Retreeb - Privacy Policy

Privacy Policy (12/12/2023)

Retreeb (the "Company" or "we") respects the privacy of our users (the "User" or "you") and is committed to protecting the information collected through our Consumer Wallet and Retailer Wallet mobile applications (the "Apps"). This Privacy Policy explains how we collect, use, and disclose information through the Apps. This Privacy Policy applies both to users of the application or the website and Retreeb Customers. For the latter, General Terms and Conditions of Retreeb apply.

We may update this Privacy Policy from time to time in order to reflect changes in our practices or for other operational, legal or regulatory reasons. Your data is retained for as long as your account is active or as needed to provide you with the services. After that point, as mandated by the GDPR, personal data is deleted after 2 years. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce agreements.

1. INTRODUCTION

Retreeb appreciates your trust. We are Lithuanian company, please read this Privacy Policy, providing consent to both documents in order to have permission to use our services.

2. DATA COLLECTED

DATA STORAGE LOCATION

We operate web servers hosted in Ireland. Our hosting provider AWS adheres to the Swiss DPA, the EU/US “Privacy Shield”, ensuring that your data is securely stored and GDPR compliant.

REGISTRATION DATA

If you register on our website, we store your chosen username and your email address and any additional personal information added to your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit this information.

If you have registered on our website and have a valid support account, you can submit support tickets for assistance in the contact form.

When you leave comments on the website we collect the data shown in the comments form, and also the IP address and browser user agent string to help spam detection.

CONTACT FORM

Information submitted through the contact form on our site is sent to our company email, hosted by Webflow.

CASES FOR USING THE PERSONAL DATA

ntergiro is the data controller for the personal data processed in connection with provision of payment services. Retreeb is Intergiro’s processor for the purpose of e.g. displaying account information, balance and historic transactions in the app/web portal. Please refer to the data processing agreement to be entered into between Retreeb and Intergiro for more information. Retreeb is an independent data controller for the personal data processed in connection with its provision of first line customer support. If Retreeb requires assistance from Intergiro’s second line customer support, Retreeb will share the relevant personal data with Intergiro as an independent data controller. Intergiro may share personal data for performance analytics with Retreeb under Intergiro’s Data as a Service. Retreeb will be an independent data controller for such data. Retreeb may use this data to see how the services work and performance, but not for other purposes. If Retreeb provides any other services to Customers, Retreeb is the data controller for any processing of personal data relating to such services.

We use your personal information in the following cases:

- Verification/identification of the user during website usage;
- Providing Technical Assistance;
- Sending updates to our users with important information to inform about news/changes;
- Checking the accounts’ activity in order to prevent fraudulent transactions and ensure the security
- over our customers’ personal information;
- Customize the website to make your experience more personal and engaging;
- Guarantee overall performance and administrative functions run smoothly.
- Onboarding : When creating a Retreeb account, we will collect certain personal information such as your phone number, name, birthdate, email address, referral code (if any), and chosen access code. This information is used to verify your identity and provide you with access to the features of the App.
- Projects : When choosing a charitable project to support, we may collect information about the project and its progress. We may also collect information when you make a donation or give a voucher to a project.
- Adding/Removing Funds : We may collect information to verify your identity during the Know Your Customer (KYC) process when adding or removing funds from your account. This may include information such as your name, address, and government-issued identification. We may also collect information about the method of payment used, such as bank transfer or credit card.
- Menu : We collect information when you modify your account information, such as your name, email, and language preferences. We may also collect information when you contact our support team.
- Map of Merchants : We may collect information about merchants who use Retreeb in your area, including their name, type, address, and contact information.
- Payment : When making a payment, we may collect information about the merchant, the amount, and any vouchers used.
- History : We collect information about your transaction history, including the date, merchant, and amount.
- Business Onboarding : When creating a Retreeb account for a business, we will collect information about the business, including its category, name, address, type, and contact information. We may also collect information about the business owner, including their name and contact information.
- Invoicing : When generating a payment QR code, we may collect information about the transaction, including the amount and date.
- Data Security : We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data

3.EMBEDDED CONTENT

Pages on this site may include embedded content, like YouTube videos, for example. Embedded content from other websites behaves in the exact same way as if you visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged-in to that website.

Below you can find a list of the services we use:

None

4. COOKIES

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymized tracking data to third party applications like Google Analytics. Cookies generally exist to make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser.

4.1. Technical or functional cookies‍

Some cookies ensure that certain parts of the website work properly and that your user preferences remain known. By placing functional cookies, we make it easier for you to visit our website. This way, you do not need to repeatedly enter the same information when visiting our website and, for example, the items remain in your shopping cart until you have paid. We may place these cookies without your consent.

4.2. Statistics cookies

We use statistics cookies to optimise the website experience for our users. With these statistics cookies we get insights in the usage of our website. We ask your permission to place statistics cookies.

4.3. Advertising cookies

On this website we use advertising cookies, enabling us to personalise the advertisements for you, and we (and third parties) gain insights into the campaign results. This happens based on a profile we create based on your click and surfing on and outside retreeb.io, retreeb.com, retreeb.fr . With these cookies you, as website visitor are linked to a unique ID, so you do not see the same ad more than once for example.

4.4 Marketing/Tracking cookies

Marketing/Tracking cookies are cookies or any other form of local storage, used to create user profiles to display advertising or to track the user on this website or across several websites for similar marketing purposes.

Because these cookies are marked as tracking cookies, we ask your permission to place these.

4.5 Social media

On our website, we have included content to promote web pages (e.g. “like”, “pin”) or share (e.g. “tweet”) on social networks. This content is embedded with code derived from third parties and places cookies. This content might store and process certain information for personalised advertising.

Please read the privacy statement of these social networks (which can change regularly) to read what they do with your (personal) data which they process using these cookies. The data that is retrieved is anonymised as much as possible.

NECESSARY COOKIES (ALL SITE VISITORS)

Cookies site :‍

Cookie depository partner	Description of the partner	List of partner cookies used on the site	Purpose	Cookie category	How long the partner keeps these cookies (Days)
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hs_opt_out	Registers the user's consent so that the user is no longer asked to accept cookies. Defined when the site offers the choice of refusing cookies.	Strictly necessary	180
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hs_do_not_track	Prevents tracking code from sending information to HubSpot.	Strictly necessary	180
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hs_initial_opt_in	Prevents the banner from displaying visitors browsing in strictly necessary mode	Strictly necessary	7
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hs_cookie_cat_pref	Records the categories to which a visitor has consented. Contains data on the categories accepted on the consent banner.	Strictly necessary	180
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	hs_ab_test	Provides visitors with the same version of an A/B test page. Contains the ID of the A/B test page and the ID of the variant selected for the visitor.	Strictly necessary	Expires at the end of a session on the site
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	<id>_key	Set so that a visitor does not have to log in again if they return to the same password-protected page using the same browser. Creates a unique cookie name for each password-protected page. Contains an encrypted version of the password so that visitors do not need to re-enter the password on future visits.	Strictly necessary	14
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	hs-messages-is-open	Determines whether the chat widget is open and saves the information for future visits. Set in the visitor's browser when they start a new chat, resets and closes the widget after 30 minutes of inactivity. Prevents the widget from reopening on subsequent page loads in the browser for 30 minutes, if the visitor has manually closed the chat widget.	Strictly necessary	Expires in 30 minutes
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	hs-messages-hide-welcome-message	Prevents the welcome message from reappearing on the same day after being rejected once.	Strictly necessary	1
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hsmem	Records a visitor's connection to a site hosted on HubSpot. Identifies the user member when they are connected.	Strictly necessary	7
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	hs-membership-csrf	Guarantees that member connections cannot be falsified. Contains a random string of letters and numbers used to verify the authenticity of the connection.	Strictly necessary	Expires at the end of a session on the site
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	hs_langswitcher_choice	Stores the language selected by the visitor when viewing pages in multiple languages. Defined when a visitor selects a language using the language selector and is used as a language preference to redirect them to sites in the chosen language, where applicable.	Strictly necessary	720
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__cfruid	Defined by HubSpot's content delivery network provider, due to its throughput limitation policies.	Strictly necessary	Expires at the end of a session on the site
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__cf_bm	Defined by HubSpot's content delivery network provider and is required to protect bots.	Strictly necessary	Expires in 30 minutes
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hstc	Contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (current visit) and session number (increases with each subsequent session).	Analytics	180
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	hubspotutk	Keeps track of a visitor's identity. Transmitted to HubSpot when a form is submitted and is used to deduplicate contacts.	Analytics	180

Cookie depository partner	Description of the partner	List of partner cookies used on the site	Purpose	Cookie category	How long the partner keeps these cookies (Days)
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hssc	Keeps track of sessions. Used to determine whether HubSpot should increase the session number and timestamp data in the __hstc cookie. Contains the domain, the number of views (incremented for each session), with a timestamp from the start of the session.	Analytics	Expires in 30 minutes
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	__hssrc	Set to determine if the visitor has reset their browser when HubSpot changes the session cookie. If this cookie is not present when HubSpot processes cookies, the session is considered new.	Analytics	Expires at the end of a session on the site
Hubspot	Centralises visitors' browsing behaviour to define a database of customers and prospects used for CRM (Customer Relationship Management) campaigns.	messagesUtk________	Used to recognise visitors who chat with you via the Chatflows tool. If the visitor leaves your site before being added as a contact, this cookie will be associated with their browser.	Functional	180

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Sdk apps

Retreeb also use Software development kit (SDK) packages that may have an collect some information. All the information collected by the SDK are non personal. Please find the relative privacy policies on the SDK websites.‍

NECESSARY COOKIES (ADDITIONAL FOR LOGGED IN CUSTOMERS)- NONE

5. WHO HAS ACCESS TO YOUR DATA

If you are not a registered client or you have not sent us any information, there is no personal information we retain or view regarding yourself. If you are a client with a registered account, your personal information can be accessed by:

- Our system administrators.
- Our supporters when they (in order to provide support) need to get the information about the client accounts and access.
- Intergiro support.

6.THIRD PARTY ACCESS TO YOUR DATA

We don’t share your data with third-parties in a way as to reveal any of your personal information like email, name, etc. The only exceptions to that rule are for partners we have to share limited data with in order to provide the services you expect from us. Please see below:

- Google
- Hubspot
- Asana
- Onesignal

7. HOW LONG WE RETAIN YOUR DATA

When you submit a support ticket or a comment, its metadata is retained until (if) you tell us to remove it. We use this data so that we can recognize you and approve your comments automatically instead of holding them for moderation. Compliant with the EU Law, we remove data for non registered users automatically after two years, even though cookies may remain, if you don’t delete them, on your computer.

If you register on our website, we also store the personal information you provide in your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit that information.

8. SECURITY MEASURES

We use the SSL/HTTPS protocol throughout our site. This encrypts our user communications with the servers so that personal identifiable information is not captured/hijacked by third parties without authorization.

In case of a data breach, system administrators will immediately take all needed steps to ensure system integrity, will contact affected users and will attempt to reset passwords if needed.

9. YOUR DATA RIGHTS

Intergiro AB (Sweden) is the data controller for the personal data processed.

You have the following rights with respect to your personal data:

- You have the right to know why your personal data is needed, what will happen to it, and how long it will be retained for.
- Right of access: You have the right to access your personal data that is known to us.
- Right to rectification: you have the right to supplement, correct, have deleted or blocked your personal data whenever you wish.
- If you give us your consent to process your data, you have the right to revoke that consent and to have your personal data deleted.
- Right to transfer your data: you have the right to request all your personal data from the controller and transfer it in its entirety to another controller.
- Right to object: you may object to the processing of your data. We comply with this, unless there are justified grounds for processing.

GENERAL RIGHTS

If you have a registered account on this website or have left comments, you can request an exported file of the personal data we retain, including any additional data you have provided to us. In most cases, this file will be empty, as we only collect data among our customers (see general Terms and Conditions for the relevant case).

You can also request that we erase any of the personal data we have stored. This does not include any data we are obliged to keep for administrative, legal, or security purposes. In short, we cannot erase data that is vital to you being an active customer (i.e. basic account information like an email address).

If you wish that all of your data is erased, we will no longer be able to offer any support or other product-related services to you.

We comply with the Swiss Data Protection Act ( 235.1 Bundesgesetzüber den Datenschutz)

GDPR RIGHTS

Your privacy is critically important to us. Going forward with the GDPR we aim to support the GDPR standard. Retreeb permits residents of the European Union to use its Service. Therefore, it is the intent of Retreeb to comply with the European General Data Protection Regulation. For more details please see here: EU GDPR Information Portal.

10. THIRD PARTY WEBSITES

We don’t integrate third party websites into our website.

All social media sharing links, either displayed as text links or social media icons do not connect you to any of the associated third parties, unless you explicitly click on them.

Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties or require disclosure of any personal information relating to members of the Service or Site. Retreeb bears no responsibility for the information collected or used by any advertiser or third party website. Please review the privacy policy and terms of service for each site you visit through third party links.

11. RELEASE OF YOUR DATA FOR LEGAL PURPOSES

At times it may become necessary or desirable to Retreeb, for legal purposes, to release your information in response to a request from a government agency or a private litigant. You agree that we may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of a civil action, criminal investigation, or other legal matter. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you, and release your information to, third parties where we believe that it is prudent to do so for legal reasons, such as our belief that you have engaged in fraudulent activities. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants.

Any passing on of personal data for legal purposes will only be done in compliance with laws of the country you reside in.

12. AMENDEMENTS

We may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will update this page accordingly and require you to accept the amendments in order to be permitted to continue using our services.

13. CONTACT

If you have any questions about this Privacy Policy or our data practices, please contact us at support@retreeb.com.

Please note in case Retreeb support is not available, you can refer to Intergiro Support (see intergiro.com) as a second line of support. Intergiro will not answer non-support (for instance commercial or marketing) related questions.