Privacy Policy

Effective as of: 15-10-2019
Last updated on: 20-09-2019

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

The terms in this document have the same meaning as in our Terms of Use.

We (GROUPADO DMCC., registered under the law of Emirates of Dubai, United Arab Emirates) act as Data controller that means that we determine the purposes and means of the processing your data.

We presume that you reasonably expect that the use of the Platform requires processing of your personal data. Should you disagree, you are free to stop using the Platform or object to personal data processing.

We never collect your personal data in secrecy. We never request more than reasonably required for the respective purpose.

In this document you will find out:
  • what data we process, how and for what purposes we process your data,
  • when and how we can share your data,
  • how long we retain your data
  • our protection measures to keep your data secure
  • your rights in respect of processing your data.
If you are under 16 or if the laws of your country set lower age for your viable consent for the processing of your personal data you will need to get your parent’s or guardian’s permission before providing any personal data to the Platform.

1. Definitions

Personal data (or data) is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to a person that collects and processes such information to identify you as an individual. It can be not only information on the person like name, address, gender, racial or ethnic origin etc., but also technical information on person’s devices like MAC-addresses, IMEI, UDID, IDFA, IP-addresses, browser information, information about location, system information.

Processing of the information means any action with your personal data, for example,collection, recording, organizing, structuring, storage, use, disclosure by any means and so on.

2. Our lawful bases for processing

We will process your personal data only when we have lawful bases such as:

  • processing is based on the consent you give us;
  • processing is necessary to provide you the opportunity to use the Platform according to our Terms of Use;
  • processing is necessary for the purposes of the legitimate interests, including, for example, our legitimate interest for marketing or ensuring safety, or those prescribed by the data protection legislation, those necessary to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us. As regards this lawful basis, you have the right to object to such processing.

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

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

3.1. Data you provide us with

This occurs when you submit information in different sections or forms available at the Platform, such as “Contact us” or “Sign up” 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 the data obtained from your account to enable the functioning of the Platform.

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

You are free to choose whether to submit further information on your profile not specifically necessary for the registration.It may include photos, address, ID information, passport, license, certificate. We may use this information to offer you relevant Experience Options.

We also use your data from your account to enable you to communicate with other users and with us through the Platform or emails. Having received communications from us, you are able to opt-out to such communications in each message, excluding legal notices, or change the user setting on the Platform.

We can use your name and email for sending you newsletters or our commercial or promotional information about our Platform by email or via social media services such as Facebook, Instagram or other well known platform in the market, You may always opt-out from our marketing messages, using the mechanisms described under the respective link in each message, and through the user settings available on the Platform or social media services.

To verify the identity of account holder we request to submit a scan of your ID-card or other equivalent document confirming your legal capacity under the laws of your residency as well as to make our Platform a safe place to share Experiences.

3.1.2 Posting Information on the Platform

We collect data that you post being signed in on the Platform. It includes information you fill in our surveys or“Contact Us” form, information from your feedback, messages, Experiences Options etc.

You acknowledge that any information you share will be available to other users of the Platform unless otherwise specified by us.

3.2. Automatic collection (cookies and similar web technologies)

When you use our Platform website or application, we can automatically receive the information from your device and send the information back to improve your interaction with the Platform and ensure its effective functioning.

We process such data based on your explicit consent, enabling us to collect the cookies identifiers.

We use such data to assess the Platform performance, customize our Platform to provide you with a more personalized experience and draw your attention to information regarding the Platform.

Please, specifically refer to our Cookies Policy for further details as to our use of cookies and similar technologies.

3.3. Data collected by third parties

When you sign up, we ask you to provide your payment, namely credit card details.These data are collected only by online payment gateway integrated into the Platform such as PayPal and/or our bank.Payment providers will use this information only to help us verify your identity and to make payments via the Platform.

We can collect your name and email obtained from our ambassadors for referral program purposes. We store 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. With whom we share your data

4.1. Access by our employees

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

4.2. Third parties

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

5. How long we retain your data

We store your data as long as your account is in use. In case you are banned or you decide to delete your account or simply stop using it we will keep your data for additional 12 months to ensure we have information in case there are any kinds of disputes between the Platform and the Users or between the Users.

We do not retain the information that was deleted by you.

As to data collected for the newsletters, we will store them as long as you are interested in receiving our emails. We consider you interested until you unsubscribe from the newsletters by clicking the respective link contained in each of our emails or by application of relevant settings in your user account.

6. How we protect your data

We use data encryption for keeping your data secured. We also will inform the Users and the respective agencies of personal data breaches should there be high risks of violation of your rights as data subjects. We would also do our best to minimize any such risks.

7. Your rights

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

  • obtain confirmation that we process your personal data and request a copy of the personal data we hold about you;
  • ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
  • ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
  • object to our processing of your personal data. and withdraw the consent (if the consent is the legal ground for such processing);
  • obtain your data in a way that can be read and used in different IT environments by the machines and software (right to data portability).

We are committed to responding to any verified User as regards any issues arising from this Privacy Policy or applicable data protection laws. We are committed to responding within a reasonable time, bearing in mind the possibility to extend the time to respond up to 24h by virtue of complexity and number of the requests. In any event, we will inform you of any such extension.

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

8. Changes to this Privacy Policy

We may amend or update this Privacy Policy from time to time, updating “Last modified” date at the top of this Privacy Policy and adding the details to the “Key changes” section below. Your further use of this Privacy Policy will confirm your acceptance of this Privacy Policy. Should you disagree with this document you have to stop using the Platform.

9. Contact information

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

GROUPADO DMCC., registered under the law of Emirates of Dubai, United Arab Emirates

Contact email:

Groupado Loader