Last Updated: 09.05.2025

1. Introduction

Welcome to Henri (‘we’, ‘our’, or ‘us’). We are committed to safeguarding the privacy of our users (‘you’, ‘your’), including minors. This Privacy Statement outlines how we collect, use, disclose, and protect your personal data when you use our mobile application, Henri, available on iOS and Android platforms.

HenriPay B.V., Dr. Holtroplaan 19, 5652XR Eindhoven, Netherlands, is the data controller responsible for your data.

This Privacy Statement complies with the General Data Protection Regulation (GDPR) for users in the European Union (EU) and the California Consumer Privacy Act (CCPA) and other relevant regulations for users in North America (NA).

This Privacy Statement also outlines your rights and choices with respect to your personal data, and how you can exercise them

By downloading, accessing, or using Henri, you agree to this Privacy Statement. If you do not agree, please do not use our services.

2. Information We Collect

We may collect and process the following types of information:

a) Personal Information:

• Name, email address, date of birth, and contact details.
• Usernames and profile pictures (or avatar).
• Account credentials.

b) Financial Information:

• Payment details for in-app purchases.
• Transaction history.

c) Usage and Device Information:

• Device type, operating system, IP address, and browser details.
• App usage data and analytics.

d) Trivia and User-Generated Content:

• Responses to trivia questions and activity data.
• User-generated text, images, and other contributions.

e) Location Data:

• Approximate or precise location data (if permitted by you).

We may collect location data to provide relevant features (e.g., region-specific content or parental control features). This data is only collected with your permission and may include GPS-level precision depending on your settings.

f) Data from Minors:

• We may collect and store information provided by minors, including trivia responses and in-app activities, in compliance with applicable laws.

3.Legal Basis for Processing (GDPR Specific)

We process your data under the following legal bases:

• Consent: When you provide explicit consent.
• Contractual Necessity: To fulfill our agreement with you.
• Legitimate Interest: To improve our services.
• Legal Obligation: To comply with legal, regulatory or compliance requirements.

When we use personal data to serve the legitimate interest of Henri or a third party, we will always balance the rights and interests of the data subject and the protection of their information against the rights and interests of Henri and/or the third party.

You may object to processing based on our legitimate interests at any time by contacting us at legal@henripay.com.

4.How We Use Your Information

We use your data to:

•  Provide, maintain, offer, and improve our services.
• Process payments and transactions.
• Personalize your user experience.
• Communicate with you about updates and offers.
• Customer support and customer services.
• Display targeted advertisements.
• Anti-money laundering and know-your-customer purposes (including trade sanction compliance).
• Prevent, detect and investigate fraud and other illegal activities.
• Legal, regulatory and compliance purposes.
• Monitor and analyze usage trends.
• Ensure compliance with legal obligations.
• Conduct research and analysis.

Targeted Advertising and Data Sales:

• Trivia responses and user data may be analyzed for targeted advertising.
• Aggregated, non-identifiable data may be sold to third parties.

You can opt out of targeted advertising by adjusting your preferences within the app settings.

We do not sell your personal data in a way that identifies you. Aggregated, anonymized data may be shared with third parties. You can opt out of targeted advertising or data sharing for marketing purposes at any time.

5. Sharing Your Information

We may share your data with:

• Service Providers: Third-party vendors assisting with app functionality, analytics, fraud prevention, anti-money laundering prevention, trade sanction compliance and payment processing.
• Advertising Partners: For personalized advertising.
• Legal Authorities: If required by law or to protect our rights.
• Business Transfers: In case of a merger, acquisition, or sale of assets.

For European users, data transfers outside the EU/EEA will only occur under appropriate safeguards, such as Standard Contractual Clauses (SCCs).

6.Data Retention

We will retain your data only as long as necessary for the purposes stated in this statement, unless a longer retention period is required by law.

Account Deletion:

• Apple iOS Users: You can request account deletion directly from within the app or by emailing legal@henripay.com.
• Google Play Users: You can delete your account via the in-app settings or by emailing legal@henripay.com.

Account deletion will result in the removal of all personal data, except for legally required retention.

Certain data may be retained after account deletion to comply with legal obligations or to prevent fraud, in line with statutory retention requirements.

7. Data Security

We implement industry-standard security measures to protect your data from unauthorized access, loss, misuse, or disclosure. However, no system is completely secure, and we cannot guarantee absolute data security.

8. Your Rights (GDPR and CCPA Compliance)

You have the following rights:

• Access: Request access to your personal data.
• Correction: Update or correct inaccurate information.
• Deletion: Request account and data deletion.
• Data Portability: Request a copy of your data in a machine-readable format.
• Opt-Out: Opt-out of targeted ads or data sales.
• Withdraw Consent: Withdraw your consent at any time.

To exercise your rights, contact us at legal@henripay.com.

For EU users, you have the right to lodge a complaint with your Data Protection Authority (DPA).

9. Children’s Privacy

Our app is accessible to minors, and we take their privacy seriously. We are committed to protecting the privacy of minors (i.e. persons below the age of 16) who use our services. This section outlines how we handle data from minors and provide safeguards to ensure compliance with applicable laws such as the General Data Protection Regulation (GDPR), the Children’s Online Privacy Protection Act (COPPA), and other relevant applicable laws and regulations.

If you are under the age of 16 (for some countries, higher age may apply), you may only use our services with the explicit consent of a parent or guardian and parental or guardian consent is verified prior to any processing of their data. We do not knowingly collect or process personal data from minors without such consent.

Parents or guardians may contact Henri at legal@henripay.com to:

– Verify or withdraw consent provided for a minor.

– Request access to, adjustment of or deletion of the minor’s personal data.

We employ robust measures to ensure that the personal data of minors is processed with heightened security and limited retention periods. Data collected for minors is only used to facilitate their travel-related activities and will not be used for marketing, profiling, or any purpose not directly related to the requested service.

We shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over the child. We may verify parental consent through email confirmation and may request proof of parental authority when appropriate.

We may offer certain parental controls that allow you to manage your child’s interaction with specific features of the app.

10. Cookies and Tracking Technologies

We use cookies, tracking pixels, and similar technologies to enhance your experience and for analytics and advertising purposes. You can manage your cookie preferences via your device settings.

For more details, please refer to our Cookie Policy. You may adjust your preferences at any time in the app settings or your device’s privacy controls.

11.Changes to This Privacy Statement

We may update this Privacy Statement from time to time. Changes will be effective upon posting on our website or app. Please review this statement periodically.

9. Contact Us

For any questions, concerns, or requests regarding this Privacy Statement, please contact us:

• Email: legal@henripay.com
• Mail: Henri Legal Department, Dr. Holtroplaan 19, 5652XR Eindhoven

Thank you for trusting Henri with your privacy.