General Privacy Policy

Only the French language version of the General Privacy Policy is authentic between the parties and may be produced in court.

1. Introduction 

The right to privacy, and more particularly the right to the protection of personal data, is one of the values of Carlo Technologies (hereinafter Carlo). 

The purpose of this privacy policy is to explain how Carlo will treat your personal data as a controller. Your personal data will be treated confidentially and only for the purposes for which you have consented or which are necessary to provide you with our services.

2. Commitment to respect for privacy 

Compliance with the General Data Protection Regulations of the European Union and the regulations relating to the protection of personal data in force and applicable, constitutes a priority objective for Carlo. 

For this reason, we make sure to implement the following principles, confidentiality being the basis on which all processing is set: 

● Transparency in data processing is one of our priorities. Thus, each time we collect personal data concerning you, we duly inform you of the purposes of this processing. 

● We will always process the data that is strictly necessary to carry out the informed processing. 

● We will never require you to provide personal data, unless it is really necessary to provide you with the service you request. 

● Where possible, we will provide you with easy ways to keep track of your personal data. 

● We will not share data with third parties, with the exception of providers who provide us with a service that requires the processing of your personal data and who will process it on our behalf, or with third parties of which we have previously informed you and for whom , where applicable, you have given us your consent.

3. Purposes of processing. 

Carlo collects your personal data in order to manage your use of the application and to offer you the services and products that may be of interest to you. More specifically, we process your personal data for the following purposes:  

To) Manage your registration as a user on the Carlo platform, as well as provide you with all the corresponding services, including the payment platform through the company LEMONWAY SAS (, which will process your data. payment directly and without Carlo having access to it. 

b) Carry out any action enabling us to comply with our legal obligations in the fight against money laundering and the financing of terrorism. This processing is based on our legal obligations in this area.  

These treatments are based on the contractual relationship that reads us as part of the acceptance of the general conditions of sale and your use of the application. 

vs) To manage your preferences based on the information you provide to us and your activity or transactions in businesses using Carlo, which helps us to personalize the services, offers or promotions we offer to you. 

d) Manage your participation in the various promotions or contests that are organized either by Carlo or by member businesses. 

e) You invite to events or activities organized by partner companies. 

f) Deal with your queries, questions or requests made through customer service or the communication channels identified on each web page and contact you to resolve them.

These treatments are based on our legitimate interest and in particular the monitoring of the commercial relationship, to provide you with specific offers and to be able to respond to your various requests. 

g) You send commercial communications about contracted services or new services we may offer you, including electronically. 

h) Perform statistical analyzes on the use of Carlo in order to improve our services and products, based on the interests and preferences of our users. 

i) Send your first and last names and email address to partner merchants only if you agree to their transmission. 

These treatments are based on your consent which you can withdraw at any time by sending your request to the following address under the conditions of article 7.

Likewise, provided that you give us your consent at the time of registration, we may send you electronic commercial communications by email, sms or even through direct messaging applications such as Whatsapp, Telegram or similar. We may also show you information or advertisements from our services by using services offered by social networks or internet services (Google, Facebook, Twitter, among others), which allow us to create personalized audience groups.

These services, called “personalized audiences”, allow the company that owns the data of subscribed users (in this case, Carlo), to share email or telephone with social networks. This is done after encrypting the information, so that the social network cannot know the identity of the user, but can check whether it is registered in the social network by a unique identifier. Once the data is included in the social network, Carlo cannot know the identity of the members who make up the group, which therefore has no direct effect on your privacy. 

These services, as we have indicated above, allow us to show specific content to users who, having agreed to receive our commercial communications, are also users of the corresponding social network, appearing as an advertising publication and duly identified. 

Another service offered by social networks, within the framework of these “personalized audiences”, consists in creating audiences with users whose preferences are similar to those of the contacts shared by Carlo, so that their data is used to generate a model of common preferences, but they are not the target of the advertisement, but will be the users of the social network in question with a similar profile. 

To perform the aforementioned services, Carlo and the social network in question use their own data which they pool to offer a common service, acting as co-responsible for the processing of advertising, in accordance with the provisions of this privacy policy and that of the social network itself, which we recommend that you read carefully and periodically. Likewise, and without prejudice to your right of opposition to Carlo, we remind you that you can personalize the way in which social networks use your data for advertising purposes by accessing your user profile.

If you are not a social media user, you don't need to worry, as your data will not be used for advertising purposes. 

To learn more about these services, you can consult the following links: 

• 3376494 



These links may change over time, and without prejudice to Carlo's reasonable efforts to keep them up to date, you can access this information by accessing the legal conditions of the social network in question, or by searching in any browser for “personalized audience” and the name of the social network concerned. 

As a rule, we always process data on the basis of our contractual obligations to you or in order to comply with applicable legal provisions.  
When we want to process data that is not necessary, or for a purpose unrelated to our commercial relationship, we will always inform you of the basis of legitimacy that we apply and, when we need your consent, we will expressly ask you for it. . 

No profiling or automated decision-making is carried out in this context.

4. The data we process. 

In order to carry out our business activities with the objectives indicated in the previous point, we will process the following data. 

To) First and last name, date of birth, address, telephone number and e-mail address, as well as your login details, necessary for the creation of the user account. 

b) First and last name, email address or mobile phone number, for sending electronic commercial communications. 

vs) Other personal information that you provide to us during the registration process, such as your age or gender, information about social media accounts, friends or contacts if you provide the data to us or allow access contacts on your device, etc. 

d) Recording of transactions made, including the amount and trade where the transaction was made, as well as the management of rewards and discounts linked to your user account to facilitate payment transactions. 

e) Based on the use of the Carlo app for purchases in participating businesses, we will be able to integrate the businesses you frequent into your profile, in order to personalize offers and promotions. 

f) Surname and first name, email address and any other information that you can provide us to answer your requests in case of doubts or questions. 

g) Through information on the use of the application and during its use, technical data such as the IP address, geolocation, statistics of use of the web or of the application through cookies (for more information, access our cookies policy), the device used, etc. 

Carlo respecting the principle of minimization, the collection of the data listed above is mandatory so that we can provide you with the expected services and offer you personalized offers.

5. Data communication.  

Carlo does not market, sell, rent or in any way disclose personal data to other third parties for their own purposes. 

However, we can make them available to service providers, who process the data on our behalf and only for the purpose of providing us with the corresponding service (maintenance of the application, sending communications, etc.), always within European Union or in countries considered equivalent in terms of data protection by the European Commission. Carlo ensures that these service providers present sufficient guarantees and put in place appropriate technical and organizational measures to guarantee the security and confidentiality of your data. 

In addition, your data is communicated internally to Carlo teams who must ensure the operation of the application, its maintenance and its upgrades. 

Likewise, as indicated in section 3 above, payment data will be processed directly by Lemonway, which will process it directly with you, without any data communication from Carlo to Lemonway. 

Finally, as indicated in section 3 above concerning advertising on social networks, Carlo and the corresponding social network will act as co-responsible for the processing, which implies prior communication of the data to this social network.

Your personal data is not transferred outside the Principality of Monaco or the European Union. Nevertheless, it is specified that in the event of a transfer outside the European Union and/or to a State that does not have adequate protection, you will be informed as well as the list of the subcontractors concerned. In any case, the measures taken to organize these transfers of personal data will be in line with the GDPR, namely the creation of standard contractual clauses and/or the implementation of specific security measures (encryption, rights of specific accesses, password policies etc.). To obtain a copy of the contractual conditions of the aforementioned subcontractors, you can send us a request at the address If these conditions are available digitally, a link will be made available to you. 

6. Duration of treatment and storage period 

At Carlo, we are committed to processing personal data for as long as is actually necessary to provide the services to you. Therefore, we will process them for as long as you remain an active user on our Carlo platform. 

Once our relationship has ended, we will keep your data for a maximum period of 5 years to comply with our legal, fiscal and / or accounting obligations and for the defense or exercise of claims. After this period, we will block your data (or isolate them from processing systems), keeping them for a maximum period of 15 years from the end of the contractual relationship, and only available to judges and courts or authorities. competent.

We would like to point out that the personal data used in the context of processing related to the fight against money laundering and the financing of terrorism are kept for 5 years from the end of our contractual relationship. 

7. Security and confidentiality measures

Carlo implements technical and organizational measures to ensure the security and confidentiality of the personal data processed by us.

Thus, you will find below a summary of the main measures implemented:

– Implementation of specific cybersecurity documentation (security insurance plan, specific policies, etc.)

– Awareness of our employees and confidentiality commitments

– Securing workstations and our development tools (antivirus, test environments)

– Protection of our network and data hosting in the Principality of Monaco

– Backup and implementation of a business continuity plan


8. Exercise of rights and complaints to the competent authority 

Data protection law guarantees all data subjects a number of rights over their personal data, so that you can maintain control over them. At Carlo, we fully respect all of these rights, so here is a brief explanation of each to make it easier for you to exercise them: 

1. Right of access: you have the right to know what personal data we are processing about you and the reasons for which we are processing it. 

2. Right of rectification: Your data will always be yours and, as such, you can ask us to rectify them at any time if the data in our records are incorrect. 

3. Right of deletion: You can request, at any time, that your personal data be deleted from our files. However, and as we have indicated in the section on data retention above, please note that, in certain circumstances, compliance with applicable law may prevent the effective exercise of this right, or limit its effectiveness. scope (e.g. we might delete your user data, but not existing information that we manage for contractual, billing, etc.) 

4. Right to object: You can object to the processing of your data in relation to one of the purposes for which we process your data, in accordance with the privacy policies applicable in each case, and provided that such processing is not strictly necessary. to the execution of the contract or the regulations in force.

5. Right to restriction of processing: You can request restriction of processing in the following cases: 

To. If you believe that the information we are holding about you is not correct or accurate; 

b. If you believe that we are not processing your data legitimately, but prefer that we limit the processing of your data to its deletion; 

vs. If the data we hold is no longer necessary for the purpose for which we collected it, but you need us to keep it to assert legal claims; 

d. If, after exercising your right to object to any processing, you expect a response from us. 

6. Right to data portability: You have the right, where technically possible and reasonable, to request that the personal data you have provided to us directly be disclosed to another data controller. If we can do so, we will provide your data directly to that other controller, but if not, we will provide it to you in a standard format. 

Insofar as we process some of your data on the basis of your consent, you can revoke your consent at any time without this having any consequences for you other than, depending on the right exercised, not to be able to you provide certain services. 

You can exercise your rights by contacting Carlo by one of the following means 

(i) By e-mail to be sent to

(ii) By mail, to Carlo's address at 6 avenue Albert II (Monacotech), Monaco 98000 

In case of reasonable doubt about your identity, we may ask you for a copy of your identity card or an equivalent identification document. 

If you do not wish to exercise a specific right, but you need to formulate a question or a suggestion concerning the processing of your personal data, you can also contact the address provided for the exercise of rights.

Please note that you can always, in any case, lodge a complaint with the relevant data protection authority if you believe that we have not processed your data in a lawful manner or that we have not complied with your requests. or your rights.

Last update on: 05/05/2023

Download the General Privacy Policy here.