Privacy policy

DATA CONTROLLER

Your data will be processed by CARLO, located at 10 rue Grimaldi in Monaco (Monaco) and with RCI N° 19P09321.

PURPOSES

The data shall be processed for the purpose of creating a platform that connects consumers and merchants and operates a cashback loyalty program. CARLO will process data to register user on the platform and provide user with the services of the platform.

CARLO will also use your data to improve its services and send you commercial communication to inform you about the latest news related to the app.

DATA SHARING

Provided that you have expressed your consent by registering to the app or by checking the respective boxes for the said purposes provided online, we may process your data to:

  • Send you important information related to our services and our new updates
  • Send you newsletter of CARLO, which shall always be personalized and adapted to your interests
  • Your first name, your last name, and your picture will be shared with other users only in the scope of the referral program; Other users can find you and choose you as referrer, only if you have previously shared your referral code (or the email address you used to sign up).
  • Your first name, your last name, your email address, and your picture will be shared with the user that you have chosen to be your own referrer.
  • Your first name, your last name, and your picture will be shared with merchants from which you made a purchase with our app. Your email address will be shared only if you have explicitly given your consent when signing up.

COMMUNICATION OF DATA

Your data shall not be transferred, sold, rented or made available in any other way to any third party, except to those which supply services to CARLO, which perform certain activities for the business (such as sending the newsletter), but that in no case shall process the data for their own purposes. Some of these suppliers may be located outside of the European Union.

AUTOMATED DECISIONS AND CREATION OF PROFILES

For some services, we may process your personal data using automated methods. This means that certain decisions are made automatically without human intervention.

We may also create a profile by analyzing your behavior on the App, showing you products that may be of interest to you, based on the preferences you have shown through your browsing, or information obtained through cookies.

In addition, if you have agreed to receive commercial communications, these may be adapted and customized according to the interests of the users, either based on the products and services requested, or based on the data that we can deduct or obtain from your browsing, interest in certain contents, reaction to our communications, among others.

INTERNATIONAL DATA TRANSFERS

CARLO, has international suppliers that may provide their services from outside the EU, so it is possible for users’ data to be processed outside the European Union or the European Economic Area (for example, the supplier of newsletter delivery, data storage, management of requests for information or member services, etc.).

In any case, CARLO will ensure that this data processing is always protected with the appropriate guarantees, which may include:

  • Standard EU approved clauses: These are contracts approved by the European regulator, and which provide sufficient guarantees to ensure that the processing complies with the requirements of the European General Data Protection Regulation.
  • Third party certifications: For example, Privacy Shield, the framework agreement between the EU and the United States that establishes a standardized framework for data processing according to the requirements of the European General Data Protection Regulation.

DURATION OF THE PROCESSING

All the data that you provide us shall be treated until you ask for the cancellation of your registration from the app, or when CARLO considers that, by any means available according to the technology available at any time, that you are no longer interested in its products.

After the term indicated in the first paragraph of this section, CARLO shall withhold your data for 3 years for statistical purposes, market analysis, and in order to comply with any legal obligation.

EXERCISE OF YOUR RIGHTS

At any time you may revoke your consent to any of the uses of data indicated above.

Likewise, you may exercise your rights of access, rectification, deletion, opposition, limitation or portability through written communication addressed to CARLO at 10 rue Grimaldi in Monaco (Monaco), with the reference “Personal Data”, or by email to hello@carloapp.com.

Additionally, you may file a claim to the competent Governing Authority if you consider CARLO to have processed your data in breach of this Privacy Policy or any other applicable regulations.

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