Privacy Policy & Cookies

Article 1: Alowaa

Alowaa attaches great importance to the protection and respect of your data and privacy.

This Privacy Policy, like our Terms and Conditions, informs you of all our practices regarding the collection, use, and sharing of information that you provide to us through the Platform.

We invite you to read this document carefully in order to know and understand our practices regarding the processing of your personal data that we implement.

Article 2: Collected information

Alowaa may collect and process the following data:

The information transmitted directly by the Member

By using the Platform, the Member is led to send us information, some of which is of a nature to identify him/her. This is the case in particular when filling in forms when participating in promotional offers, studies or surveys, when making complaints, or when contacting us by telephone, email, or any other means of communication.

This information contains the following data:

The identity of the Member (information required when registering on the Platform, without this information the Member will be unable to use the Platform). The identity contains the Member's first and last name, e-mail address, telephone number, date of birth, and password.

A photograph

A postal address

His biography

All exchanges between the Member and another Member, Partner or Alowaa.

A copy of all reservations or publications made on the Platform.

Details of financial or accounting transactions carried out on the Platform or by any other means, including payment card information, bank details, information relating to Events reserved or for which the Member has published an Advertisement on the Platform.

Details of his visits to the Platform and the content he has accessed.

Answers or comments left to evaluate a Partner or a Member, this information being in particular likely to be used in the context of research and analysis of user behavior.

The data that the Member provides in the event of a complaint or report of a problem relating to the platform or our services.

The data related to its location when it has previously agreed to their collection and processing.

2. Data collected automatically

In the situation where the Member connects to the Platform via a social network (Facebook, Twitter or Google), Alowaa will have access to certain data in his or her account such as his or her first and last name, profile photo, email address, and the number of Facebook friends in accordance with the general terms and conditions of use of the social network used. Alowaa is also likely to collect some of its Personal Data when the Member interacts with features of these social networks, such as the "Like" features.

During each of the Member's visits, Alowaa may collect, in accordance with applicable legislation and with the Member's consent, if applicable, information relating to the devices on which the Member uses our services or the social networks from which the Member accesses our services, such as, in particular, IP addresses, connection data, operating systems, and platforms, data concerning his or her browsing path on the Alowaa Platform, in particular his or her path on the various Alowaa URL pages, the content that the Member accesses wherever he or she consults, the search terms used, download errors, the duration of consultation of certain pages, the advertising identifier of his or her device, interactions with the page and any telephone number used to contact us. Among the technologies used to collect this information, Alowaa uses cookies (see charter below article ...).

Alowaa also collects information on the Platform Member's use of the Platform (such as the number of ads published, the response rate to messages, the date of registration, etc.) which may be displayed on its public profile.

Upon proof of the Member's identity and if the conditions for exercising these rights are met, the Member may exercise his or her right of access, right of rectification, right of deletion, right to limit processing, right of opposition, right to lodge a complaint with the CNIL and right to determine the fate of his or her data after his or her death.

3. Data Retention

The Personal Data are archived for the following durations:

5 years after the last use of the Platform, if the Member has not closed his account.
1 year after account closure, unless the Member has received a negative notice or a report, in which case his data will be kept for 2 years.
Alowaa reserves the right to keep its Personal Data for a longer period following the last negative notice or report received by the Member.

Alowaa also reserves the right to keep the Member's Personal Data for different durations for the following data:

Financial data (used for payments or reimbursements) are kept for the duration required by applicable tax and accounting laws.
The contents created by the Member on the Platform (comments, opinions, and ratings) are made anonymous after the above-mentioned periods but remain visible on the Platform.

In the event that the Member's account has been blocked or suspended, we keep his data for a period that may vary from 2 to 10 years from the date of suspension, in order to avoid any circumvention by the Member of the rules in force on the Platform.

4. Goals of Personal Data Collection

Alowaa collects Personal Data from Members for the purpose of :

Execute the contracts concluded between the Member and Alowaa and our business partners and provide the information and services requested.

Send information to the Member about our services (reservation confirmation for example) by email, SMS or any other means of communication. This processing is necessary for the performance of our respective contractual obligations and/or carried out with the Member's consent.

Collect payments from the Member or transmit the sums collected on behalf of the Partner.

Allow the Member's profile to be personalized on the Platform. This processing is carried out on the basis of the Member's consent.

Enable the Member to communicate and exchange with other Members of the community or Partners.

To give the Member access to and allow him/her to communicate with the Platform's Member Relationship Service. This processing is necessary for the performance of our respective contractual obligations, carried out with the Member's consent and/or necessary for the ascertainment, exercise, or defense of a right in court.

To ensure compliance with applicable legislation, our general terms, and conditions of use, and our privacy policy. In the event of breach by the Member, Alowaa reserves the right to suspend his or her Platform Account. This processing is necessary for the performance of our respective contractual obligations, carried out with the Member's consent and/or necessary for the establishment, exercise, or defense of a right in court.

To send the Member, in accordance with the applicable legal provisions and with his or her agreement when required by law, marketing, advertising, and promotional messages and information relating to the use of our services, the booking terms and conditions, or to suggest and advise him or her of goods or services that may be of interest to him or her. We may use your data to send you advertising messages that may be of interest to you on social networks or third-party sites. If the Member would like more information on this subject, we invite him/her to read the contractual documents of these platforms. This processing is based on his consent and/or the legitimate interest of Alowaa.

In order to inform the Member of the modifications made to our services/platform. This processing is necessary for the execution of our respective contractual obligations, to comply with our legal obligations, and/or to ascertain, exercise, or defend a right in court.

To manage the Platform and carry out internal technical operations in the context of problem-solving, data analysis, tests, research, analysis, studies, and surveys. This processing is based on our legitimate interest in order to ensure the security of the Platform and improve its characteristics.

To improve and optimize the Platform, in particular, to ensure that the display of our content is adapted to the Member's device. This processing is in our legitimate interest.

Allow the Member to use the functionalities of our services if he or she wishes to do so.

To help us maintain a healthy and secure environment on the Platform and to evaluate the effectiveness of the advertising messages we send and adapt them to the Member. This processing is based on Alowaa's legitimate interest (ensuring the security of the Platform and measuring and optimizing the effectiveness of our campaigns), necessary for the observation, exercise, or defense of a legal right and or on the consent of the Member.

Article 4: Recipients and purpose of the Member's Personal Data transmission

As part of the use of our services, some of the Member's information is passed on to other Community Members or Partners authorized to publish Events on the Platform, via his public profile, or as part of the booking process.

Alowaa also works closely with third-party companies that may have access to the Member's Personal Data and more specifically with :

Social network platforms may offer functionalities allowing the Member to integrate information from his Account into his Alowaa profile on his own platform.

Alowaa Business Partners on whose website we may possibly advertise Alowaa services.

The subcontractors we use for technical services, payment services, identity verification, or providers of analytical solutions.

We only share Member data with the third parties mentioned above in the following cases:
- When Alowaa uses a service provider as part of the execution of any contract concluded between the Member and Alowaa or in order to provide or improve our services.
- As part of the reservation process, in order to provide the requested services, we may display on the Platform or transmit to another Member some of his or her Personal Data such as the Member's first name, photo, telephone number, or e-mail address.
- Alowaa publishes the notices drafted by the Member within the framework of our notice system on the Platform. These notices, which contain the Member's First Name, Last Name, and photograph are visible to all visitors to the Platform.

When we use suppliers of search engines and analytical solutions to improve and optimize the Platform.

When the Member expressly requests it (authentication methods provided by social networks for example), subscribes to a service provided by one of our Partners, requests to benefit from an offer or a good plan from our Partners.

When Alowaa distributes, on the website of our Business Partners, certain parts of our Platforms via APIs or widgets. In this case, certain information from the Member's profile may be displayed on these sites.

When Alowaa is legally obliged to do so or if we believe in good faith that it is necessary to do so in order to respond to any claim against Alowaa, to comply with any legal request, to enforce any contract concluded with our Members, such as the Terms and Conditions and this Privacy Policy, in the event of an emergency involving public health or the physical integrity of a person, in the context of investigations and inquiries, or in order to guarantee the rights, property, and safety of Alowaa, its Members and more generally any third party.

In the event that we sell or acquire a business or assets, in which case we reserve the right to share your Personal Data with the potential seller or buyer of such business or assets.

If Alowaa or any part of its assets are bought by a third party, the data in our possession will, where applicable, be transferred to the new owner.

In accordance with applicable legislation and with the consent of the Member when required, we may aggregate data concerning you that we receive or send to our commercial partners, in particular all or part of your Personal Data and information collected through the use of Cookies. This aggregated information will only be used for the purposes described above.

We draw attention to the fact that if the Member decides to let us access some of his information, in particular his Personal Data, through connection services made available by our Business Partners, their confidentiality policies are also enforceable against him. We have no control over the collection or processing of the Member's data implemented by our Business Partners on their own platform.

Article 5: Use and moderation of Member's messages

Alowaa reserves the right to review messages exchanged between Platform Members for the purposes of fraud prevention, improvement of our services, user assistance, verification, and compliance by our Members with the contracts concluded with Alowaa and the Terms and Conditions. For example, in order to prevent a Member from bypassing our online reservation system, we authorize ourselves to browse and analyze the messages exchanged on the Platform in order to ensure that they do not contain any contact details or references to other Internet sites.

Alowaa never takes cognizance of communication between Members for promotional purposes or advertising targeting. Whenever possible, we use automated systems to moderate the messages transmitted between Members via the Platform, without any individual decision being taken.

Article 6 Targeted advertising, e-mails, and SMS

In accordance with applicable legislation and with the Member's consent when required, Alowaa may use the data that the Member provides on the Platform for commercial prospecting purposes (for example, to send our newsletters, send invitations to our events, or any other communication that may be of interest to the Member and to display targeted advertisements on social networks or third party sites).

With regard to promotional emails: The Member may withdraw consent at any time by un-checking the relevant box in his or her account, clicking on the unsubscribe link provided in each of our communications or by contacting us as described in Article 13 below.

With respect to Targeted Advertising:

On social networks (e.g. Facebook and Twitter), the Member may object to such processing at any time by configuring the advertising settings of the Member's Account.
On third-party sites: the Member may refer to the Cookie Policy below to understand how to withdraw consent.

Article 7: Process for the transfer of Members' Personal Data

As a general rule, Alowaa will keep the Member's Personal Data within the European Union. However, to the extent that, for example, some of our service providers are located in countries outside the EU, we transfer some of its Personal Data to Third Countries. This may be the case in particular to Third Countries for which the European Commission has not taken a decision of "adequate protection". In such a case, Alowaa ensures that this transfer is carried out in compliance with the applicable regulations and guarantees an adequate level of protection of the privacy and fundamental rights of individuals (in particular through the standard contractual clauses of the European Commission).

Article 8: The Member's rights over Personal Data

The Member has the right to receive a copy of his Personal Data in our possession ("right of access").

The Member may also request the deletion of its Personal Data as well as the correction of erroneous or obsolete Personal Data ("right of deletion and right of correction"). Please note that Alowaa is likely to keep certain information concerning the Member when the law requires it or when we have a legitimate reason to do so. For example, if Alowaa suspects that the Member has committed fraud or violated our Terms and Conditions and we wish to prevent the Member from circumventing the rules applicable to the Alowaa community.

The Member also has the right to oppose at any time for reasons relating to his or her particular situation, the processing of his or her Personal Data for direct marketing purposes or processing carried out on the basis of our legitimate interest ("right of opposition").

The Member has the right to limit the processing carried out on his Personal Data ("right of limitation"). Please note that this right only applies if the Member challenges the accuracy of his or her Personal Data during the period of time during which Alowaa is able to verify the accuracy of the Personal Data: in the event of unlawful processing on our part and the Member requires a limitation of their use rather than a deletion, Alowaa no longer needs the Personal Data for the purposes of the processing but they are still necessary for you to establish, exercise or defend your rights in court, in the event that you exercise your right to object during the period of verification as to whether the legitimate grounds that Alowaa is pursuing prevail over yours.

The Member has the right to lodge a complaint with the competent supervisory authority or to obtain redress from the competent courts if the Member considers that Alowaa has not respected his or her rights.

The Member also has the right to the portability of its data, i.e. the right to receive the Personal Data that the Member has provided to Alowaa in a structured, commonly used, and machine-readable format and the right to transmit this data to another data controller ("right to portability").

The Member has the right to define guidelines regarding the fate of his or her Personal Data after your death.

Article 9: Cookies and similar technologies

Alowaa ("we", "us" or "our") uses cookies in order to offer the Member an improved and more personalized web service. Through this Alowaa Cookie Usage Charter, we present to the Members how and why we use cookies on the Platform, in all transparency.

Cookies definition and function

A cookie is a small text file saved and/or read by your browser, on the hard disk of the Member's terminal (PC, laptop, or smartphone, for example) and deposited by the websites that the Member visits.

2. Cookies on Mobile Applications

There are no cookies on mobile applications. The applications use the unique identifiers of the Member's mobile phone (hereinafter "Mobile Identifiers") to identify his or her device. These Mobile Identifiers are stored in the user's device and accessible on the Platform. Partner tools have been installed on the Platform and collect information from these identifiers in order to ensure that the Application works correctly, to enable certain functionalities to work, or to use them for advertising or analysis purposes.

3. The use of mobile identifiers

Alowaa uses Mobile Identifiers for different purposes, namely :

To guarantee access and stable performance of our Services and our website.
To personalize the Member's experience when using our Services or accessing our website.
To monitor the use and progress of Members on our Services and on our website.
Measure audiences.
Targeting advertising campaigns and measuring the results.

Third-party sites may store or access cookies on the hard drive of the Member's terminal when collecting the unique identifier of his mobile when he visits the Platform, in order to track his browsing habits, measure audiences, and/or for targeted advertising purposes.

4. Collection of mobile identifiers

When the Member installs the Platform, he consents to the collection of his mobile's unique advertising ID by the Application's Tracking Tools in order to receive personalized advertising, unless he configures his device to oppose targeted advertising (see the paragraph "Manage your Mobile Identifiers"). Similarly, by installing the Platform, the Member consents to the use of his Mobile Identifiers for audience measurement purposes.

Other uses of Mobile Identifiers for purposes strictly necessary for the operation of the Platform are exempt from consent, as they are necessary to guarantee access and the stable operation of the Services.

5. Managing mobile identifiers

Mobile Identifiers are collected and used as long as the Platform is installed on the Member's device.

If the Member does not want Alowaa to collect and use his Mobile Identifiers, he must not install the Application on his device.

With the exception of the Tracking Tools used for advertising purposes, all the Application Tracking Tools listed above are essential for the stable operation and exploitation of the Application Services to which the Member has subscribed.

For Tracking Tools used for advertising purposes, the Member may configure his or her device to refuse personalized advertising:

For Apple / IOS :

Go to Settings > Privacy > Advertising

Activate "Limited ad tracking".

(In case of changes, please consult:https://support.apple.com/en-us/HT205223) .

For Android / Google Play Store :

Go to Settings > Account or Sync or Google (depending on your device) > Privacy or Advertising or Announcements (depending on your device)

Activate " Deactivate the personalization of advertisements ".

(In case of changes, please consult: https://support.google.com/googleplay/android-developer/answer/6048248?hl=fr).

Deactivating ad personalization will not disable advertising on the Platform, the Member will only see non-personalized ads.

Alternatively, the Member may download the AppChoices application (https://youradchoices.com/appchoices) which allows the Member to select which advertisers are allowed to collect their advertising preferences.

At any time, the Member may prevent the Application's Tracking Tools from using his Mobile IDs by uninstalling/removing the Platform from his device.

Article 10: Password confidentiality

The Member is responsible for the confidentiality of the password he or she has chosen to access his or her account on the Platform.

The Member undertakes to keep this password secret and not to communicate it to anyone.

Article 11: Links to other websites and social networks

The Platform may occasionally contain links to the websites of our partners or third-party companies. Please note that these websites have their own privacy policies and that we decline all responsibility for the use made by these websites of the information collected when the Member clicks on these links. We invite the Member to read the privacy policies of these websites and to transmit his Personal Data to them.

Article 12: Modification of the Alowaa Privacy Policy

We believe that we may occasionally need to change this Privacy Policy from time to time. Where necessary, we will notify the Member and/or seek your consent. We advise Members to check this page regularly to be aware of any changes or updates to our privacy policy.

Article 13: Contact

If you have any questions about this privacy policy or if you have any requests relating to your personal data, you can contact us by sending an email to dataprotectionAlowaa@gmail.com.

Updates : 14/05/21