Privacy policy - Alaya

1. Purpose

1.1. The purpose of this Privacy Policy is to inform Users about the nature of the personal data collected and processed by Alaya, as well as the purpose of such processing and Users’ rights with respect to the personal data collected.

1.2. This Privacy Policy applies in addition to the Terms and Conditions and other documents included in the Contractual Documentation. In the event of any discrepancy between the general terms and conditions and this Privacy Policy, the latter shall prevail.

1.3. In case of disagreement with this Privacy Policy, the User is invited not to use the Site or the Platform and not to communicate his or her personal data.

1.4. A summary table of the data processed (the Data Table) is attached to this Privacy Policy.

2. Collected data

2.1. Information collected automatically. When consulting the Site or using the Platform, certain data concerning the User is collected automatically (IP address, location, pages consulted, date and time of consultation, cookies or similar technologies, browser preference, operating system, access data, etc.). In addition to the data collected directly by Alaya, certain data may be collected by other service providers such as. Only the privacy policies of these service providers apply when they collect data and Alaya cannot be held responsible for their treatment. To learn more about the use of cookies, please see the Cookie Management Policy.

2.2. Information freely provided by Users. The User may be asked to provide personal data in order to benefit the Services offered by Alaya. The data required for use is, in particular:

(i) : email address, first name, last name, respectively company name, native language, skills and interests.

(ii) For Employers: last name, first name, phone number, email address, company name, representative.

(iii) For the Employees: name, first name, email address, gender, Employer, Office Location etc.

(iv) For the Beneficiaries: name, respectively company name, representative, activities, email etc.

These data are mandatory and their absence may make it impossible to provide the Services. In addition to the data necessary to access the Services, optional data may be provided voluntarily by the User, such as a photograph, interests, hobbies, biography, participation in activities, registered means of payment, answers to questions in surveys, etc.

The data required for use (mandatory) are mentioned in the forms by an asterisk or the impossibility to validate the form without filling in the dedicated field.

2.3. Information provided by the employers. Employers can register their Employees directly on the Platform. In doing so, they provide personal information about their Employees. The Employer confirms that it is and shall be solely responsible for obtaining the consent of Employees to their registration on the Platform and for providing the information necessary for this purpose.

2.4. Information provided by third parties. The Data Table lists third-party information collected and processed by Alaya.

2.5. Information concerning minors. Alaya strives to ensure that no data is collected from minors unless otherwise agreed by legal representatives or under specific agreements with schools or other Clients. Any data that may be collected unintentionally will be destroyed as soon as possible after Alaya discovers such collection.

2.6. Information related to the use. When using Alaya’s Services, certain data is collected through the use of the Services. The Data collected is listed in the Data Table.

3. Use of collected data

3.1. Data collected automatically. Automatically collected data allows Alaya to analyze User behavior on the Site and Platform, traffic, and preferences, in particular to optimize and improve the quality of its Services.

3.2. Data provided by users, the employer or third parties and data collected during the use of the services. Alaya processes and uses the necessary data in order to fulfill its contractual or legal obligations and to verify compliance with the terms of use. The processing of this data also makes it possible to provide personalized content to better meet the User’s expectations.

3.3. The Data Table details the timing and use of the types of data collected.

4. Communication and data transmission

4.1. The User’s personal data is not passed on to third parties with the intention of using it for direct marketing purposes, unless the User has given his or her consent to the contrary.

4.2. The User’s personal data may be transmitted or communicated to third parties in the following cases:

(i) in order to execute the obligations resulting from the relationship between the Employee and the Beneficiaries. In particular, when an Employee undertakes Benefits in favor of a Beneficiary. The data collected in the context of the use of the Platform may also be used for the purpose of promoting profiles, positions or similar or identical articles that may be of interest to the User;

(ii) When opening an account with financial partners to allow payments;

(iii) in order to allow the Employers to know the total activity of its Employees authorized by him on the Platform as well as the Employees of the same Company;

(iv) in connection with the provision of services on behalf of Alaya;

(v) when the User has given its consent to it;

(vi) during joint promotions or programs with partners;

(vii)  where required by law or where disclosure is reasonably necessary to comply with a court order or to respond to a legal claim;

(viii) in the event of a merger, acquisition of the company or shares of the company by another company.

The specifies the purpose for which the collected data is processed.

4.3. You are reminded that the processing of data by third parties to whom Alaya may be required to communicate data is governed exclusively by the privacy policy of said third parties. Alaya cannot be held responsible for their use.

4.4. As a matter of principle, personal data of Employees may be communicated and shared to all other Employees of the same Enterprise and to the Employer, mainly through social network features of the Platform (for instance, as a user you can see all the other users that have created an account and you can invite them to specific activities). Other information is automatically shared on the newsboard with other employees, such as for example the amount of volunteering hours or the completion of a challenge. However, Employees may indicate, for certain Services (as defined in the conditions applicable to the use of the Platform) that information concerning them is to be made anonymous for their Employers & other Employees (e.g., the amount of a donation made through the Platform).

4.5. Alaya reserves the right to anonymize certain data for the purpose of using it or passing it on to third parties for research, statistical or marketing purposes.

5. User rights

5.1. Access right and right to data portability. The User may at any time request that the personal data stored by Alaya concerning him/her be transmitted to him/her in a structured, commonly used and machine-readable format.  In addition, the User may request Alaya to transmit the said personal data directly to another data controller, which Alaya will undertake within a reasonable period of time and to the extent technically possible.

5.2. Right of rectification. Users whose data is inaccurate or incomplete have the right to obtain it for rectification.

5.3. Right to withdraw and / or object. The User may at any time object to the collection or processing of certain data concerning him/her (opting out). This objection may prompt the termination of use of the Site or the Platform.

5.4. Right to erasure. The User has the right to request the erasure of personal data concerning him/her when their use is no longer necessary or when the User no longer agrees with the processing of his/her data. Such data will be erased as soon as possible, unless otherwise provided by law.

5.5. Exercise of rights. To exercise the above rights, the User can make a request at any time to the following address: support@alayagood.com.

6. Security

6.1. Alaya takes the protection of its Users’ data very seriously and is committed to treating their personal data confidentiality and with the utmost care. In particular, Alaya takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of the data collected. However, although some personal data is encrypted, Alaya cannot guarantee full and complete protection of the data against unauthorized processing due to the risks associated with the use of the Internet and electronic means of communication.

7. Data retention

7.1. Data collected by Alaya is retained for as long as required for the purpose for which it was collected, subject to legal provisions that provide for longer data retention periods. After this period, personal data is deleted.

7.2. The duration data is kept is specified for each type of data in the Data Table.

8. Modifications

8.1. Alaya reserves the right to change its Privacy Policy at any time. Changes will be posted on the Site and Platform and will be effective from the date of publishing.

8.2. The online Privacy Policy is applicable. By continuing to browse the Site or the Platform, the User accepts the Privacy Policy in force.

Appendix to the privacy policy

*For the purpose of this appendix, the Term “Service Providers of Alaya” for the specific services listed shall be the following: