This Privacy Policy describes how we process and protect your personal data (“Data”) collected through your use of our Platform.

Terms used in this document have the same meanings as in our Terms of Use.

We GROUPADO sarl, a limited liability company, registered with the RNE under number 1681258W, The building located at 3, rue Ibn Nafis, Khereddine industrial zone LAC 3,, act as a data controller, which means that we determine the objectives and means of processing your data.

We assume that you reasonably expect that use of the Platform will require the processing of your personal data. If you do not agree, you are free to stop using the platform or object to the processing of your personal data.

We never collect your personal data secretly. We never ask for more than is reasonably necessary for the respective purpose.

You will find out in this document:

what data we process, how and for what purposes we process your data,

when and how we can share your data,

the duration of retention of your data

our protection measures to ensure the security of your data

your rights regarding the processing of your data.

If you are under 16 years of age or if your country’s law sets a lower age for your valid consent to the processing of your personal data, you will need to obtain permission from your parent or guardian before providing personal data to the platform.

1 Definitions

Personal data (or data) is any information about you which, alone or in combination with other pieces of information, enables a person collecting and processing it to identify you as an individual. This may include not only information about the person, such as their name, address, gender, racial or ethnic origin, etc., but also technical information about the person’s devices, such as MAC addresses , IMEI, UDID, IDFA, IP addresses, browser information, location information, system information.

Information processing means any action with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means and so on.

We will only process your personal data if we have legal bases such as

the processing is based on the consent you give us;

the processing is necessary to enable you to use the Platform in accordance with our Terms of Use;

achievement of legitimate interests, including, for example, our legitimate interest in marketing or security, or those prescribed by data protection legislation, those necessary for the protection of your vital interests or the vital interests of another natural person; or for the performance of a task carried out in the public interest or within the scope of the official power conferred on us. With regard to this legal basis, you have the right to object to such processing.

We will inform you of the legal basis applied for the processing and other relevant details before we start processing your personal data on the specific legal basis, not listed above, unless we are unable to do so. do so in accordance with our obligations under any applicable legislation.

3 What data we collect, how we process it and for what purposes

3.1 Data you provide to us

This happens when you submit information in different sections or forms available on the platform, such as ‘Contact Us’ or ‘Register’ or when you register your Experience Creator or Experience Participant account. If you submit this information, you give us your consent to process it.

3.1.1 Data from your account

We process all data obtained from your account to enable the operation of the Platform.

We collect your first and last name or company name (if applicable), email address, telephone number, password as data required for account registration and subsequent maintenance. Without this data, we will not be able to ensure the proper functioning of the Platform.

You are free to submit additional information on your profile that is not specifically necessary for registration, such as photos, address, identity information, passport, license, certificate. We may use this information to provide you with relevant experience options.

We also use your account data to allow you to communicate with other users and with us through the Platform or emails. After receiving communications from us, you have the possibility to refuse these communications in each message, with the exception of legal notices, or to modify the parameters of use of the platform.

We may use your name and email address to send you newsletters or marketing or promotional updates on our Platform via email or through social media services such as Facebook, Instagram, or other popular platforms. You can always unsubscribe from our marketing messages, as described under the relevant email, and through the user settings available on the platform or social media tools.

In order to verify the identity of the account holder, we ask you to submit a scan of your identity card or other equivalent document confirming your legal capacity under the laws of your place of residence, as well as to make our platform a safe place to share experiences.

3.1.2 Publication of information on the Platform

We collect data that you post while logged in on the Platform. This includes information you fill out in our surveys or ‘Contact Us’ form, information from your comments, messages, experience options, etc.

You acknowledge that any information you share will be available to other users of the Platform unless we indicate otherwise.

3.2 Automatic collection (cookies and similar web technologies)

When you use the Platform’s website or application, we may automatically receive information from your device and return it to you in order to improve your interaction with the Platform and ensure its proper functioning.

We process this data based on your explicit consent, which allows us to collect cookie identifiers.

We use this data to evaluate Platform performance, personalize our Platform to provide you with a more personalized experience, and draw your attention to information about the Platform.

Please refer specifically to our Cookie Policy for further details on our use of cookies and similar technologies.

3.3 Data collected by third parties

When you register, we ask you to provide your payment, namely your credit card details. This data is collected only by online payment gateways integrated into the platform such as our bank. Payment providers will use this information only to help us verify your identity and make payments through the Platform.

We may collect your name and email address obtained from our Ambassadors for the purposes of the referral program. We retain this information for sending emails that will invite you to visit the Platform if you are not a user of the Platform as well as for tracking the success of our referral program.

4 Who we share your data with

4.1 Access by our employees

We may share your personal data with our verified employees or contractors. For the above purposes, we may share your personal data with these persons. We secure this processing by taking the necessary security and organizational precautions for this sharing.

4.2 Tiers

We do not transfer your data to third parties in the strict sense of the term. Technically, the data you submit will be processed and stored on proven servers and using approved software such as Amazon Web Services cloud computing platforms (AWS S3, EC2, RDS, Code Deploy, Systems Manager). Some information will be shared with other verified and approved services that enable certain critical functions of the platform, i.e. your financial details may be processed by online payment services.

5 How long we keep your data

We keep your data for as long as your account is used. If you are banned or decide to delete your account or simply stop using it, we will retain your data for an additional 12 months to ensure that we have the necessary information in the event of a dispute between the platform and users or between users.

We do not retain information that has been deleted by you.

As for the data collected for newsletters, we will keep them for as long as you are interested in receiving our emails. We consider you interested until you unsubscribe from the newsletters by clicking on the corresponding link contained in each of our emails or by applying the appropriate settings in your user account.

6 How we protect your data

We use data encryption to keep your data secure. We will also notify users and respective agencies of personal data breaches if there are high risks of violation of your rights as data subjects. We will also do our best to minimize such risks.

7 Your rights

You have various rights in relation to your personal data, including the right:

to obtain confirmation that we are processing your personal data and to request a copy of the personal data we hold about you;

to request that we update the personal data we hold about you or correct any that you consider to be incorrect or incomplete;

to request that we delete the personal data we hold about you or restrict the way we use that data;

object to the processing of your personal data and withdraw your consent (if consent is the legal basis for such processing);

obtain that your data can be read and used in different IT environments by machines and software (right to data portability).

We undertake to respond to any Verified User with respect to any questions arising from this Privacy Policy or applicable data protection laws. We undertake to respond within a reasonable time, taking into account the possibility of extending the response time up to 24 hours due to the complexity and number of requests. In any case, we will inform you of this extension.

To exercise any of your rights, or if you have any other questions regarding our use of your personal information, please contact us via the contracts listed below.

8 Changes to this Privacy Policy

We may modify or update this Privacy Policy from time to time, by updating the ‘Last Modified’ date at the top of this Privacy Policy and adding details in the ‘Major Changes’ section below. below. Your subsequent use of this Privacy Policy will confirm your acceptance of it. If you do not agree with this document, you must stop using the Platform.

9 Contact us:

If you have any questions regarding the Privacy Policy, please contact us.

Email address: [email protected]