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Privacy Policy

WSHNETWORK, INC.

ARTICLE I - Introduction

This Privacy Policy explains how WSHNETWORK, INC. ("we," "our," "us") collects, uses, stores, and protects your personal data when you use our WSH mobile application and associated services (the "Platform"). WSHNETWORK, INC. is the data controller for the personal information we collect and process through our services.

This Privacy Policy is designed to comply with the EU General Data Protection Regulation (GDPR) and applies to all users of the WSH mobile app. By using WSH, you acknowledge that you have read and understood this Privacy Policy. This policy is written in a clear and accessible way, and you can request it in an alternative format if needed.

Effective Date: November 3, 2025
Last Updated: November 3, 2025

ARTICLE II - Data Protection Officer

WSHNETWORK, INC. has appointed a Data Protection Officer (DPO) to oversee our data protection strategy and ensure compliance with applicable privacy laws. If you have any questions about this Privacy Policy, how we handle your personal data, or wish to exercise your data protection rights, you can contact our DPO directly:

ARTICLE III - What Personal Data We Collect

In line with the principle of data minimization, we only collect personal data that is necessary to provide and improve our services. The types of personal information we collect are as follows:

Data Category	Description
Account Information	Your university email address. This is essential for verifying your student status and granting you access to your university's WSH community.
User-Generated Content	All content you create and share on the Platform, including text posts, polls, images, videos, comments, and reactions.
Technical Data	Information automatically collected for security, functionality, and performance, including your IP address, device type and identifier, browser type and version, operating system, app version, and activity logs.
Moderation Data	Records related to content moderation, including reports of content violations, enforcement actions taken on your account, and related correspondence.

WSH does not intentionally collect sensitive personal information, such as health data, financial information, or other special categories of personal data.

ARTICLE IV - How We Collect Your Data

We collect your personal data through the following methods:

• Direct Collection: We collect your university email address. We also collect the content you voluntarily create and post on the Platform.
• Automated Collection: Our systems automatically collect technical data when you use WSH, such as your IP address and device information. This is done through standard technologies like cookies and log files.
• User Reports and Moderation: We collect information when users report content or when our moderation systems flag content for review.

ARTICLE V - How We Use Your Data and the Legal Basis for Processing

We process your personal data for specific purposes and only when we have a valid legal basis to do so under the GDPR. The purposes for which we use your data and the corresponding legal bases are outlined below:

Purpose	Legal Basis
Account Creation & Authentication	Contract: We use your account information to create and maintain your account, verify your student status, and provide access to the WSH community. This processing is necessary to perform our contract with you.
Content Moderation and Community Safety	Legitimate Interest: We process user-generated content and moderation data to maintain a safe and respectful community. Our legitimate interest in protecting users from harmful content justifies this processing.
Security and Fraud Prevention	Legitimate Interest: We use technical data to detect and prevent security threats, unauthorized access, and other fraudulent activities. Our legitimate interest in protecting the Platform and its users justifies this processing.
Communications with Users	Contract: We use your contact information to send account-related notices, platform updates, and security alerts. This is necessary to fulfill our contractual obligations.
Legal Compliance	Legal Obligation: We may process your data to comply with applicable laws and respond to valid legal requests from law enforcement or regulatory authorities.

We do not use your personal data for marketing or advertising purposes.

ARTICLE VI - Data Sharing and Disclosure

WSHNETWORK, INC. does not sell, rent, or trade your personal data. We do not share your personal data with any third-party providers for marketing, advertising, or any other purpose not directly related to the provision of our services. Your data is shared only in the following limited circumstances:

• Legal Requirements: We may disclose your personal data if required by law, court order, or other legal process, or if we believe in good faith that such disclosure is necessary to comply with legal obligations, protect our rights, or ensure user safety.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a part of our business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

ARTICLE VII - Data Retention

We retain your personal data only for as long as necessary to provide our services, comply with legal obligations, and protect our legitimate interests. Our data retention periods are as follows:

• Active Accounts: We retain your account information and user-generated content while your account is active.
• Account Deletion: When you delete your account, we will remove your core account data and user-generated content from our active systems. Some data may be retained in our backup systems for up to 180 days for disaster recovery purposes.
• Legal and Regulatory Requirements: We may retain certain data for longer periods if required by law or to resolve legal disputes.

ARTICLE VIII - Your Data Protection Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of Access: You have the right to request access to the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct or update any inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal data.
• Right to Restrict Processing: You have the right to request that we limit the processing of your personal data.
• Right to Object: You have the right to object to our processing of your personal data.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where we process your data based on your consent, you have the right to withdraw that consent at any time.
• Right to Lodge a Complaint: You have the right to file a complaint with a supervisory authority if you believe we have violated your privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at contact@wshnetwork.com. We will respond to your request within 30 days.

ARTICLE IX - Data Security

We have implemented appropriate technical and organizational security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using HTTPS/TLS. Our databases and storage systems employ encryption at rest.
• Access Controls: We maintain strict access controls to ensure that only authorized personnel can access personal data.
• Regular Security Reviews: We conduct periodic security assessments to identify and address potential vulnerabilities.
• Data Breach Response: In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authorities within 72 hours.

ARTICLE X - Automated Decision-Making

We use automated tools to assist in content moderation; however, all significant moderation decisions that result in account restrictions or content removal are subject to human review. We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.

ARTICLE XI - Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify you through an in-app notification or by email. The "Last Updated" date at the top of this policy will indicate when the latest changes were made.

ARTICLE XII - International Data Transfers

Your personal data may be transferred to, and processed in, countries other than your country of residence. These countries may have data protection laws that differ from those in your country. Specifically, our servers are located in the United States, and our group companies and service providers operate around the world.

When we transfer your personal data outside the European Economic Area (EEA), we ensure that it receives an adequate level of protection. Where applicable, we rely on the EU–U.S. Data Privacy Framework for transfers to certified organizations in the United States, and on the European Commission's Standard Contractual Clauses (SCCs) for other international transfers. These mechanisms require all recipients to protect personal data in accordance with EU data protection law.

ARTICLE XIII - Children's Privacy

Our Platform is intended for users aged 18 and over. Individuals under 18 are not permitted to use the Platform. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

ARTICLE XIV - Contact Us

If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us at: