Kiwi Campus Inc. (“Kiwibot,”“we,”“us,”or “our”) is committed to respecting the privacy rights and concerns of all users (“you”) of the services made available by Kiwibot. This Privacy Policy applies to Kiwibot Service. Kiwibot’s service (the “Service") is defined as deliveries made by Kiwibot using any of our own or third-party platforms. We have established and implemented this Privacy Policy to inform users of the Service of how we use and protect the information we collect through the Service, that may include personal data as defined by applicable laws and regulations.

Please note that some privacy rights and obligations may differ in certain locations based on local law, in which case we will comply with the local legal requirements. By using the Service, you consent to Kiwibot’s collection, use, storage, processing, and deletion of information relating to you as outlined in this Privacy Policy. This Privacy Policy is effective as of the date set forth above and is only applicable to the Service and not to any other websites accessible from the Service, as they may be subject to their own data collection and use practices and policies.

Your personal data will be processed by the Controller and/or Processor. Controller is a natural or legal person or public authority which determines the purposes and means of the processing of personal data. A processor is a natural or legal person or public authority which processes personal data on behalf of the controller.

When you use our Service we are the processor of the data you submit. When you link to technology, software, and services owned and controlled by third parties (“Third Party”), the controller of your personal data is the Third Party. The Service may contain direct links to websites operated by our partners and other third parties. These third-party websites may collect information about you when you visit them or otherwise interact with them. This Privacy Policy does not cover the information practices of third-party websites accessible through the Service. Although we encourage such third parties to adopt and follow their own privacy practices, we are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of their websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use, and disclosure practices.

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2.1. Third-Party Privacy Policies

‍Through the service, you may be able to link to technology, software, and services owned and controlled by third parties (“Third Party Features”). You may be permitted or required to submit personal information to access Third Party Features. Such use of third-party features and submission of information through third-party features will be subject to the applicable terms of use, terms of service, and privacy policy of the third party. You agree to look solely to the third party to enforce your rights in relation thereto.

When you click on a third-party logo or URL displayed in our applications or accessed through the Service, which links to third-party features, our Privacy Policy and terms of use no longer apply. You must read the terms of use, terms of service, and privacy policy of the third party to see how your personal information will be treated on their website.

To provide you with access to our Sites and Services, your Personal Information is collected and used by Kiwibot, which may include Kiwi Campus Inc., a Delaware corporation, having offices at 2173 Bancroft Way, Berkeley, CA 94720, its partners, or its affiliates for particular Services or in specific jurisdictions. Kiwibot will treat your personal information in the United States (EEUU) according to applicable law. We will not transfer your personal information across borders.

When Kiwibot collects your personal data, it is only collected for an appropriate lawful reason. We use, process, and share it only for the purposes for which it was collected. We collect all the information in accordance with appropriate lawful reasons and purposes: to process food delivery orders, optimize logistic processes, predict best routes and offerings to customers, which include: (i) order placement, (ii) processing and delivering you the requested products; (iii) providing you a faster, convenient and satisfactory quality service; (iv) processing orders, (v) handling your customer service inquiries, (vi) verifying your identity, (vii) requesting feedback (viii) distributing newsletters. You give us your consent to use your personalinformation in connection with the performance of our Service as set forward in this Privacy Policy.

To access our Service, you might provide us with your personal information, or it can be automatically collected.



4.1 Information you provide to us‍

(i) Your location: We need this information to know and store your address or delivery location in order to deliver to you the food you order.

(ii) Your phone number: We need to know your phone number in order to notify you about your order delivery and contact you in order to solve any problems or questions related to the Service. Furthermore, your phone number lets us identify you as a customer or user of our Service and assist you with technical questions about our Service. We will use your phone number information with communication purposes for managing and tracking the delivery process and for the advertisement and promotion of our website and/or mobile application and/or Services. We may collect information from you if you subscribe to our newsletter, receive customer support, or participate in components of the service through which users may post content.

(iii) Your email address: We will use your email address information with communication purposes for managing and tracking the delivery process and for the advertisement and promotion of our website and/or mobile application and/or Services. We may collect information from you if you subscribe to our newsletter, receive customer support, or participate in components of the service through which users may post content.

(iv)Your payment card and other payment method information: We need your payment card information in order to make the payment of your order in a faster and secure way. Kiwibot will not access or store this information or the full credit data itself. Personal Data and Credit Card Information: We use secure payment processing, according to Payment Card Industry Data Security Standard (PCI DSS) in accordance with guidelines set forth by Controller’s acquiring bank.



4.2 Information we collect automatically:  

‍(i) Images and videos captured by Kiwibot robots: We use semi autonomoustechnology to provide the Service, accordingly, we use cameras and sensors, with theexclusive and only purpose of assisting with localization, location, driving assistance,visibility, and mapping of the robots and the fulfillment of the Service; thus, it enables us to effectively deliver orders safely while navigating highly complex situations. We workdiligently in order to avoid collecting or storing any personal information or identifiableimages of people in the usage of those cameras and sensors, for which we use medium-uality resolution photos. Kiwibot robots don’t record or capture any conversations oraudio data. We may make your personal information non-personally identifiable by eithercombining it with information about other users or by removing characteristics that makethe information personally identifiable. This process is known as de-personalizing of your
information.

We may collect photos of the infrastructure of the sidewalks or facilities in order to enhance the safety and efficiency of our robots in the traffic. These photos are medium-quality resolution and under no circumstances or for no reason will the cameras and sensors used to operate the Robots be a means of surveillance by us or any third party.
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4.3 Incident Rules:
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Access to customers’ personal information is limited by high-grade commercial cryptography with mutual certificate-based authentication to the server that also provides transport security between our operators and the Service. Kiwibot’s robots have on-board high-level technical telemetry and sensors (including high-resolution visual sensors) that serve as a black box, this data is taken at a lower resolution for use in the black box which will allow us to detect improvements and review the status of the robot based on incidents such as vandalism, robot failure or roll over, among others.

Kiwibot classification schema is designed to ensure that information is classified and protected in accordance with its importance or sensitivity. Information is classified in accordance with any relevant legal, regulatory and industry compliance requirements, business value, criticality and sensitivity to ensure appropriate protections are in place to prevent unauthorized disclosure or modification. Classification categories and associated protective controls for information must be proportionate to the sensitivity of the information and take into account the business needs for sharing or restricting information, as well as legal, regulatory and industry compliance requirements. Information classification is consistently applied and easily understood.

All information created, received, handled, transmitted or stored is categorized according to Kiwibot information classification categories. All the information we collect from you is treated as “KIWIBOT Restricted - Personal Information”, according to Kiwibot´s Data Protection and Handling Process internal Policy. Restricted- Personal Information must be understood as any information, either alone or when combined with other information, that is about a natural living individual or can be used to identify, locate, contact or target them, this includes any personally identifiable information that is subject to privacy regulations.

As we provide our Service using any of our own or third-party platforms, we do not knowingly collect personal information from children under 13 nor allow them to access the Service. We take children’s privacy very seriously and encourage parents to always play an active role in their children’s online experience.

We will keep your Personal information for as long as it is necessary to fulfill the purpose for which it was collected according to section 4 or to comply with legal and regulatory requirements. If you wish to have any Personal information removed from our databases,you can have it removed in accordance with Section 9. Deletion of Data shall be performed in a manner that is compliant with General Data Protection Regulation.

We take your privacy seriously. We take different measures to protect and ensure that your information is safely treated:

(i) we take and implement the appropriate, relevant security and confidentiality measures;

(ii) we take relevant industry standard measures to prevent physical access to Personal Data;

(iii) we take relevant industry standard measures to ensure that Personal Data is accessible only by its properly authorized personnel;

(iv) we take relevant industry standard measures to prevent Personal Data from being used without authorization;

(v) we take relevant industry standard measures to ensure that it is possible to check and establish whether and by whom Personal Data
has been entered into data processing systems, modified or remove;

(vi) we take relevant industry standard measures to prevent Personal Data from being read, copied, altered or deleted by unauthorized parties during the treatment of your Personal Data;

(vii) we back-up the databases we use to provide our Services on a regular basis, and ensure that such databases are secured, tokenized and/or encrypted. Consequently, the personal information that you provide to us is stored on servers that are located in facilities in the United States with restricted access and protected by protocols and procedures designed to ensure the security of such information. We are also making sure that all our employees are aware of the rules and requirements regarding the handling and protecting personal information of our customers.

We restrict the access of Personal Information to Kiwibot employees, independent contractors, and agents who need to know that information in order to develop, operate and maintain the Service. Once we receive a transmission from you, we will endeavor to maintain its security on our servers.

The personal information uploaded by you through the Service will be shared with authorized people to whom you specifically grant access, as follows:

(i) Kiwibot’s subsidiaries, affiliates, partners and other related companies for the purposes listed in Section 4.

(ii) Service providers and business partners for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications. We may use your personal information with service providers to process your information on our behalf. Additionally, we may partner with other companies to process, analyze, and store data, including, but not limited to, analytical
data. To the extent applicable, we require these partners to comply with this Privacy Policy and appropriate confidentiality and security measures. Where required by the privacy shield, we enter into written agreements with such service providers requiring them to provide the same level of protection the privacy shield requires and limit their uses of the data to the specific services offered on our behalf.

(iii) Outside Kiwibot or its partners, we may transfer Personal information to third parties to complete the purposes listed in Section 4. Third parties may include governmental entities requests, such as a court order or a request by law enforcement or governmental authorities. We may also share personal information if such action is appropriate to enforce our Terms of use for the Service, including any investigation of
potential violations thereof, when such action is deemed necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the service, or when such action is appropriate to protect the rights or property of Kiwibot, its employees, users of the Service or others.

In all cases, we require all unaffiliated third parties such as agents, or service providers to treat personal information as confidential, comply with this Privacy Policy and maintain appropriate security to protect your information from unauthorized access or processing, as stated on the agreements we sign. In addition, we take reasonable and appropriate steps to ensure that third parties process your personal information in accordance with our privacy shield obligations, where applicable, and to stop and remediate any unauthorized processing of your personal information.

We strive to make sure that our information about our customers is reliable, accurate, and up to date. You have rights concerning personal information about you, as follows:

(i) Right to be informed: You have the right to receive information about what data we capture, process and store about you, this information may include the categories orspecific types of personal information we have collected; the purpose for collecting or disclosing the information; the sources from which personal information was collected; among others.

(ii) Right of access: You have the right to ask us to rectify personal information that you think is inaccurate. This also includes the right to ask us to complete information you think is incomplete or outdated.

(iv) Right to deletion: You have the right to request deletion of your personal data that is being stored by us. Please keep in mind that we cannot delete any data that we process to fulfill contractual or legal obligations.

(v) Right to data portability: You have the right to request to port your data to a similar service to the extent this is technically feasible.

(vii) Equal service and price: You have the right not to be discriminated against when you exercise your rights, we will not deny you goods or services, charge a different price, impose penalties, provide a different level or quality of service, or suggest a different price or rate or different level or quality of goods or services in order to ensure we provide an equal service and price to all customers.

(viii) Opting out of receiving communications from us: If you no longer want to receive our newsletter, emails, or other announcements, you may unsubscribe by writing to us at info@kiwibot.com or by following the “unsubscribe” link at the bottom of our emails. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account.


10.1 Exercise your rights

You may update or request rectification or deletion of your personal information or exercise of any of your rights regarding your personal information when treated by Kiwibot by writing to us at data@kiwicampus.com. Additionally, you may have the right to access the privacy shield data that we hold about you. If you would like to request access to your privacy shield data, you can submit a written request to the email address provided above. We may request specific information from you to confirm your identity.

You agree that, in the event, any dispute or claim arises out of or relating to this Privacy Policy, you and Kiwibot will attempt in good faith to negotiate a written resolution of the matter directly between the parties. You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Los Angeles, California, the United States of America whichever is closest to you, with a mutually agreed mediator in an attempt to resolve the dispute.

If you have any questions about our privacy practices for this Privacy Policy, please contact us by email at data@kiwicampus.com.