Privacy Policy

Identity: PEOOPLE APP, S.L. (hereinafter, the "Company" or the "Provider")

CIF: B16755407

Postal address: Calle Arias Montano 5, 28007 Madrid

Email: hey@peoople.app

Data Protection Delegate: hey@peoople.app PEOOPLE APP , S.L., as Responsible for the platform, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (RGPD) regarding the protection of natural persons in terms of the processing of personal data and the free circulation of these data and other current regulations on the protection of personal data, and by Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSICE), informs you that has implemented the necessary security measures, of a technical and organizational nature, to guarantee and protect the confidentiality, integrity and availability of the data entered. The platform is made up of the website www.peoople.app and the corresponding mobile application (hereinafter, jointly referred to as "Peoople" or the "Platform").

1. DATA PROCESSED

Peoople processes the following personal data wich it accesses in the following ways: a. Data from the Platform Forms and the User Profile: to be able to register as a user of the Application (the “User” or “Users”) and/or perform certain actions on the Platform (for example, to contact Peoople ) the User must complete the electronic registration form that appears on the Platform, providing a series of necessary data for the provision of our services. Access and registration to the Platform is prohibited to those under 18 years of age. Registration is done through the Double Opt-In system, a process by which we establish a double validation system for all those users who register. The user who gives his consent by filling out a form, later accepts again through a confirmation email or an SMS, which will be sent to his email or telephone number. By registering on the Platform as a User, you guarantee that you are of legal age. The personal data collection form specifies the data that users must fill in, and the refusal by users to provide them will imply not being able to register as a User (in the case of the registration form) or You will not be able to perform the determined action on the platform (for example, contact us). Likewise, the fact of being a registered User on the Platform implies having a profile with open fields in which the User can indicate what he deems appropriate (except with respect to the Prohibited Data indicated below). The data requested in the registration form are: (1) e-mail or social network account login data, (2) username and (3) password in the case of using the e-mail to register . When the registration data is extended to become a User with the option of a reward (as detailed in the Conditions of Use), the User must complete a complementary form in which they must add (4) the country of tax residence, (5) their ID number or other document proving your identity, (6) your full name and surname, (7) the province of residence in the case of residents in Spain, (8) the full address in the case of non-residents in Spain and (9) date and place of birth (in the case of non-residents in Spain). The data requested in the contact form are: (1) name and surname, (2) e-mail address, (3) telephone number and (4) message sent. b. Data provided by third-party companies: the User may have the option not to fill out the registration form but to identify themselves on the Platform through user accounts of third-party services such as Facebook, Inc., Apple, Inc or Instagram, LLC. In addition, the web portals to which users are redirected from the Platform (generally e-commerce portals of firms or fashion brands), may send us information indicating that you as a User have made purchases on your own web page influenced by the Platform The User knows that in all these cases these companies will provide us with certain data about the User in accordance with the privacy and/or cookie policies of said companies (which the User has previously consented to). Peoople will make their best efforts not to access more data than is necessary to guarantee a good user experience and proper functioning of the Platform. c. Data automatically processed by the Application: when using the Application, it automatically accesses a series of data and elements of your mobile device on which it is installed. Most operating systems inform the user before allowing the download of the Application and some of them allow the user to limit this access (although they may prevent normal use of the Application). The current version of the Application uses the following accesses (with the treatment of personal data that each access implies): (1) access to the photographs and multimedia files of the device, (2) access to the camera of the device, ( 3) device Wi-fi connection information, (4) device identifier, (5) device country and language settings, and (6) when User enables location services within their device settings, we collect information about the approximate location of your device. d. Data associated with navigation related to the Platform: When a User accesses any of the Platform formats, Peoople collects the browsing data associated with each of the Users. In this way, all the actions carried out by the user within the Platform are collected (for example, seeing another user's publication, saving a product...) associated with the user ID, the IP address, the general information of the device and its operating system/browser, the date and time, as well as the IDs of the rest of the elements associated with that action (for example, the ID of the publication that liked) with the aim of verifying [(i) the effective registration as a User; (ii) obtaining the consent and acceptance of the interested party of this Privacy Policy; (iii) control of foreign or duplicate IPs; (iv) fraud detection, etc. e. Data associated with the Cookie Policy: We use cookies and similar tracking technologies to operate and provide the Platform to you. For example, we use cookies to remember your language preferences, for security purposes. We also use these technologies for marketing purposes. For more information about our use of cookies, see our Platform cookie policy, in web format at https://peoople.app/politica-de-privacidad; and in app format in the "Privacy Policy" section (Profile >> Settings >> Privacy Policy) f. Data from your communications with Peoople: when sending us a communication, we collect the metadata of the same (time and date of the call or e-mail, identity of the sender and receiver, technical data) and the data incorporated in any communication between the User and Peoople. g. Data included in User Content: when posting User Content, we collect any personal data included in such Content (as defined in the "Terms of Use"), which is processed by the company on behalf of and for User account. We collect the content that you have created, shared or published through the Platform, such as: photographs, videos, audio recordings, comments, hashtag or any other identifying sign, information (when, where and who created the published content). We collect User Content at the time you create, upload or import User Content within the Platform, regardless of whether the User chooses to post or share such Content on the Platform. Your location information will be collected if you choose to add location information to User Content that you recommend or share. Regardless of whether you are not a user of the Platform, information about you may appear in content created or published by users of the Platform. h. Data from social networks: If the registration occurs through a social network or connects a Peoople service with it, the User authorizes Peoople to obtain, store and use the personal data of said social network for its treatment in accordance with this Privacy Policy. The data may include the identity or username associated with said social network and any information that allows the social network to share with Peoople, as well as any other personal data that may have been made public through said social network. i. Direct messages. If the User contacts other people through direct messages, we collect the content of the message and the associated metadata (such as the time the message was sent, received or read, as well as the participants in the communication). j. Data provided by advertising, measurement and other partners. Advertisers, measurement partners, among others, share information with us about users and about actions you have taken outside of the Platform, such as your activities on other websites and apps or in stores, including products or services that you have bought These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses, and cookie identifiers, which we use to match you and your actions off the Platform with your Peoople account. Some of our advertisers and other partners allow us to collect similar information directly from their website or app by integrating with our advertiser tools. k. Prohibited data: in any case, it is prohibited to provide Peoople or publish on the Platform, (especially but not exclusively in User Content) any content that contravenes any prohibition and limitation established in the Conditions of use (especially but not exclusively, the prohibition to use personal data -both of the User himself and of third parties- that contain sensitive information related to identifiable or identified persons, such as: racial origin; union membership; religion, ideology or sexual orientation; health data; or data relating to criminal records, proceedings and sanctions or fines derived therefrom or non-compliance with monetary obligations). The user guarantees (a) the authenticity and veracity of all those data (especially but not only those that are personal data) that he communicates through the Platform, (b) that are personal data and the image of his person or who has the permission of the interested party to use said data and has informed of the terms contained herein for this purpose, (c) and who will keep the information provided to Peoople updated, so that it responds at all times to their real situation, being the solely responsible for the false or inaccurate statements that it makes, as well as for the damages that it causes to Peoople or to third parties.

2. PURPOSE OF PROCESSING

Your personal data will only be used for the following purposes:

- Carrying out the necessary commercial and administrative procedures with the users of the platform, allowing them to create, share and view content, interact with other users and their content, as well as offer user assistance.

- Sending or viewing electronic commercial communications. They can be of two types: (a) User Content recommendations or similar that - based on the information that the Platform has about the user is considered to be of interest (as an inseparable aspect of the set of services provided by the Platform for the purpose of principle, that is, it cannot be rejected by the User except by unsubscribing from the Platform) or (b) the periodic remission of electronic commercial communications (e-mails, push notifications -through your mobile terminal- or in -app -included within the application itself-, telephone calls, or through messaging applications, such as Instagram, Whatsapp, Telegram or similar) for promotion or advertising of the services and products offered by Peoople or who offer these same information services or who belong to one or more of the following sectors with the purpose of making offers and promotions of products and services: insurance, business and finance, banking, education, automotive, construction, computing, telephony, technology and telecommunications, consulting, energy and water, health, home, NGOs, fashion, clothing and accessories, hygiene, health, beauty, drugstore, real estate, furniture, collecting, musical arts, retail trade (among others, articles consumption, electronics, garden, toys, children, household appliances, pharmacy and pets), tourism and transport, sports, leisure and entertainment, editorial, games of chance, culture, appointments, events, advertising, surveillance, security, offices and offices, food and drink, hotels, restaurants and others (astrology, genres, resources, ISP, spirituality, information and notifications, exchange platforms, portals, promotion servers, auctions and promotions, web services, social networks). Communications may include links to external pages and promotions offered by brands or companies collaborating with Peoople. - The User will have the option to oppose the receipt of these types of electronic commercial communications and the processing of personal data referred to both in the data collection and in each of the electronic commercial communications). - The monitoring of user activity on the web portals to which users are redirected from the Platform (generally e-commerce portals of firms or fashion brands), including the registration of purchases or possible purchases of products in order to generate rewards in favor of Users and manage the relationship between Peoople and those responsible for said web portals; - Respond to queries and/or provide information required by the User; - Carry out the provision of services and/or products contracted or subscribed to by the User. - Use your data to contact you, by any means, to obtain your opinion about the service provided and, - Notify you of changes, important developments of the privacy policy, legal notice or cookie policy. - Profile and usability analysis will be carried out. To create a profile, we take into account the personal data that Peoople have accessed through the different channels, the behavior of the user through our website or mobile application, the interaction with the electronic communications that we send them. In none of these processes are automated individual decisions made about your data. - The data of clients and/or suppliers will be processed, within the contractual relationship that links them with the person in charge, in compliance with the administrative, fiscal, accounting and labor obligations that are necessary under current legislation. Following Purposes according to category: Category "Data from the Platform and Profile Forms": the Platform may include forms that are clearly linked to specific purposes and so indicate on the Platform itself (for example, the data collected in the "form contact" will be treated for the purpose of responding and communicating with whom you want to communicate with Peoople). Category "Data associated with the Cookies Policy": They will also be processed for the purposes indicated in the Cookies Policy. Category "Data included in the User Content": they will only be treated by Peoople as data processors (not as data controllers) as indicated in clause "13. Peoople as Processor”.

UNSUBSCRIBING FROM THE SERVICE. To unsubscribe, you can go to the application at any time, in the section: Profile, Settings, edit profile, and choose the unsubscribe option. In the event that the previous option was not enabled or did not work for any reason, you can also revoke your consent at any time by sending an email with the subject "User Unsubscribe" to hey@peoople.app, including in the body of the email the user name (username) and the email or username on the social network used when registering on the Platform. In accordance with the LSSICE, in all communications that you will receive from Peoople, the user has the possibility of canceling their express consent to receive such communications. Peoople will not process your personal data for any other purpose than those described except by legal obligation or judicial requirement.

3. LEGITIMACY OF THE PROCESSING

The legal basis for data processing is your prior, informed and express consent granted to carry out the purposes described above, which is requested at the time the user registers on the Platform and accepts the conditions of service. Failure to provide the requested personal data or failure to accept this data protection policy implies the impossibility of subscribing, registering or receiving information on the Provider's products and services. In cases where there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, fiscal, accounting and labor obligations that are necessary under current legislation will be the prior existence of the commercial relationship established between the parties. . In any case, the free and voluntary subscription to the Peoople app is considered the establishment of a contractual relationship between Peoople and the user. Said relationship is based on the provision of information on trends, interests and, in general, on any of the categories on which the recommendations made or consulted by said user may refer (i.e. movies, books, restaurants, fashion, accessories, clothing, etc.) by Peoople to the user. Therefore, the sending of informative communications that fall within this category is considered part of the service contracted by the User at the time of subscribing to the APP. This without prejudice to the fact that the User may, at any time, unsubscribe from communications through the mechanisms enabled for this purpose in the commercial communications themselves or configure their profile so as not to receive them or by writing directly to Peoople through the addresses indicated above. In the case of commercial communications, the legitimizing basis is the informed, unequivocal and express consent of the User. This is voluntary, although without it it will be impossible to provide you with generic commercial communications of services and/or products from Peoople based on your interests and needs and the sectors indicated above.

4. COMMUNICATIONS FROM PEOOPLE

Any communication that is sent will be incorporated into the Peoople systems. By accepting these conditions, terms and policies, the User expressly accepts that Peoople can carry out the following activities and/or actions, unless the User expressly indicates otherwise: Sending commercial and/or promotional communications by any authorized means, informing the Users of the activities, services, promotions, advertising, news, offers and other information on the services and products related to the activity. In the event that the User has expressly consented to the sending of commercial communications electronically by subscribing to the newsletter, the sending of said communications by electronic means informing Users of the activities, services, promotions, publicity, news, offers and other information about the services and products of Peoople that are the same or similar to those that were initially contracted or of interest to the User.

6. RECIPIENTS OF ASSIGNMENTS OR TRANSFERS AND VIEWING CONSENT

Peoople may carry out transfers of personal data for their own purposes, as well as international transfers with the same objective. When registering, new Users are proposed to give their prior, express and informed consent, for their data to be transferred for their own direct marketing. The provider will provide information to the security forces and bodies under court order or by obligation of a legal norm, without prejudice to being able to block or cancel your account if there may be indications of the commission of a crime by the user. The information provided will only be that available at this time to the provider. Users know, consent and are informed that according to their configuration and actions on the Platform some personal data (which the User himself decides what they are) may be consulted or viewed by other users of the Platform in accordance with this Privacy Policy and the Conditions of Use, for the purposes of providing the Service as indicated in the Conditions of Use. The information that you provide us through both the web and the application will be hosted on Peoople's servers.

7. RIGHTS OF DATA SUBJECTS

As an interested User, you can request the exercise of the following rights before Peoople by submitting a letter to the postal address in the heading or by sending an email hey@peoople.app as Subject: "GDPR: Rights affected", specifying the right you wish to exercise. Rights Right of access: allows the interested party to know and obtain information about their personal data submitted to treatment. Right of rectification or deletion: allows errors to be corrected and data that turns out to be inaccurate or incomplete to be modified. Right of cancellation: allows data that turns out to be inadequate or excessive to be deleted. Right of opposition: right of the interested party not to carry out the processing of their personal data or to cease it. Limitation of treatment: involves marking the personal data stored, in order to limit its future treatment. Data portability: allows obtaining the data that Users have provided to a third entity/company/organization in a structured, commonly used and machine-readable format. Right not to be subject to automated individual decisions (including profiling): right not to be subject to a decision based on automated processing that produces effects or significantly affects. As a User, you have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the legality of the treatment carried out before the withdrawal of consent. You also have the right to file a claim with the control authority if you consider that your rights may have been violated in relation to the protection of your data (agpd.es).

8. ADDITIONAL INFORMATION INTELLECTUAL PROPERTY AND IMAGE RIGHTS

Through this Privacy Policy, the User is informed that the photographs that are posted on the platform are the property of Peoople, including those of minors, in which, in order to obtain these, the prior consent of parents, guardians or legal representatives by signing the forms made for this purpose by the centers in which the minors are part. Regarding the image rights of the Users and their realization of any creation or content capable of generating intellectual property rights, by registering and using the Platform, the Users agree to assign the intellectual property rights, as well as the image rights that are referred to Peoople in the terms set forth below. To this end, it is recalled that uploading photographs on the Platform constitutes an act of public communication. Image rights.- In accordance with Law 1/1982 on civil protection, the right to honor, personal and family privacy and their own image, Users assign to Peoople the rights to their image derived from their participation and use in the Platform through, including but not limited to, any means of reproduction, whether electronic (Internet, cd and other analogues) or conventional (paper, photographs and the like), in any currently existing technical or technological medium or system or future (including, by way of example, Internet exploitation; television exploitation in any form; exploitation through mobile telephony or through any other means that is of interest to Peoople), for the maximum time legally permitted and for the world territory to be used for advertising, commercial or similar purposes legitimately linked to the public projection of Peoople as well as its exposure in public events of any kind. Participation in the platform and, where appropriate, the acceptance of the privacy policy by the User implies the express authorization by the User of the assignment of rights set forth herein. The use and publication of the images and data of the Users according to the above does not generate or grant reimbursement, fee payment or economic rights of any kind for the User.

9.- SOCIAL NETWORKS

Peoople expressly informs the User that they can have a presence on social networks. The treatment of the data that is carried out of the people who become followers in the social networks (and/or carry out any link or connection action through the social networks) of the official pages of Peoople will be governed by this section. , as well as those conditions of use, privacy policies and access regulations that belong to the social network that is appropriate in each case and previously accepted by the user. Peoople is not responsible for the security or privacy of information collected by such third parties. Therefore, it is recommended, in advance, to consult the privacy policies of said social networks before giving your consent. Peoople will process your data for the purpose of correctly managing your presence on the social network, informing you of the provider's activities, products or services. The publication of content is prohibited: - That are allegedly illegal by national, community or international regulations or that carry out allegedly illegal activities or contravene the principles of good faith. - That violate the fundamental rights of Peoople, lack of courtesy in the network, annoy or may generate negative opinions in our users or third parties and in general whatever the content that Peoople consider inappropriate. - And in general that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of private life, consumer protection and intellectual and industrial property rights. Likewise, Peoople reserves the right to withdraw, without prior notice from the corporate social network, those contents that are considered inappropriate. The communications sent through social networks will be incorporated into a file owned by Peoople, being able to send information of interest to you.

10. SECURITY MEASURES

The data provided to Peoople by Users will be treated confidentially. The Provider has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the treatment of the data and to avoid its alteration, loss, theft, treatment or unauthorized access, according to the state of the technology and nature of the data stored. Likewise, it is also guaranteed that the treatment and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in current regulations and the current state of technology. We periodically review our security measures to include new technologies and methods available.

11 DATA RETENTION PERIOD.

Your data will be kept for the duration of the commercial relationship with us or you exercise your right to cancel or oppose, or limit treatment. However, we will keep certain personal identification and traffic data for a maximum period of 2 years in the event that it is required by the Judges and Tribunals or to initiate internal actions derived from the improper use of the website or the application. You will not be subject to decisions based on automated processing that have effects on your data.

12.SEND CV

In the event that the User sends his CV through our website enabled for this purpose https://peoople.factorialhr.com/, he is informed that the data provided will be processed to make him a participant in the selection processes that may be , carrying out an analysis of the applicant's profile in order to select the best candidate for the vacant position of the Manager. This is the only official procedure to accept your CV, so CVs submitted by a different procedure will not be accepted. In the event of any change in the data, the User will be asked to communicate it in writing as soon as possible, in order to keep their data duly updated. Likewise, the offers will also be published on Peoople's social networks. However, the CV can only be sent through the website enabled for this purpose. The data will be kept for a maximum period of one year, after which the data will be deleted, guaranteeing the User full respect for confidentiality both in the treatment and in its subsequent destruction. In this sense, after the aforementioned period has elapsed, and if you wish to continue participating in the selection processes of the Responsible, you will be asked to submit your CV again. The data may be processed and/or communicated to the member companies of our group during the time your resume is kept and for the same purposes previously reported.

13. PEOOPLE AS PROCESSOR OF TREATMENT AND INTERNATIONAL TRANSFERS

The User in his use of the services provided by Peoople through the Platform and his use of the Platform may include, through User Content, personal data of third parties or his own in said User Content (“Content Data” ). Said User is solely responsible for this Content Data, as "Responsible for the Treatment". Peoople provides a service for the treatment of this information on behalf and account of the User, as "Treatment Manager" for the purpose of allowing the use of the Platform and providing the services offered through the Platform. To the extent that Peoople is a "Processor", (a) it implements technical and organizational measures to safeguard the Content Data from any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) only processes the Content Data in accordance with the instructions provided by the User, which include the configuration of their User Account and indications ("clicks" on the Platform) regarding this specific material, (c) does not use the Content Data for purposes other than those related to the development of the Services or in accordance with the instructions provided by the User, (d) does not communicate the Content Data, not even for its conservation to third parties (this does not prevent that, if the instruction of a User is that a User Content must be public and subject to recommendations, logically Peoople complies with said instruction and allows access to the Users of said Content Data and may even recommend the display of said User Content). With the cancellation of the account and request for cancellation of the User's data, Peoople will stop using any Content Data, which will be destroyed. Peoople reserves the right to save such Blocked Content Data before deleting it for as long as Peoople may be held liable for such data processing. If you discover that another User uses your old Content Data in Peoople without authorization, you must inform Peoople of this, since Peoople does not monitor, edit or control User Content. The User responsible for the Content Data authorizes us, as Data Processor, to allow access and processing of said Content Data to one or more service providers (data hosting and messaging), as a subcontractor on his behalf. , if we reasonably consider that said access and treatment is necessary for the development of the Services. These providers process the data for the sole purpose of providing us with the aforementioned services that we have indicated and are currently the Google group (whose subsidiaries with possible access to the data would be: (i) Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland, (ii) Google Asia Pacific Pte. Ltd., with offices at 8 Marina View Asia Square 1 #30-01 Singapore 018960, or (iii) Google Inc., with offices at 1600 Amphitheater Parkway, Mountain View, California 94043, (in Ireland, Singapore and the US respectively) Amazon group (whose affiliates with possible access to the data are (i) Amazon.com, Inc. in the US and (ii) Amazon Web Service Ireland Ltd in Ireland); or the Facebook group (whose affiliates with possible access to the data are (i) Facebook, Inc., with offices at 1601 S California Ave; Palo Alto, California 94304 and (ii) Instagram, Inc. , with offices at 1601 Willow Rd; Menlo Park, California 94025) Countries in which data may be processed that are outside the European Economic Area (all of them except Ireland) may not have personal data protection rules. equivalent to the Spanish/European ones). Before this treatment occurs, a contract has been signed with said third parties that offers sufficient and necessary guarantees oriented in accordance with the legislation for the treatment carried out by those third parties on our behalf and guarantee that it is in accordance with the applicable provisions of this Policy. The User responsible for the Content Data declares and guarantees to have all the necessary consents of the Peoople whose personal data is provided and shared, which will be treated in accordance with this clause (including even the International Transfer of data of this subcontracting or to other users of the Platform of other countries to which access). The User, responsible for the Content Data, will indemnify Peoople and hold it harmless in relation to any claim, damage or loss that they may suffer that is related to the processing of personal data of third parties processed in accordance with this clause.

14. CHANGES TO THIS PRIVACY POLICY

Peoople reserves the right to modify this policy to adapt it to new legislation or jurisprudence. In the event that said modifications are related to the consents requested, we will request your consent again. In any case, the modification of the privacy policy will be notified in general to Users.

15. LEGISLATION

For all purposes, the relations between Peoople and the Users of its telematic services, present on this Platform, are subject to Spanish legislation and jurisdiction to which the parties expressly submit, being competent for the resolution of all derived or related conflicts. with its use the Courts and Tribunals of Madrid. Last updated: December 02, 2024