Shaaare - Privacy Policy (English version)

Last updated: March 2024

We invite you to carefully read this privacy policy to understand our practices regarding the collection, processing, and retention of your personal data when using our Services.

The website https://shaaa.re and the mobile application Shaaare are published by Smartness SAS, a simplified joint-stock company with a share capital of €1,100, having its registered office at 40 Rue Alexandre Dumas, 75011 Paris, France, registered with the Paris Trade and Companies Register (hereinafter "the Company" or "we").

For any complaint or question relating to this privacy policy, you can contact us at the following email address:
legal [at] shaaa.re, or fill out this form.

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1. Definitions

To ensure a precise and unambiguous understanding of the terms used in this Privacy Policy, the following definitions are applied:

Application or Platform: refers to the Shaaare mobile application, which is made available to users on iOS, MacOS, and Android operating systems.

Account or User Account: refers to the personal space created and dedicated to the User within the Application. This space is accessible following the registration and login of the User, conditioned by the acceptance of this Privacy Policy.

Service(s): encompasses all the features, services, and content offered by the Company via the Website and the Application.

Website: corresponds to the website accessible at https://shaaa.re.

XKO: represents the internal cryptocurrency developed specifically for the Application's ecosystem. The XKO token is used as a means of financial transaction for all operations carried out within the Application.

Brand Tokens: refers to tokens issued by the Company's partner brands, also in the form of cryptocurrency, allowing Users to be rewarded for specific content.

Wallet: designates the digital wallet integrated into the Application, where Users can store and manage their XKO and Brand Tokens.

Score: rating, expresses the number of points assigned to content by AI analysis, serving as a criterion for the allocation of Rewards.

Reward(s): includes all forms of compensation or benefits granted to Users in exchange for their Brand Tokens or XKO. This includes, without limitation, gift cards, virtual objects, cash prizes, vouchers, discounts, support for humanitarian or ecological projects, as well as other goods or services available through the Application.

Information: refers to a set of data that may include, without limitation, personal data.

2. The information we receive and collect about you

We collect the information you provide to us directly, in addition to that resulting from your use of our Services, which is stored on Supabase servers located in Europe.

2.1 Data you share directly

To fully benefit from the Application, certain crucial information is necessary from registration: your phone number, your date of birth, a username of your choice, a profile picture.

After creating your account, you also have the option to provide us with additional information to enrich your profile: your first and last name, your email address, a brief introduction about yourself.

The content data you share using the Application, including: photos, videos, support given to other users (Shaaare Power), comments, geolocation data.

It is imperative to always keep in mind that the content shared on the Application can be seen by other users with whom you interact. The latter can potentially save your content on their device without us being able to intervene to prevent it, notably through screenshots. Therefore, we recommend that you do not share content that you would not want to be disclosed or used by others.

Communications with us: messages you send us, reports you make.

2.2 Data Collected During the Use of our Services

When using our Services, as is the case for most online services, information about you is automatically collected via your device and your interaction with our Services.

Technical and connection data: date of creation of your account, IP address, date and time of your last login, information about the equipment and connection point used.

Interaction Data:

Information about your profile: the list of your subscriptions and subscribers, the total number of posts.
Details related to posts: reactions received, comments, scores assigned, date and time of creation.
Information about blockchain transactions performed: the wallet address of the transaction recipient, the amount transferred, list of tokens transferred, unique transaction identifier "hash", associated private notes, status, date, cost of transaction fees.
Details about your wallet: the number of tokens held, transaction history, the date of saving the mnemonic phrase.
Information about deletions or blocks you perform.
Geolocation data.

To optimize your experience of the Application, we implement a monitoring tool, specifically Sentry, which provides us with additional information, including: information about the device used and its operating system, details about the application's execution environment, data related to the use of the application and user interactions with it, information about errors or incidents that occurred during the use of the application.
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This information allows us to continuously improve the quality of the Application and offer an optimized user experience. For any questions regarding the management of your personal data, please contact us.

We also collect data when you decide, if you wish, to use certain features of the Application:

Cameras and Photo Gallery: access to the camera and/or Photo Gallery is necessary for creating or adding a profile picture, which is mandatory for using the Application.

Geolocation Data: You can choose to share your location when you post content via the Application.

Directory Data: You have the option to allow the Application to access your contact directory in order to identify friends who may already be on the platform. We will not access your directory without your explicit consent. If you choose to search for your friends by allowing us to access your directory, we only analyze the phone numbers (without accessing other information), securely transmit these numbers to our systems, and then compare these numbers to those of other users of the Application. In case of a match, we suggest the associated username as a friend suggestion.

‍KYC Verification:
For conducting KYC (Know Your Customer) verifications, essential for validating your identity on the Application, we have established a collaboration with Stripe. We invite you to review Stripe's terms of use by following this link.

It should be noted that, in certain countries, the KYC verification procedure is mandatory to access the Application.

3. Data Collected on the Blockchain

The blockchain is a fundamental element in the functioning of our Services, offering a series of significant advantages, including process automation, transaction transparency, and enhanced security.

This revolutionary technology allows transactions to be recorded in an indelible manner, thus ensuring unprecedented traceability and reliability.

It is crucial to understand that any data recorded on the blockchain remains permanent and unalterable. This means that each transaction, once made, is permanently recorded on the blockchain without the possibility of modification or deletion.
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No sensitive or personal information is stored on the blockchain from our Services. This approach ensures that although transactions are transparent and secure, user identities remain protected.

4. Use of Your Personal Data

With the main objective of providing you with access to the services available on the Application and ensuring a secure, enjoyable, and high-quality user experience, it is essential for us to access, use, and/or share your personal data. For an in-depth understanding, please refer to the detailed enumeration below of the purposes for which your data may be processed.

4.1 Management of your relationship with us and access to Application features

Creation and management of your user account, including access to the Application's services and customer support. Depending on your geographic location, parental consent may be required for you to access our services.
Enabling your use of the features offered by the Application, such as viewing or publishing content, assigning a score to content published to remunerate it, which includes analyzing the content to determine quality and relevance, obtaining and using Rewards, or sending them to other users, as well as the opportunity to become a "verified" profile.
Presentation, when appropriate, of offers and content that may be of interest to you.
Processing and responding to your requests, inquiries, and complaints submitted to our support service.

4.2 Optimization of our services and user experience

Analysis of your use of our services, identification of preferred or less appreciated features to develop statistics on the use of our application and evaluate them.
Design and development of new features within the Application, including conducting tests prior to the deployment of new features.
Identification and resolution of technical problems you may encounter to ensure smooth use of the Application.
Management of our communication and marketing actions, including community animation on the platform and conducting internal statistical studies.
Suggestion of your profile to other users and presentation of profiles that may match your interests, based on your settings, location, activities, and information contained in your profile.
Continuous improvement of the user experience, technical functioning of the application, and interaction between users on the Application.

4.3 Offering tailored services and access to specific information from your device

Authorization to access your photo gallery, camera, and microphone to allow you to publish images and videos on the Application.
Sending push notifications to inform you about new features of our services, security updates, as well as interactions and messages from other users, to keep you informed of relevant activities.

4.4 Strengthening online security and maintaining platform integrity

We rigorously enforce our policies to moderate content and behaviors that violate our Terms of Use. This involves monitoring your activity and behavior on the Application to identify and intervene in case of security incidents. Measures taken may include sending warnings, removing or filtering inappropriate content, requesting verification of your account, or temporarily or permanently suspending your account. Decisions significantly impacting your access to the Application, such as permanent suspension, are made in accordance with our internal policies by our moderation teams. We also use automatic filters to prevent users from being exposed to content deemed inappropriate. Additionally, security measures may be activated in response to reported behaviors on third-party platforms.
We develop and implement automatic detection technologies to identify violations of our terms and manifestly illicit content. These technologies analyze published content, including text, photos, and videos, to identify violations of our guidelines. Our goal is to identify and intervene as quickly as possible against violent content, the use of illicit substances, child abuse, as well as unwanted, sexually explicit, hateful, or discriminatory content, even before they are reported. These tools enhance our moderation capabilities and help us respond promptly in case of a proven violation.

4.5. Compliance with Legal Obligations and Cooperation with Authorities

We have implemented a reporting system directly accessible via the Application, allowing each user to alert us about content or profiles deemed non-compliant with our Terms of Use. Any report you make will be thoroughly examined by our moderation teams, who will determine the appropriate actions to be taken with regard to the incriminated content or users.
Our collaboration with the competent authorities is essential for the eradication of illicit content on our platform. We are committed to removing or restricting access to such content as soon as we become aware of it. We are also willing to report certain offenses to the competent authorities and retain the data necessary for conducting judicial investigations, in response to official requests.
We ensure compliance with all applicable legal and regulatory obligations. This includes the diligent processing of your requests concerning the exercise of your rights related to the protection of your personal data, in accordance with the applicable legislation on privacy and data protection.

5. Retention period of your personal data

5.1. Validity Period of the User Account

We retain your personal data for the period strictly necessary for the provision of the services offered by the Application.

You have the option to delete your account at any time by accessing the Application settings and selecting the "Delete my account" option. The deletion of your account will be effective after a 30-day reflection period, during which you can cancel the deletion request. After this period, your account will be permanently deleted, making your profile inaccessible and invisible to other users.

Furthermore, your account will be automatically deleted in case of prolonged inactivity on the Application, i.e., if you do not log in for a continuous period of two years.

5.2. Specific Retention Periods

The personal data we collect is subject to varying retention periods depending on its nature and purpose:

The information related to your account and your content will be completely deleted upon the deletion of your account on the Application.
Interactions with our support team, following your requests, may be retained for a period of up to 5 years after their resolution. This measure helps us track our customer support interventions and establish an adequate defense in case of a complaint or legal proceeding.
Data collected via additional tracking tools, such as Sentry (mentioned in section 2.2), will be erased 30 days after the deletion of your account.
The information recorded on the blockchain, as well as your wallet and the tokens it contains, will remain indelible. Blockchain technology, by its nature, does not allow the deletion of data once it is recorded. However, you have the option to continue using your wallet by importing the security phrase (mnemonic). We strongly advise you to keep this phrase in a safe place, outside the Application, before deleting your account. Please note that we do not have any access to this key and are therefore unable to restore your wallet.
Regarding the data collected by Stripe for KYC (Know Your Customer) verification, we invite you to consult Stripe's terms of use for more information on their retention policy.

Notwithstanding sections 5.1 and 5.2 above, certain personal data may be retained for an additional period in case of a legal obligation to do so. Similarly, the retention of personal data may be necessary for the resolution of a dispute or for the exercise or defense of our legal rights.

6. Persons with whom we share your data

6.1. Data we share

Company Personnel: Our authorized employees access and process your personal data within the framework of the purposes established in section 3, as well as for the provision of services. They are subject to strict confidentiality obligations and can only access your information in a limited manner, according to their specific functions.
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Service Providers: Some of your personal data may be shared with our service providers, who contribute to the operation and improvement of our services. This includes, for example, hosting our services, performance analysis, content moderation, detection of violations of the Terms of Use, user support, and development of new features. We ensure that we only collaborate with trusted providers who offer strong data protection guarantees and are subject to rigorous contractual obligations regarding security and confidentiality.

Change of Control: In the context of a reorganization, merger, acquisition, bankruptcy, dissolution, restructuring, sale of assets, or any other change of control or financial structure, your personal data may be transferred to another entity. The protection of your data will remain governed by this Privacy Policy.

Affiliated Companies: Your information may also be shared within our network of affiliated companies, with the aim of assisting in the provision and improvement of our services, in accordance with the objectives described in section 4.

Defense of our Rights: To protect our interests, we may disclose your data to courts, government authorities, lawyers, or other competent parties in case of litigation or legal obligations, in compliance with our Terms of Use or to preserve our rights.

Legal Obligations and Public Safety: In accordance with the law, we may be required to provide your data to law enforcement agencies or administrative entities to respond to judicial requests, ensure the safety of individuals, maintain public order, or protect our rights and those of others.

Partnerships with Brands: We may share certain data with our business partners for the purpose of rewarding you for your engagement and content creation on the platform.

6.2. Data you share

The information, text, images, or videos you share on the Application are considered your personal data. It is essential to be cautious about the information and content you choose to share online.

It is important to note that we are not able to restrict you in sharing your data when using our services, nor regulate the use that other users may make of it after receiving it.

7. Data transfers outside the European Union

As part of our services, we may use analytics and notification service providers located in countries outside the European Union, which have not been recognized by the European Commission as offering an adequate level of data protection. These countries, such as the United States, Madagascar, and the United Kingdom, may not offer the same level of data protection as that in force in Europe. In such circumstances, we take the necessary measures to ensure that these transfers are carried out in accordance with the applicable regulations and by taking all the required legal, technical, and operational precautions to protect your data.

For any questions regarding these data transfers, we invite you to contact us at the following email address:
legal [at] shaaa.re, or fill out this form.

8. Data security

We have implemented strict security measures to protect the confidentiality, integrity, and availability of your personal data. The nature of these measures varies according to the sensitivity of the information processed, always aiming to provide adequate protection against identified risks.

Despite our sustained efforts to secure our network and systems, it is important to keep in mind that the challenges and vulnerabilities associated with the Internet can sometimes exceed our security controls. This is why your vigilance is essential. We strongly encourage you to maintain the confidentiality of your identifiers, such as your password and mnemonic phrase.

The mnemonic phrase, a unique set of words generated during the creation of your wallet, is crucial for recovering your tokens if you lose access to your account. Therefore, it is vital to keep it in a safe place, separate from your electronic devices or online accounts.

We ask you to inform us immediately if you suspect any security breach related to your account.

9. Cookies and tracking technologies

Our Services may also automatically collect standard information about users through cookies that allow visitors to be identified.

The cookies we use primarily allow us to collect and analyze statistics such as the number of visits, unique visitors, pages viewed, or to produce other global statistics on the activities of our Services. These cookies are provided by third-party providers.

Instructions for deleting all cookies are also available at: http://www.allaboutcookies.org/manage-cookies/

For more information on cookies, consult the website of the Commission Nationale de l'Informatique et des Libertés (CNIL): http://www.cnil.fr/vos-libertes/vos-traces/les-cookies/

10. Your rights regarding your privacy

In accordance with European regulations on the protection of personal data, you have the following rights:

A right of access allowing you to know at any time whether or not your personal data is being processed by our services and, when it is, to have access to said personal data and to the information required by law concerning the methods of processing this data;
A right of rectification allowing you to request that any inaccuracy concerning your personal data be corrected as soon as possible;
A right to erasure, allowing you to request as soon as possible that your personal data be erased when (i) its retention is no longer necessary in view of the purposes for which it was collected (ii) you have objected to the processing and therefore wish it to be erased (iii) the data has been subject to unlawful processing; (iv) the data must be erased to comply with a legal obligation provided for either by European Union law or by French law;
A right to the limitation of the processing of your personal data (i) when you contest the accuracy of the personal data collected for the duration necessary to verify the accuracy of the data, (ii) when, following processing established as non-compliant, you prefer the limitation of processing to the complete erasure of the data (iii) when the personal data is no longer necessary for the purposes of the processing but is still necessary for the establishment, exercise or defense of legal claims; (iv) when you have objected to the processing and you wish to have the processing limited for the duration necessary to verify whether the legitimate reason invoked is justified;
A right to portability allowing you to receive your personal data in a structured, commonly used and machine-readable format, or to request that this personal data be transmitted to another data controller, provided that this request for portability relates to personal data that you have directly provided and concerning you and that this request for portability does not infringe on the rights and freedoms of third parties;
A right to object to the processing of your personal data for reasons relating to your particular situation, and the processing in question will then be terminated unless there are legitimate and compelling reasons justifying its continuation in accordance with the applicable regulations;
The right to define directives relating to the retention, erasure and communication of your personal data after your death;
In the event that the processing of your personal data is based on your consent, you also have the right to withdraw this consent at any time.

These rights can be exercised by contacting us directly at the following email address legal [at] shaaa.re, or by filling out this form.

Complaints relating to the use of your personal data may also be addressed to the Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX.