We GROUPADO Sarl, limited liability company, registered in the RNE under number 1681258W, and situated at 23, Rue du lac de Tibériade, 1st floor, office 1_1 Les Berges du lac, Tunis, do act as a data controller, which means that we define the purposes and means of your data processing.
We assume that you reasonably expect that the use of the Platform will require the processing of your personal data. If you do not consent, you may stop using the Platform or oppose the processing of your personal data.
We will never collect your personal data secretly. We will never ask for more than what 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 may share your data,
how long we keep your data
our security measures to ensure the safety of your data
your rights regarding your data processing.
If you are under 16 years old, or if your country's law sets a younger age for valid consent to the processing of your personal data, you will need to obtain your parent's or legal guardian's permission before providing personal data to the Platform.
Personal data (or data) is any information about you that - whether separately or combined with other information - enables a person collecting and processing it to identify you as an individual. This may not only include information about the individual, such as name, address, gender, ethnicity, etc., but it can also consist of technical information about the individual's devices, such as MAC addresses, IMEI, UDID, IDFA, IP addresses, browser information, location information, system information and so on.
Information processing means any action involving your personal data, such as collection, recording, organization, structuring, storage, use, disclosure by any means, and so on.
2 Our legal processing bases
We will only process your personal data if we have a legal basis for doing so such as
the processing is carried out upon your consent;
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 of your data as well as other relevant details before we start the processing of your personal data on the specific legal basis, not listed above, unless we are unable to do so in accordance with our obligations under any applicable legislation.
3 What kind of data we collect, how we process it and for what purposes
3.1 The data you provide to us
This happens when you submit information in various sections or forms available on the platform, such as 'Contact Us' or 'Sign Up' or when you sign up for your account on Groupado Experience. By submitting this information, you are giving us your consent to process it.
3.1.1 Data from your account
We process all data obtained from your account to enable the running of the Platform.
We collect your first and last name or company name (if applicable), email address, phone number, and password as data required for the creation of the account and its 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 required 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 information to enable you to communicate with other users and with us through the Platform or via emails. After receiving messages from us, you have the option to opt-out of these communications in each message, except for legal notices, or to change the Platform's use settings.
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 country of residence, thus making our platform a safe place to share experiences.
3.1.2 Publishing information on the Platform
We collect data that you post when you log in to the platform. This would include information you provide by filling out our surveys or the 'Contact Us' form, information derived from your comments, posts, experience options, etc.
You agree that any information you share will be available to other users of the Platform unless we state 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 send it back 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 the performance of the Platform, customize our Platform to provide you with a more customized experience and draw your attention to information about the Platform.
3.3 Data collected by third parties
When you sign up, we ask you to provide your payment details, namely your credit card details. This data is collected only by the online payment gateways embedded in the Platform such as our bank. Payment providers will only use this information 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 purposes related to the referral program. We retain this information for the purpose of sending emails inviting you to visit the Platform if you are not a user of the Platform and for a follow-up on the effectiveness of our referral program.
4 With whom we share your data
4.1 Access by our employees
We may share your personal data with our employees or verified contractors. For the above purposes, we may share your personal data with these individuals. We will make this processing secure by taking the necessary security and organizational precautions for such disclosure.
4.2 Third parties
We do not transfer your data to third parties in the strict sense. Technically, the data you submit will be processed and stored on proven servers, using approved software such as Amazon Web Services' cloud platforms (AWS S3, EC2, RDS, Code Deploy, Systems Manager). Some information will be shared with other verified and approved services that enable certain critical platform functions, i.e. your financial details may be processed by online payment services.
5 How long do we keep your data
We keep your data for as long as your account is active. 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 information we need in case of any disputes arising between the platform and users or between users themselves.
We do not retain information that has been deleted by you.
As for the data collected for the newsletters, we will keep it for as long as you are interested in receiving our emails. We assume that you are interested until you unsubscribe from the newsletters by clicking on the corresponding link embedded 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 ensure the security of your data. We will also inform users and respective agencies of any personal data breaches if there are high risks of violation of your rights as a concerned person. 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;
Request that we update the personal data we hold about you or correct any personal data that you consider to be incorrect or incomplete;
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);
Allow your data to be read and used in different computer environments by machines and software (right to data portability).
To enforce any of your rights, or if you have any other questions regarding the use of your personal data, please contact us as indicated below.
9 Contact us:
Email address: firstname.lastname@example.org