Privacy policy

Intro

Rary is a platform dedicated to the communication of shopping events by merchants to consumers present in their cities.

"Platform" is referred to as the Rary application.

"Consumers" are defined as all people, residents, national and international tourists registered on the Rary application.

"Merchants" are all merchants offering BTOC products and services registered on the Rary application.

"Shopping events" is a time-limited promotional offer, created and distributed through the Rary application in the form of videos lasting up to 10 seconds where the business owner or his employees express themselves.

There are three shopping events:

Private sale
Special event
Private event

This Privacy Policy ("Privacy Policy") applies to personal information that Rary processes as part of the Platform and other applications, websites, products and services related to Rary that refer to or refer to this Privacy Policy (collectively, the "Services").

Data controller: If you reside in the European Economic Area ("EEA"), the United Kingdom or Switzerland, Dinov Group International, a French company ("Rary", "our", "we" or "our") are jointly responsible for all information processed under this Privacy Policy.

The information we collect

We collect three categories of information: Information you provide, Information collected automatically and Information from other sources. Below you will find more details on each of these categories.

Information you provide

Profile information. We collect the information you provide when you create your Rary account, such as your date of birth, username, email address and/or phone number, and password. You can add other information to your profile, such as a biography or a profile picture.
User content. We collect the content you create or publish through the Platform, including photographs, videos, audio recordings, live streams and comments, as well as associated metadata (such as when, place and author of the content). We collect User Content through pre-loading at the time of creation, import or download, regardless of whether you choose to save or download this User Content. We also collect content (such as text, images and videos) from your device's clipboard if you choose to copy and paste content to or from the Platform or share content between the Platform and a third-party platform.
Direct messages. When you communicate with others through direct messages, we collect the content of the message and associated metadata (such as the time at which the message was sent, received and/or read, as well as the participants in the communication). We do this to block spam, detect violations and protect our users.
Your contacts. When you choose to import your contacts, we collect information from your device's phone book or your social media contacts. We use this information to help you establish connections on the Platform when you use our "Find Friends" function and to suggest your account to others.
Information on purchases. We collect your payment card information or other payment information from third parties (such as PayPal) when a payment is required. We also collect the history of your transactions and purchases.
Surveys and Promotions. We collect the information you provide if you choose to participate in one of our surveys, promotions, contests, campaigns or marketing events.
Information when you contact us. When you contact us, we collect information you send us, such as proof of your identity or age, comments about your use of our Services or information about possible violations of our Terms of Service (our "Terms"), Community Rules (our "Rules") or other policies.

Information collected automatically

Technical information. We collect certain device and network connection information when you access one of our Services. This information includes your device model, operating system, typing patterns or rhythms, IP address and system language. We also collect service, diagnostic and performance information, including fault reports and performance logs. We automatically assign you a device ID and a user ID when you use our Platform. When you sign in from multiple devices, we use information such as your device ID and user ID to identify your activity on all devices to provide you with a seamless and security login experience.
Location. We collect your approximate location based on your Technical Information (such as SIM card and IP address) in order to personalize your experience and for diagnostic and troubleshooting purposes. With your permission, we may also collect accurate location information (such as GPS).
Information of use. We collect information about how you use our Services, including information about the content you view, the duration and frequency of your use of our Services, how you interact with other users, your search history on the Platform and your settings.
Features and characteristics of the content: We detect and collect features and characteristics regarding video and audio recordings that are part of your User Content, for example by identifying objects and landscapes; the existence or location in an image of a face or other parts of the body; and the text of words spoken in your User Content. We do this, for example, for content moderation and to provide special effects (such as video filters and avatars) and captions.
Information deducted. We deduce your attributes (such as age group and gender) and interests based on the information we have about you. We use inferences to, for example, ensure the security of our Platform, moderation of content and, where permitted, to offer you personalized advertising based on your interests.
Cookies. We use cookies and similar tracking technologies to operate and provide our Services. For example, we use cookies to remember your language preferences, ensure that you do not see the same video more than once, and for security purposes. We also use these technologies for marketing purposes. We will obtain your consent for our use of cookies when required by law.

Information from other sources

Advertising, measurement and data partners. Advertisers and measurement and data partners share with us information such as mobile identifiers for advertising, hashed email addresses and event information about actions you have taken on a website or application.
Information on third-party platforms. If you choose to register for Rary using a third-party platform (such as Facebook or Google), the third-party platform will share information such as your email address, user ID and public profile.
Integration partners. When you interact with a third-party service (such as a third-party application, website or product) that integrates Rary development tools, we will receive the information necessary to provide you with features such as authentication or cross-publishing. For example, this will be the case if you sign in to another service with your Rary account or if you use the Rary "share" button on a third-party service to share content from the third-party service to Rary.
Others. Other users or individuals may provide us with information about you, including if you are highlighted or mentioned in another user's content or direct messages, as part of a complaint or comment submitted by a third party, or if your contact information is provided to us by another user.

How we use your information

We use your information to operate, provide, develop and improve our Services, including for the following purposes. You will find more details in the section "Our legal bases and how we process your information".

Provide and administer our Services, including allowing you to create, share and consume content and interact with other users and their content.
Personalize your experience on the Platform, for example by providing you with your "Favourites" information feed.
Process, facilitate or satisfy requests to purchase products, goods and services.
Enforce our Terms, Rules and other policies that apply to you. We review User Content and other information to protect the safety and well-being of our community.
Provide some interactive features, such as allowing the use of your content in other users' videos and suggesting your account to other users to help you connect with other users.
Provide and improve our advertising services, including to serve ads (including personalized ads where permitted) and to measure and understand the effectiveness of ads.
Maintain and improve the safety, security and stability of our Services by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts and the detection of abuse, fraud and illegal activities).
Review, improve and develop our Services, including monitoring interactions and usage on your devices, analyzing how people use our Services and informing our algorithms.
Share your information with third-party platforms at your request to provide you with features, such as content sharing when you integrate your Rary account with a third-party service.
Promote our Services or third-party services through marketing communications, contests, lotteries or promotions.
Comply with our legal obligations, or if necessary to perform public interest tasks, or to protect the vital interests of our users and others.

How we share your information

Service providers

We use service providers who help us provide, support and develop our Services and understand how they are used. They provide services such as online hosting, content delivery, customer and technical support, content moderation, marketing, analysis and online payment. We share the Information you provide, the Information collected automatically and Information from other sources with these service providers to the extent necessary to enable them to provide their services.

Partners

Integration partners: When you choose to access third-party services from our Platform, we may share your usage information with third-party partners to help them integrate with Rary technology and provide you with a seamless experience.

Third-party platforms. We partner with third-party platforms (such as Facebook or Google) to provide you with a smooth connection and content sharing experience. We share information with these third-party platforms when you want to use these features. For example, if you choose to:

log in to a third-party platform using your Rary account, we will share your account basic information and any other information you provide;
register or log in to the Platform using your account identifiers on a third-party platform, we will share certain Technical Information to facilitate this operation;
share User Content you post on the Platform on other social media platforms, we will share your User Content and related information.

Advertising partners

Advertisers: We provide advertisers with aggregated information on the performance of their ads to help them measure the effectiveness of their advertising campaigns. We create this aggregated information using Technical Information and Usage Information relating to how you interact with advertisements on our Platform, and Information from other sources. We share your information directly with advertisers when you give us permission.

Measurement and data partners: We also share Technical Information and Usage Information with third-party measurement providers who help us measure ads on our Platform and help our advertisers determine the effectiveness of their ads.

Our Group of companies

As a global company, our Services are supported by a number of affiliated entities within our group of companies ("Company Group"). We share the Information you provide, the Information collected automatically and Information from other sources with our Group of Companies if necessary to enable them to perform important functions such as online hosting, content delivery, security, research and development, analysis, online payments, customer and technical support and content moderation.

Other

We share your information in other limited scenarios as follows.

Other users and the public: Depending on your privacy settings, your Profile Information and User Content may be visible to other users of the Platform and to the public. Your profile and content may also be visible to third parties, such as search engines, content aggregators and news sites. You can choose to share information, such as text and photos, with others on the Platform using direct messaging.

Business transactions: Your information may be disclosed to third parties as part of a business transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or the acquisition of all or part of our business.

Legal obligations and rights: We may access, preserve and share the information described in the "What information we collect" section with law enforcement agencies, public authorities, copyright holders or other third parties if we believe in good faith that it is necessary to:

comply with applicable laws, legal procedures or government requests, in accordance with internationally recognized standards;
protect the rights, property and safety of our users, copyright owners and others, including to protect life or prevent imminent personal injury. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where a person's life or safety is at risk.
investigate and enforce potential violations of our Terms, Rules or other applicable conditions, policies or standards; or
detect, investigate, prevent or treat misleading activities, copyright infringements or any other illegal activity.

For more information on how we handle requests from law enforcement agencies and public authorities, see our Guidelines for Data Requesting from Law Enforcement Agencies.

Our legal bases and how we process your information

We can only use your information if we have a "legal basis" to do so. We use different legal bases depending on why we use your information (in other words, the "purpose" of our processing). These legal bases include contractual necessity, legitimate interests (our, yours or those of another party), consent, compliance with a legal obligation, the performance of a task in the public interest and the protection of vital interests.

Here we explain the legal bases on which we rely when we process your information. This section also describes why we use your information, how this information is processed, the categories of information concerned and the associated rights (which always include the right to access your information). For more information on how to exercise any of your rights, please consult the "Your rights and choices" section of the Privacy Policy.

Contractual necessity

We use the Information you provide, the Information collected automatically and Information from other sources when necessary to perform the contract you enter into (our Terms) when you register, access or use our Services. This means that we use your information to:

Provide you with our Services. We use your information to provide you with our Services. This includes using your information so that you can create, share and consume content, and interact with others. This also includes using your information to provide you with the products and services you purchase through the Platform. We also personalize your experience on the Platform, for example by offering you a "Favourites" feed, which shows you videos based on what might interest you.
Enforce our Terms, Rules or Policies. We use your information to enforce our Terms, Rules and Policies. This may include deleting content or suspending or closing your account if we determine that you are violating our Terms or Rules.
Administer our Services. We also use the information we have to administer our services, for example to communicate with you on questions about the services and respond to your requests (including when you report a problem to us or request a copy of your information).

Your rights: Whenever we use your information on the grounds that it is necessary for the contract we have with you, you have the right to retrieve the information you have provided to us.

Legitimate interests

We use your information when necessary to satisfy legitimate interests - whether ours, yours or those of a third party - provided that these interests are not outweighed by your interests or fundamental rights and freedoms. We use your information to:

Allow your videos to be used in interactive functions.

Our interactive features allow other users to include your videos in their videos (if you allow it in your settings).
Legitimate interest invoked: Provide users with tools to inspire creativity, collaboration and entertainment, and create opportunities for users to reach new audiences.
Information used: The Information you provide and the Information collected automatically.

Suggest your account to other users.

We may suggest your account to other users.
Legitimate interest invoked: Allow users to quickly and effectively find and get closer to other users on our Platform.
Information used: The Information you provide, the Information collected automatically and Information from other sources.

Provide all users with non-personalized ads.

We show all users non-personalized ads, including those who have chosen not to receive personalized ads.
Legitimate interest invoked: We show non-personalized ads to keep our Platform free. We process limited categories of your information to ensure that our advertising service is useful to our advertisers (for example, to serve advertisements to users in a particular country or to users who speak the same language).
Information used: Information collected automatically and Information from other sources.

Measure the effectiveness of advertising.

We measure the effectiveness of the advertising you see on our Platform.
Legitimate interest invoked: Allow advertisers to view and understand the performance of their ads and make informed decisions (such as the types of advertising campaigns they may want to launch and the type of audience they want to reach). This makes it possible to maintain the relevance of advertising on our Platform and to maintain the freeness of our Platform for all users.
Information used: The Information you provide, the Information collected automatically and Information from other sources.

Ensure the safety and well-being of our community.

We use your information to ensure your safety and well-being, including by reviewing User Content (and if permitted by applicable law, direct messages and associated metadata) to detect violations of our Terms, Rules and other policies. We also deduct your age group and, in certain circumstances, we may ask you to provide additional information to confirm your age.
Legitimate interest invoked: To ensure the safety of our users, verify compliance with our Rules and prevent inappropriate use of our Services.
Information used: The Information you provide, the Information collected automatically and Information from other sources.

Ensure the security and stability of our Services.

We use your information to perform tests and analysis to ensure the stability and security of our Services, including identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud and illegal activities).
Legitimate interest invoked: Ensure the continued stability and security of our Services and ensure that they are available and operate continuously.
Information used: The Information you provide, the Information collected automatically and Information from other sources.

Revise, improve and develop our Services.

We use the information we have to understand how people use our Services to improve and develop our Services (including our algorithms). We also use this information to understand and promote popular topics and emerging trends on the Platform.
Legitimate interest invoked: To improve, promote and develop our Services in an informed manner.
Information used: The Information you provide, the Information collected automatically and Information from other sources.

Share your information with third parties to provide additional features.

We share your information with third parties providing additional features when you choose to use these features. For example, when you link your Rary account to a third-party service, the third party may obtain the basic information of your account and other information you choose to provide based on the permissions you give.
Legitimate interest invoked: To enable these third-party service providers to better authenticate users and optimize the user experience.
Information used: The Information you provide, the Information collected automatically and Information from other sources.

Marketing communications.

We may send you direct marketing messages about the features of our Services and third-party services that we believe may be of interest to you. We may also send you promotions, contests, campaigns or marketing events. We will obtain your consent to send you messages when required by law.
Legitimate interest invoked: To promote new developments and functionalities of our Services and/or third-party products and services.
Information used: The Information you provide, the Information collected automatically and Information from other sources.
Your rights: Whenever we use your information on the basis of a legitimate interest, you can object to this use and request its restriction.

Your consent

We ask for your consent to access your information or use it for specific purposes. If we do, you can always revoke your consent through device permissions or application settings.

Personalized advertising. With your consent, we will offer you personalized advertising based on your activity on and off the Platform.

We use the Information you provide, the Information collected automatically and Information from other sources for this purpose.

Your rights: When we use your information on the basis of your consent, you can withdraw your consent at any time. However, the withdrawal of your consent will not affect the lawfulness of the processing of your information based on your consent before its withdrawal. You can withdraw your consent for personalized ads.

You also have the right to retrieve the information you have provided to us and that we use on the basis of your consent.

Compliance with a legal obligation

We may use your information, including your Profile Information or User Content, when necessary to comply with a legal obligation. This includes situations where we have an obligation to take measures to ensure the safety of our users or to comply with a valid legal request, such as an order of law enforcement agencies or courts. We generally use the Information you provide and the Information collected automatically, although it depends on the specific situation.

To perform a task of public interest

We may use your information when necessary to perform a task of public interest, including to undertake research, prevent and detect crimes, protect children and promote public safety, security and integrity, in accordance with applicable law. We generally use the Information you provide and the Information collected automatically, although it depends on the specific situation.

Your rights: When we use your information on the grounds that it is necessary for a task carried out in the public interest, you have the right to object to our use and request a restriction of it.

To protect a person's vital interests

We may use your information when it is necessary to protect your life, physical integrity or security or that of someone else. This may include providing information to law enforcement agencies or emergency services in emergency situations to protect health or life. We generally provide the Information you provide and the Information collected automatically, although it depends on the specific situation.

Your rights and choices

You have rights and choices regarding your information. Some of these rights apply generally, while others apply only in certain circumstances. Depending on the case, these rights may be subject to certain limitations.

Access your information: You can ask us, free of charge, to confirm what information we process about you, to provide certain information about the processing, and to obtain a copy of your information. The application settings allow you to:

access your information that is visible to other users when you navigate to the "profile" tab of your account.

Delete your information: You can delete or ask us to delete all or part of your information. The application settings allow you to:

delete content published on your profile, such as your User Content and Profile Information.
delete your account.
request the deletion of particular content using the reporting function in the application.

Correct your information: You can modify or ask us to modify or correct your information when it is not accurate. You can modify or correct much of your information through the application's functions and settings (such as Profile Information and video content).

Transfer your information: You have the right to data portability in cases where we rely on contractual necessity and consent as a legal basis. This means that you have the right to receive your information in a structured, commonly used and machine-readable format and to share it with a third party.

Object to the processing of your information: You also have the right to object to the processing of your information in certain circumstances. The right to object applies when the processing to which you object has as its legal basis the legitimate interest or the public interest. When submitting a request for opposition, you must explain what specific processing activity you object to and why processing must be stopped. We will stop the special processing if we do not have compelling legitimate reasons to continue this processing or if we do not need it in the context of legal actions.

Limit the processing of your information: You have the right to request the restriction of the processing of your information when (a) you dispute the accuracy of the information, (b) the information has been processed unlawfully, but you object to the erasure of this information, (c) when you need the information to be kept for the prosecution or defense of legal action, or (d) you have objected to the processing and you expect the result of this request for opposition.

Exercise of your rights: To exercise any of the above rights, please contact us via our platform. Before we can respond to a request to exercise one or more of the rights listed above, you may be asked to verify your identity or account identifiers or provide additional information so that we can understand the problem.

We encourage you to contact us if you are not satisfied with the way we responded to any of your requests to exercise rights.

Security and data retention

The security of your information is important to us. We maintain appropriate technical, administrative and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification or loss. We regularly review our security measures to take into account new technologies and methods available.

We retain the information for as long as necessary to provide our services and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest in doing so (such as improving and developing our Services, and improving the safety, security and stability of our Services), and for the exercise or defense of legal actions.

Retention periods will be different depending on the type of information and the purposes for which we use this information. For example, when we process your information to provide you with the Service, we keep this information for as long as you have a Rary account. This information includes Profile Information, User Content and Direct Messages. If you violate our Rules or Terms, we may immediately remove your Profile Information and/or User Content from public view, but retain your information to the extent necessary to deal with the breach.

Our global operations and data transfers

To support our global operations, we share your information with members of our Group of Companies and other entities outside your country of residence, as described in the "How we share your information" section. These entities undertake to use and store information in accordance with applicable privacy laws and to implement appropriate security measures to protect your information.

When we transfer your information outside the European Economic Area (EEA), the United Kingdom or Switzerland, we ensure that it benefits from an adequate level of data protection by:

relying on the European Commission's adequacy decisions taken under Article 45 of the GDPR, finding that the third country to which the information is transferred offers an adequate level of data protection; or
using the standard contractual clauses approved by the European Commission under Article 46 of the GDPR for the transfer of information to all other third countries.

Young users

You must be at least 13 years old to use the Services. If you believe that we have information about a younger person, please contact us via the contact details indicated in the "Contact Us" section below.

To offer users under the age of 18 an age-appropriate experience, some features are not available.

Updates to the Privacy Policy

We may modify or update this Privacy Policy from time to time. We will inform you of any significant changes to this policy by a notice posted on the Platform or by other means. The "Last updated" date at the top of this policy reflects the effective date of these policy changes.

You can contact us about this privacy policy via our web form.