RIPPLA (“RIPPLA”, “we” or “us”) is a Portugal company offering SaaS services at its social marketing web platform found at rippla.com (the “Platform”). The Platform provides services for hotels and influencers (“Services”).

 
RIPPLA respects your privacy. This Privacy Policy (this “Policy”) describes how we process Personal Data (as defined below) we gather through in the course of operating the Platform (including if you subscribe to use our Platform, or if you sign up for a free trial), when you interact with RIPPLA, and when you apply for a job at RIPPLA. It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any queries or concerns.

1. Personal Data We Collect

   In this Policy, “Personal Data” means any information relating to an identified or identifiable natural person. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.
   
   Information provided by you
   
   Information provided by Platform users when creating an account. If you use the Platform to find, analyze and contact influencers or hotels (“Users”) for your social media campaigns, we will ask you to provide us with Personal Data including, if you are a hotel - your name, name and location of the hotel, website and authorized email, and if you are an influencer - your name, email and the link to your Instagram open account. We may also ask you to provide us with billing data, such as your bank account, payment card and billing address to facilitate your subscription plan. We will also ask you to create a username and password for access to the Platform.

   When we say a “hotel” we mean an establishment that provides lodging, meals, and other services for travelers and tourists. When we say an “influencer” we mean a person who has an established credibility and audience, and who can persuade others by virtue of their trustworthiness and authenticity.
   
   When you contact us. If you contact us using a contact form, via email, or by other means, you may provide us with Personal Data, such as your name and contact details, the company you work for, and the content, date and time of our communications.

   When you apply for a job. If you apply for a job, you may provide us with Personal Data, such as your educational and professional history, certifications, interests and accomplishments, job and salary preferences, professional resumes and CVs, assessments, and references.
   
   Information collected via automated means
   
   Publicly available information. We collect information about influencers and theiraudience from publicly available resources. This includes Personal Data that the influencer or her or his audience has posted, such as their name, contact details (e.g., email address), location, bio, interests, photos, video and other content. We collect information about hotels and their characteristics and needs from hotels website link to which they provide us. This includes Personal Data that the hotel has posted, such as their name, contact details (e.g., email address), location, bio, interests, photos, video and other content.

   Cookies and similar technologies. We use cookies and similar technologies (collectively “cookies”) to ensure that our website and Platform function properly, to understand how you use those ()s, to improve our products and to assist with marketing campaigns. Cookies are small text files containing a string of alphanumeric characters. We and third-party partners collect information using cookies, pixel tags, or similar technologies. For more information on our use of cookies, please refer to our cookie policy. 
   
   Information collected from other sources
   
   Information from Google. Through our contractors we may obtain Personal Data about you from Google if you choose to sign in using their services. The information we receive from Google may include your name, email address, language preference and profile picture.
   
   Information from business intelligence platforms. Through our contractors we may obtain Personal Data about you, such as your email address, from business intelligence platforms, including LinkedIn, Clay or others.

   Information from influencer analytics. If you are the influencer you understand and agree that for the provision of the Services we may, ourselves or with the help of our contractors (including Yoloco, Modash and others), collect and analyze the data about you (including but not limited to number of followers, engagement rate, popular content, activity, gender, location, interests, lookalikes, brand affinity, contact details) and your audience (including but not limited to their age, gender, cities, countries, interests, language, credibility) in open accounts in social networks.
   
   

2. How We Use Personal Data

   We will only process your Personal Data based on a valid legal ground. Below describes the legal ground by purpose.

   Providing the Platform. We use Personal Data about users of the Platform to operate, maintain, and provide our Platform. For example, we use your Personal Data to create your account, set your preferred language and allow you to login. We have a legitimate interest in using your Personal Data for the purpose of developing, hosting, and maintaining the Platform. 

   Providing insights about influencers through our Platform. We utilize Personal Data concerning influencers and their audiences to deliver insights to hotels via our Platform. For instance, we may analyze the Personal Data of influencers and their audiences to draw inferences (such as estimating their age range, identifying their countries of residence, and understanding their interests). This enables hotels to select suitable influencers for potential marketing collaborations. We have a legitimate interest in using your Personal Data for the purpose of providing insights to hotels, and this interest is not overridden by the interests of influencers.As our customers, hotels have a legitimate interest in the processing of Personal Data to identify influencersthat are suitable for their marketing campaigns.As our customers, influencers give us their authorization under RIPPLA Terms of Service to disclose their Personal Data for the hotels.

   Support. We use Personal Data to provide technical support, including diagnosing and resolving any issues you report. We have a legitimate interest in using your Personal Data for the purpose of providing technical support. 

   Fraud prevention. We use your Personal Data to keep our Services secure and to identify and prevent fraud in the use of our Platform. We need it to comply with a legal obligation, for instance to comply with a court order. We have a legitimate interest in using your Personal Data for the purpose of preventing fraud.

   Customer relationship management. We may process your Personal Data for customer relationship management purposes. We have a legitimate interest in using your Personal Data for the purpose of managing customer relationships 

   Communicating with you. We may use your email address and other Personal Data as necessary to contact you for administrative purposes such as to provide information that you request, to respond to comments and questions, or to ask you to provide feedback and complete surveys. We have a legitimate interest in using your Personal Data for the purpose of communicating with you. 

   Analytics and product development. We use Personal Data about you to analyze usage trends and preferences to improve our Platform, as well as to develop new products, services, features, and functionalities. We have a legitimate interest in using your Personal Data for the purpose of evaluating and improving our products or Services. 

   Marketing. We may process your Personal Data for marketing purposes, such as to develop and provide promotional materials or events that may be relevant, valuable or otherwise of interest to you.You give us consent to do so. We have a legitimate interest in using your Personal Data for the purpose of delivering marketing and advertising materials.

   Administrative and legal purposes. We may use your Personal Data to enforce this Policy, our Terms of Service, to defend our legal rights and to comply with our legal obligations and internal policies. The processing is necessary for entering into, or performance of a contract to which you are a party.We need it to comply with a legal obligation, for instance to comply with a court order. We have a legitimate interest in using your Personal Data for the purpose of addressing administrative and legal issues.

   Recruitment. We use Personal Data about you when you apply for a job at RIPPLA, such as your educational and professional history, certifications, interests and accomplishments, job and salary preferences, professional resumes and CVs, assessments, and references. We have a legitimate interest in using your Personal Data for the purpose of assessing your suitability for employment. 

   Aggregation. We may aggregate or otherwise de-identify Personal Data and use the resulting information for other business purposes, as permitted by applicable law. We have a legitimate interest in using your Personal Data for the purpose of aggregating and de-identifying the data. 
   
   

3. How We Share Your Personal Data

   We may share your Personal Data with third parties in the following circumstances:
   
   Service providers, vendors and analytics partners. We work with third party service providers to operate our Platform, including for IT infrastructure, web analytics and security, communications, payments, project management, customer support and management, marketing, workflow management, recruitment and job applications, and other services. These third parties may have access to or process your Personal Data as part of providing those services to us. In addition, we use analytics service providers such as Amplitude and Google Analytics to collect and process certain analytics data.
   
   Legal. We may disclose your Personal Data to third parties if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose your Personal Data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Platform and any facilities or equipment used to make our Platform available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others.
   
   Merger. We may disclose or otherwise transfer Personal Data to an acquirer, investor, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, financing or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
   
   Consent. We may also disclose your Personal Data with your permission.
   
   

4. Data Retention

   We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we need to retain certain information as required by law, including to comply with tax requirements, or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. When determining the specific retention period, we consider various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations. For instance:
   
   Account data. We will retain your user account data as long as you are an active user, and for three years after that.
   
   Invoicing data. We are legally obliged to keep invoicing data and the documentation on which it is based for ten years.
   
   Backups. We keep backups for as long as you are an active user, and for three years after that.
   
   

5. Your Rights in Relation to Your Personal Data

   Depending on where you reside, you may also have the following legal rights:
   
   Access and Portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us, and request information about its processing.
   
   Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Data, or to have the information anonymized or deleted, as appropriate.
   
   Restriction and Objection. You may ask us to restrict the processing of your Personal Data, or object to such processing.
   
   Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
   
   Complaint. You may lodge a complaint with your local data protection authority, the details of which you can find here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. If you are in the UK, you can contact the Information Commissioner’s Office, who you can contact using the details found at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach a data protection authority, so please contact us in the first instance.
   
   You may exercise these rights by contacting us using the contact details at the end of this Policy. Please note that there are exceptions and limitations to each of these rights.
   
   

6. Third Parties

   Our Platform may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
   
   

7. Security

   We make reasonable efforts to protect your Personal Data by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information, to the extent permitted by applicable law.
   
   

8. Children’s Privacy

   We do not knowingly collect, maintain, or use Personal Data from children under 13 years of age, and no part of our Platform is directed to children. If you learn that a child has provided us with Personal Data in violation of this Policy, then you may alert us by contacting us using the contact details at the end of this Policy.
   
   

9. Cross-Border Data Transfers

   We may use outsourced services in countries outside Europe from time to time in order tosupport our business. If we need to transfer your Personal Data to a country outside of Europe where the level of protection of Personal Data may be different than in your country, we will comply with applicable data protection laws. In particular we will rely on (i) an EU Commission, UK or Swiss government adequacy decision, (ii) contractual protections for the transfer of your Personal Data, or (iii) another valid data transfer mechanism. If you are located in Europe, you may contact us as specified below for more information about the safeguards we use to transfer Personal Data outside of Europe.
   
   

10. Changes to this Policy

    We may update this Policy from time to time to reflect changes in our privacy practices. If we modify this Policy, we will indicate the date of the latest revision at the top of this Policy.
    
    

11. Our contact information

Should you have any queries regarding this Policy, about RIPPLA 's processing of your Personal Data or if you wish to exercise your rights with respect to your Personal Data, you can contact RIPPLA by email: privacy@rippla.com or by writing to us at: Rua dos Murças, n.o 15, 2.o Andar, Sala H, - Funchal, distrito de Ilha da Madeira, concelho de Funchal, freguesia de Funchal (Sé).