Privacy Policy

Last updated: 19 October 2025

Your privacy matters deeply to us. We at Rule Threes Enterprise (MA0340370-W) follow a set of fundamental principles:

• We only collect information that is necessary to provide and improve our services for all users.
• We store personal information for as long as we have a reason to keep it.
• We help protect you from unreasonable requests for your personal information.
• We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

Hi there! We are the team behind Chur, and we're committed to create a more active and connected world. Our mission is simple, to make life more sociable and exciting by connecting people through play. From fitness, sports, to esports, we believe there's something for everyone – and we're here to help you find it.

Throughout this Privacy Policy we will be referring to Chur as the App.

Please note that this Privacy Policy applies only to information that we collect about you when you use the App. It does not extend to any third-party activities, websites, applications, or services, which are subject to their own privacy policies.

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

1.1 Information We Collect

We only collect information about you if we have a reason to do so – for example, to make the App do what it's meant to do – connect like-minded businesses and people, to communicate with you, or to make our App better.

We collect this information in a few ways: if and when you share it with us, automatically through the use of the App, and from external sources. Let's go over the information that we collect.

1.2 Information You Provide Us

It's probably no surprise that we collect information you choose to share with us. Here are some examples:

• Basic account information. When you sign up, we ask for some basic details so we can create your account. This usually means your name, email address, and password. We also ask for your date of birth to make sure you meet our minimum age requirement of 16 years old, as well as location – just the city you live in, nothing more – in order to show you nearby activities. If you're a business, we may also ask for your business information such as name, job title, address, and contact details to help customers find and connect with you.
• Profile Information. When you create your profile, we will be asking you to share what activities you're interested so we can help match you with the right classes, events, and businesses. You can also add a profile picture if you like, but that part's optional.
• Business Profile/Listings. If you're a business user, you'll be asked to share details about your business and the classes or events you host. This includes things like your company name, business description, contact information, hosting location, operating hours, pricing etc. You'll also need to share some photos and details about the individual hosting the class / event. Your business information will be made public – or else how can people find you – so please keep that in mind when deciding what to include.
• Payment Information. If you are a business user and choose to purchase a subscription to unlock more features, you'll provide payment information at checkout. We don't process or store payment details ourselves – that's handled securely by our payment partner, Stripe. We only store information about your purchase including subscription plan as well as keep copies of invoices and receipts in case you need them.
• Communications with us. If you contact us for help, share feedback, or respond to a survey, we collect the information you provide like your name, email address, and message, so we can respond and help.

1.3 Information We Collect Automatically

We also collect some information automatically when you use the App. This helps us keep things running smoothly, understand how people use the App, and make improvements overtime.

• Log Information. Like most apps, we automatically collect basic technical details such as your device type, operating system, IP address, language preference, the date and time of access, and mobile network information.
• Usage Information. We collect information about how you use the App – for example the details of the locations, classes, and events created in the past, the actions you take in the app (like checking into classes or events), and general interaction patterns.
• Transactional Information. When you make a payment through the App (for example, to purchase a subscription), we automatically receive information such as transaction amount, currency, payment status, and timestamp from our payment processor – Stripe, to confirm and record the transaction.
• Location information. We may collect your approximate location from your device or IP address to help show relevant businesses, classes, and events nearby.
• Stored Information. If you give us permission through your device settings, the App may access stored information like photos when you upload a profile photo or business-related image(s).
• Interactions. When you interact with a business – such as checking into a class or leave a review. This helps the business keep track of attendance and receive feedback from customers.

1.4 Information We Collect from Other Sources

We may also receive some information about you from other services that we use to help run the App. For example:

• Third-Party Login. If you choose to sign in using a third-party account (like Google, Apple, Discord, or Facebook), we may receive information associated with your login information such as connection token, your username, your email address.
• Payment Processing. When you make a payment through our partner - Stripe, we receive limited details from them such as your payment status, transaction reference, and customer ID.
• Maps and Location Services. If you use location features in the App (like viewing nearby businesses or activities), we may receive location and map-related data from our map provider to display accurate results.

How and Why We Use Information

2.1 Purposes for Using Information

We use the information we collect for a few important reasons.

• To ensure quality, maintain safety, and improve the App. For example, by monitoring and analyzing how people use the App we are able to make informed decisions to improve the overall experience, and develop new features that make the app easier, safer, and more useful for everyone.
• To place and manage ads in our advertising program. For example, to place ads tastefully throughout the app as part of our advertising program without comprising the user experience, and understand ad performance.
• To market our in-app features as well as measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who a particular subscription plan or have been users for a certain length of time), advertising our features, analyzing the results of our marketing campaign (like how many people purchased a certain subscription plan after receiving a marketing message), and understanding, forecasting user retention.
• To fix problems with our App. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements, as well as providing tailored business and activity recommendations.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most of the App, or sharing with you offers and promotions that we think will be interest to you. If you don't want to hear from us, you can opt out of marketing communications at anytime. That said, if you opt out, we'll still send you important updates relating to your account.

2.2 Legal Bases for Collecting and Using Information

For people in the UK or European Union, we rely on the following legal bases to collect and use your information: to perform our contract with you (providing the App), our legitimate interests (keeping the App running, safe, and improving over time), your consent (where required, such as certain marketing), and to comply with legal obligations.

Sharing Information

3.1 How We Share Information

We share information about you only when it's necessary, and always with appropriate safeguards on your privacy. Here's how and when your information could be shared:

• Subsidiaries and independent contractors. We may disclose information with our subsidiaries and trusted independent contractors who need the information to help us keep the app running or process the information on our behalf. We require our subsidiaries and independent contractors to respect and follow this Privacy Policy for any personal information that we share with them.
• Third Party Vendors. We may share information with trusted third-part providers who help make the App possible. This includes companies that handle processing (like Stripe), mapping and location visualisation (like Google Maps), data hosting, analytics, customer support, and email delivery. These providers are only allowed to use your information to perform their specific tasks on our behalf and are required to protect your information.
• Legal and regulatory requirements. We may disclose information if we are required to do so by law or in response to valid legal requests, such as a court order or government enquiry.
• To protect rights and safety. We may share information when we believe in good faith that it's necessary to protect the rights, property, or safety of the App, our users or the public – for example, to prevent fraud or misuse of the App.
• Business Transfers. If the App, or Rule of 3s is involved in a merger, sale, or transfer of assets, your information may be part of that transaction. If that happens, this Privacy Policy will continue to apply to your information.
• Aggregated or de-identified information. We may share data that has been aggregated or de-identified, so that it can't reasonably be used to identify you. For instance, we might share aggregate statistics about the use of the App, or statistics about participation of a certain activity in a region to facilitate customized ad campaigns.
• Published support requests. If you send us a request for assistance (for example, via one of our feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

3.2 Sharing Information Publicly

Information that you choose to provide in the App may be visible to other users or the public. For example:

• Business, class or event listings. If you list a business, class, or event, that information (including the host, contact details, schedule, and images) will be visible to the public. Simply put, by creating a listing, you consent to it being share publicly.
• Reviews and ratings. Any reviews or ratings you leave for a business, class, or event, will be visible to others.

Please think carefully about what you share, because this information can be seen by other users and may also appear in search results.

How Long We Keep Information

We generally discard information about you when it's no longer needed for the purposes for which we collect and use it. In other words, we keep information as long as it's needed to continue making the App work as intended, or to comply with legal obligations. Once it's no longer needed, we delete it or anonymise it. For example:

• Account and profile information. If you choose to delete your account, we remove your personal information from the app unless we need to keep it for legal or administrative reasons.
• Business, class, or event listings. When you remove a listing, it may remain in our backups for administrative and/or operational reasons, but will no longer be publicly visible.
• Check-ins, reviews and ratings. Same as the removal of a listing, it may remain in our backups for administrative and/or operational reasons, but will no longer be publicly visible.
• Payment and subscription records. We retain invoices and receipts for tax and accounting purposes, even after a subscription ends.

Security

While nothing online can be completely secure, we take the protection of your information seriously. We use reasonable measures to help protect your information against unauthorized access, use, alternation, or destruction of your data.

To help keep your account safe, we encourage you to use strong passwords and use the available security features, such as two-factor authentication.

Your Choices

You have several choices available when it comes to information about you:

• Limit the information that you provide. If you have an account with us, you can choose not to share certain information like uploading a profile photo, however, some features – such as accessing subscription features – may not work without certain information.
• Limit access on your mobile device. Your mobile device operating system should provide you with the option to discontinue our ability to access functions (like your camera), stored information (like photos), or location information. If you choose to limit this, you may not be able to use certain features, like create listings, or find businesses and/or activities within your vicinity.
• Manage marketing communications. You can opt out of receiving promotional messages from us at any time by following the unsubscribe instructions in the message. However, we may still send you important information or account-related notifications.
• Close your account. While we'd be very sad to see you go, you can close your account at anytime if the App is no longer of use to you. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above – for example, to comply with legal obligations or reasonably needed for our legitimate business interest.

Your Rights

If you are located in certain parts of the world, including some US states and countries that fall under the scope of the UK or European General Data Protection Regulation (aka the "GDPR"), you may have certain rights over your personal information, such as right to request access or deletion of your data.

7.1 UK or European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, including the rights to ask the following:

• For a copy of your data;
• To correct or delete your data;
• To stop using or processing your data;
• To limit how we use it; or
• To send your data to you or another provider.

You also have the right to make a complaint to a government supervisory authority.

7.2 US Privacy Laws

Laws in some US states requires us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You can find information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide under California Law).

Depending on how you use the App, we may have collected the following categories of personal information:

• Identifiers (such as your name, contact details, and device or online identifiers);
• Commercial information (such as billing details, subscription history, or purchase records);
• Characteristics protected by law (for example, providing your gender as part of a research survey for us, or your age for verification purposes);
• Internet or network activity (such as how you use to App or interact with listings and features);
• Geolocation data (such as approximate location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Inferences we make (such as likelihood of retention or attrition).

We collect this information for the purposes described in How and Why We Use Information section, and may share it with the categories of third parties described in the Sharing Information section. We retain this information for the length of time described on our How Long We Keep Information section.

Depending on your state of residence, you may have rights to:

• Request a copy of the specific pieces of information we collect about you and, if you're in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
• Request deletion personal information we collect or maintain;
• Request correction of personal information we collect or maintain;
• Opt out of the sale or sharing of personal information;
• Receive a copy of your information in a readily portable format; and
• Not receive discriminatory treatment for exercising your rights.

7.3 Right to Opt Out

We never directly sell your personal information in the conventional sense (i.e., for monetary gains).

We may share your information as necessary with our third-party service providers to provide our services to you. To the extent that we share your information with certain advertising, marketing, or analytics vendors, this can be considered a "sale" or "share" in certain US States, which you may have the right to opt out of.

To exercise these rights, you can contact us using the details provided in the How to Reach Us section below.

We do not collect or process sensitive personal information unless it's strictly necessary for the functionality of the App, where the processing is not for the purpose of inferring characteristics about you, or for the other purposes that do not require an option to limit under California Law. We don't knowingly sell or share personal information of those under 16.

7.4 Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings, but if you aren't able to or you'd like to contact us about one of the other rights, scroll down to "How to Reach Us" to, well, find out how to reach us.

When you contact us about one of your rights under this section, we'll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

7.5 Appeals Process for Rights, Requests, Denials

In some circumstances we may deny your request to exercise one of these rights. For example, if we cannot verify that you are the account owner we may deny your request to access the personal information associated with your account. As another example, if we are legally required to maintain a copy of your personal information we may deny your request to delete your personal information.

In the event that we deny your request, we will communicate this fact to you in writing. You may appeal our decision by responding in writing to our denial email and stating that you would like to appeal. All appeals will be reviewed by an internal expert who was not involved in your original request. In the event that your appeal is also denied this information will be communicated to you in writing.

If your appeal is denied, in some US states you may refer the denied appeal to the state attorney general if you believe the denial is in conflict with your legal rights. The process for how to do this will be communicated to you in writing at the same time we send you our decision about your appeal.

Controller and Responsible Companies

The App is run by a small but mighty team at Rule of 3s, based in Malaysia. That means we're the ones in charge of decision how and why your personal information gets used when you interact with our app.

Right now, it's just us – no parent companies, no subsidiaries, no complicated corporate family tree.

We do work with a few trusted partners who help keep things running (like Stripe for Payments and Google Maps for location stuff). These partners only process your info so we can provide the services you asked for, and they're required to protect it just like we do.

Since we're a small company, some of our tools and servers are located in other countries (for example, Singapore, US). Whenever your data crosses borders, we make sure it's protected by using standard legal safeguards that privacy laws like the GDPR require.

How to Reach Us

If you ever have a question about this Privacy Policy, or would like to contact us about any of the rights mentioned in the Your Rights section above, drop us a line at privacy@ruleof3s.com.

We'll get back to you – rest assured it's actually us reading those emails!

Other Things You Should Know

10.1 Transferring Information

Because the App is available for use worldwide, the information about you that we process when you use it in the EU or the UK may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) or the UK who work for us, other members of our group of companies, or third-party processors. This is required for the purposes listed in the How and Why We Use Information section above.

When providing information about you to entities outside the EEA or the UK, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law.

If you're ever curious about where your information goes or how it's protected, just reach out to us at privacy@ruleof3s.com — we'll happily explain.

10.2 Third-Party Software and Services

From time to time, you may use features in the App that connect with third-party tools – for example, maps, payment processors like Stripe, or social media embeds. When you use those, some information might be shared directly with that third party.

We don't control how those companies handle your data, so their own privacy policies will apply. We recommend checking them out before using any third-party features, just for peace of mind.

10.3 Visitors to User Content

If you post your business, or host activities through the app, you control what information you share publicly – for example, the event name, location, or contact information.

If other users interact with your listing we may process some of that data on your behalf (like who checked-in), but you decide what to do with that information.

We do not moderate or control user-generated content. So if someone has an issue with what's being shared, we suggest they reach out directly to the business that made the post.

Privacy Policy Changes

We may update this Privacy Policy from time to time — but don't worry, most changes will probably be small. Whenever we make an update, we'll change the "last updated" date at the top of the policy so you can tell what's new.

If there's ever a major change (like something that affects how we handle your information), we'll make sure you know — for example, by sending a notification through the app or email.

By continuing to use the app after any changes are posted, you're agreeing to the updated Privacy Policy. We encourage you to check back every so often to stay up to date.

Translation

Our Privacy Policy was originally written in English (UK). We may translate it into other languages in the future.

In the event of a conflict whereby a translated version of our Privacy Policy is required in a different language, the English version will control.

Credit and License

Shout-out to the awesome folks at Automattic – they made their Privacy Policy available under the Creative Commons Sharealike License making it possible for startups like us to have a solid foundation to build on.

Finally, that's it! Thanks for reading.

Change Log

• 19 October 2025: Privacy Policy — Ver. 1.0 Published.