General Privacy Policy

Only the French and Spanish language version of the General Confidentiality 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 process your personal data in the context of the business relationship that we will have with you as a partner merchant of Carlo (Merchant). Your personal data will be treated confidentially and only for the purposes to which you have consented or which are necessary for the carrying out of our commercial relationship.


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) To manage your registration as a merchant on the Carlo platform, as well as to provide you with all the corresponding services, including the acceptance of electronic payments. 

b) This processing is based on the contractual relationship that reads us in the context of the acceptance of the general conditions of sale and your use of the application.

vs) 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 and being able to respond to your various requests.

d) Send you commercial communications about contracted services or new services we may offer to you, including electronically. 

e) Perform statistical analysis to improve our services and products. 

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. . 

In order to provide our payment services, the Merchant must create a payment account with the Lemonway payment institution (Lemonway SAS, Carlo takes care of creating the account, but certain personal data may be made available to Lemonway and will be processed for its own purposes, as a payment service provider regulated by the ACPR - Banque de France. This communication is made within the framework of the contractual obligations assumed between you and Carlo for the use of the service.

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) Surname and first name, as well as any other professional information, such as your function, your telephone numbers, your postal or professional electronic addresses, and any other information that you provide to us in the context of our commercial relationship (for example, the contact details of employees authorized to use Carlo, etc.) 

b) First and last name, company, email address and any other information you can provide to us in case of doubt or question. 

vs) Likewise, depending on the relationship maintained, we will process professional data, economic, financial or banking data, traffic and location data, etc. 

d) In order to manage the payment services and therefore meet our contractual obligations, we must manage the following data, which will be communicated to Lemonway so that it can also manage your account: name and surname, identity card, passport or equivalent ( and therefore the data contained in said document), RCI, address, mobile or landline telephone number, email, company statutes and articles of association, as well as the bank details that you provide us to use the Carlo service. 

e) To improve our products, we may use, in addition to application usage data, technical information collected from the devices with which you use Carlo, such as IP address, cookies, geolocation, analysis of use of the web or applications (frequency of visit, pages visited, operating system and other unique data related to your activity. In this case, you will be informed via the application. 

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.  

By default, 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, certain data may be communicated to Lemonway, the payment service provider responsible for carrying out all the payment transactions necessary for the operation of the application. Lemonway will process your data as an independent data controller. The data communicated are those indicated in section 4 above and Lemonway will treat them in accordance with the provisions of its own privacy policy, available on its website.

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.

7. 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 updated on: 02/11/2021

Download the General Privacy Policy here.