on a page without the express written consent of Hoda; (2) access or tamper with non-public areas of the Service, Hoda's computer systems, or technical delivery systems of Hoda's providers; (3) test the vulnerability of any Weople system or violate security or authentication measures; (4) circumvent any technological measure implemented by Hoda or third parties (including another User) to protect Weople or its contents; (5) modify, decompile, disassemble, reverse engineer, tamper with, or otherwise attempt to derive the source code of any software that Weople provides to the User or any other part of the Service; (6) provide, during registration, or subsequently, false information regarding their identity; (7) create multiple accounts; and (8) attempt to access another User's Account.

Art. 17 – Cancellation and Closure of the Account

The User can deactivate their Account at any time through the Weople interface or by directly contacting Hoda.

Hoda reserves the right to suspend or deactivate the Account if it believes that the User has violated these terms and conditions of service or that the use of the Account may cause any kind of damage or violate laws or regulations.

The data present in the activated safes will be permanently deleted along with the account closure.

The earnings obtained by the User (in the form of discount vouchers, points, spending cards, tokens, etc.) and present in the Weople Piggy Bank can no longer be used after the Account cancellation; therefore, the User is invited to use them before cancelling the Account.

In any case, Hoda reserves the right to close the account and delete the associated data if the case referred to in Art. 15, last paragraph (no activity for more than one and a half years), occurs.

Art. 18 – Indemnification and Limitation of Liability

Hoda assumes no liability towards the User in case of non-fulfilment of the obligations provided for in these terms and conditions of service, if the non-fulfilment is caused, alternatively, by:

To the extent permitted by applicable law, Hoda is not liable to the User for losses:

Hoda's liability will be limited to the amount received by the User for the 12-month period preceding the date to which the compensation request refers.

Hoda will do everything possible to maximize Revenue and, consequently, the profitability of the Investment of the received Data. However, Users acknowledge and accept that Hoda, in performing the Service, assumes an obligation of means and not of result and, therefore, cannot in any way be held responsible for the economic results related to the investment of their Data.

Similarly, the User acknowledges that the result connected to the exercise of the rights referred to in the previous section depends on numerous factors, also external to Hoda, including, by way of example and not exhaustively, technical obstacles, problems connected to the behaviour of the third-party data controller, legislative and regulatory interventions. The User accepts that such factors are outside Hoda's sphere of control and cannot therefore be attributed to it.

Section V: Miscellaneous

Art. 19 – Use and Interruption of the Service

The use of the Service requires the use of compatible devices owned by the User ("Devices") and access to an Internet connection. To guarantee Users the best possible use of the Service, the Provider reserves the right to interrupt the Service for maintenance or system update needs, informing Users through constant updates.

Art. 20 – Update of the Terms and Conditions of Service

These terms and conditions of Service may undergo changes. In such circumstances, the Provider will notify the User at least 15 days before the change takes place (e.g., via email or through push notifications). Once the updated Terms come into force, the User's acceptance will be considered implicit in the case of continued use of Weople.

We hope that our Products continue to be used. However, if the user does not accept our updated Conditions and intends to leave the Weople community, they can delete their account at any time.

Art. 21 – Intellectual Property Rights

All intellectual property rights of any content of the Application (including texts, graphics, software, photographs and other images, videos, audio, trademarks, and logos) are owned by Hoda or its licensors.

The User agrees to access such materials exclusively for the use of the Service and in compliance with the provisions of these terms and conditions of service. No part of the Application, the site, or the Service may be reproduced in any form or by any means. The User agrees not to modify, rent, lease, lend, sell, distribute, or create derivative works based on the Service.

Hoda, the Weople logo, and other Hoda trademarks, service marks, graphic signs, and logos used in connection with the Service constitute trademarks or registered trademarks of the Provider.

Art. 22 – Age Requirements

The use of the Service is reserved for Users who have reached the age of sixteen.

Art. 23 – Applicable Law

The terms of this Contract will be governed and interpreted in accordance with Italian and European law. The applicable jurisdiction is Italian.