Our Privacy Obligations

Karamba is a solution developed by ØPP sa, a company located in Liège, Belgium. This Privacy Policy also explains how we process ‘personal data’ about people in the European Union (EU), as required under the General Data Protection Regulation (GDPR).

The APP regulate how personal information is handled by Karamba.

‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Karamba’s Privacy Policy applies to personal information collected and/or held by Karamba.

 

The types of personal information we collect and hold

Karamba collects personal information about its users in order to provide its service and to offer customer support. Karamba services and customer support are provided through many platforms including but not limited to: websites, phone apps, email, and telephone. The specific platform and product, service, or support you interact with may affect the personal data we collect.

In some situations users may provide us personal information over platforms that are outside our control; for example through Facebook or Google single sign-on. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy.

 

How we collect personal information

Information that you specifically give us

While you use Karamba app you may be asked to provide certain types of personal information. We may request, collect, or process the following information:

• Account Details – username, password, profile picture.
• Contact Details – email address.
• Location Details – timezone.
• Identity Details – full name.
• User Generated Content – statistics about performances

 

Information that we collect from others

Users can give permission for us to connect to their account on other platforms to collect personal information. This includes but is not limited to Facebook, LinkedIn, and Google. Information collected will be governed by this Privacy Policy.

Users can stop us from collecting data from other platforms by removing our access on the other platform or by contacting our support team.

Admin users have the ability to invite non-users to our platform by providing contact details such as email address, and proposing them to sign up to Karamba. In these situations, the information will be collected and stored by us to contact the non-user and to prevent abuse of the invite systems.

This non-user data is not forwarded to any third party or Karamba’s customer.

 

Information we collect as you use our service

We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button.

When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.

We may collect or process the following information:

• Metadata – IP address, computer and connection information, referring web page, standard web log information, language settings, timezone, etc.
• Device Information – device identifier, device type, device plugins, hardware capabilities, etc.
• Location – timezone. 
• Actions – pages viewed, buttons clicked, time spent viewing, search keywords, etc.

 

How we use personal information

The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:

• to provide the service or product you have requested;
• to provide technical or other support to you;
• to answer enquiries about our services, or to respond to a complaint;
• to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications);
• to allow for debugging, testing and otherwise operate our platforms;
• to conduct data analysis, research and otherwise build and improve our platforms;
• to comply with legal and regulatory obligations;
• if otherwise permitted or required by law; or
• for other purposes with your consent, unless you withdraw your consent for these purposes.

The ‘lawful processing’ grounds on which we will use personal information about our users are (but are not limited to):

• when a user has given consent;
• when necessary for the performance of a contract to which the user is party;
• processing is necessary for compliance with our legal obligations;
• processing is necessary in order to protect the vital interests of our users or of another natural person.
• processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.

 

When we disclose personal Information

Our third party service providers The personal information of users may be held or processed on our behalf outside Belgium, including ‘in the cloud’, by our third party hosting provider (OVH). Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.

Our third party service providers include:

• Cloud hosting, storage, networking and related providers
• Marketing and analytics providers
• Security providers

 

Third party applications

Through the Karamba API it is possible for users to grant third party applications access to their Karamba account. Depending on the permissions that are granted, these applications may be able to access some personal information or do actions on the users’ behalf. These third party applications are not controlled by us and will be governed by their own privacy policy. Users are able to remove third party applications from access their data through their settings.

Other disclosures and transfers We may also disclose your personal information to third parties for the following purposes:

• • • if necessary to provide the service or product you have requested;
    • we receive court orders or other requests for information by law enforcement;
    • if otherwise permitted or required by law; or
    • for other purposes with your consent.

 

Accessing, correcting, or downloading your personal information

You have the right to request access to the personal information Karamba holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge.

Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer.

You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance, please contact our customer support.

Exercising your other rights You have a number of other rights in relation to the personal data Karamba holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide.

Much of the data we collect is in order to establish ranking between users of the same company – these data uses are protected against the below rights.

You have the right to:

• • • seek human review of automated decision-making or profiling
    • opt-out of direct marketing, and profiling for marketing
    • erasure
    • temporary restriction of processing.

Users may exercise any of the above rights by contacting our Privacy Officer.

To contact our Privacy Officer

If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:

By Email:

Emma Bauden

Privacy & GDPR Officer

emma@opp.mx

By Mail:

Attn: Privacy Officer

Quai Marcellis 17

4020 Liège

BELGIUM

For the purposes of the GDPR, our Privacy Officer is also our Data Protection Officer (DPO).

While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days of receipt.

If you are in the European Union, you can choose to instead lodge a complaint with your local Data Protection Authority (DPA). The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.