Welcome to GoodBarber! Thank you for choosing to use our services.
GoodBarber is alternatively a data processor or a data controller when it processes data directly or indirectly based on the order of its Users. GoodBarber is headquartered at CampusPlex, 12 Rue Général Fiorella, 20000 Ajaccio (FRANCE, EUROPE).
GoodBarber is registered at the French Registre du Commerce et des Sociétés (RCS) under the number: RCS 438 864 894. Simoni Sébastien and Pietri Jérôme are the legal representatives of SAS GoodBarber.
GoodBarber has appointed a Data Protection Officer (“DPO”).
The following terms shall have the following meaning:
“Access codes”: username and password any credentials (including but not limited to passwords, usernames, 2FA and OTP) used by the User or the Customer together or separately to identify oneself and access the Services. The access codes are part of the User Account.
“Adequacy Decision”: means, according to the European Data Protection Supervisor (https://edps.europa.eu/data-protection/data-protection/glossary/a_en):‘An “adequacy decision” is a decision adopted by the European Commission on the basis of Article 45 of the GDPR, which establishes that a third country (i.e. a country not bound by the GDPR) or international organisation ensures an adequate level of protection of personal data. Such a decision takes into account the country's domestic law, its supervisory authorities, and international commitments it has entered into”.
“App stores”: means any type of digital shop provided by Platforms or Third Party on mobile devices, computers or any other digital devices to download any kind of applications made available to the public by developers.
“Application(s)” or “Service(s)”: alternatively means any type of interface allowing the User to deliver to its End-Users any type of contents through the use of GoodBarber’s “BackOffice”“Application”: mobile or desktop application created by the User through GoodBarber infrastructure and made available to the public to for download or to access from a third-party platform or accessible from a web browser through PWA or on any mobile device.
"BackOffice": the embedded web app allowing the User to create, review, personalise, modify, delete and send to GoodBarber and finally send to Platforms its finalised Application.
“Binding Corporate Rules” ("BCR"): mean according to the European Data Protection Supervisor (https://edps.europa.eu/data-protection/data-protection/glossary/b_en#bindingrules): Binding corporate rules (BCRs) are a legal tool that can be used by multinational companies to ensure an adequate level of protection for the intra-group transfers of personal data from a country in the EU or the European Economic Area (EEA) to a third country.
“Cookie”: means a small piece of text file that is implemented on your computer or mobile device to allow that website to remember your choices, personalisation requests and to keep this information in memory for a certain limited time in accordance with law and regulation.
"Customer Service": the service that assists the Customer or the User regarding but not limited to any technical issues or assistance that must be dealt with, invoice issues, payment/fees regarding the subscription or any kind of assistance made through email or chat regarding how the “BackOffice” works or can be used by the User.
"Data Protection Law": means all data protection and privacy laws applicable to the processing of personal data.
"Data Controller": means any entity that determines the purposes and means of the processing of personal data.
"Data Protection Officer (“DPO”)": means the physical person or entity or within any Sub-processors in charge of compliance regarding both European Union Regulation (GDPR “Section 4, articles 37, 38 and 39”) and National Regulation regarding the treatment and processing of personal data or personal information.
“Data importer”: means the processor who agrees to receive form the data exporter personal data intended for processing on his behalf.
“Data exporter”: means the controller who transfers the personal data.
“End User”: Any person or entity who actually uses our Service(s). It can be users, visitors and customers of our User's Application.
"European Union Data Protection Law": means since the 25 May 2018 Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation) (“GDPR”) and Directive 2002/58/EC modified by directive 2009/136/CE (November 25th 2009) concerning the processing of Personal Data and the protection of privacy in the electronic communications sector and applicable to national implementation of it.
“Guest”: any person being invited by a User of the Service to provide or drop comments or publish as an Author, under the Client’s responsibility.
"iBeacon" or “beacon”: iBeacon or beacon is a miniaturised network device that uses Bluetooth Low Energy (BLE) also known as Bluetooth 4.0 and acts as a relay to detect or track any smartphone or mobile device appearing within a set range. The iBeacon or beacon can hence send push notifications to the device.
“Order”: online subscription of our Service(s).
"Personal Data" or “Personal Information”: means any information relating to an identified or identifiable natural person in accordance with article 4.1 GDPR.
"Platform'': any third-party entity including but not limited to Apple Inc. and Google LLC. A “Platform” means a provider of a hosting service which at the request of a recipient of the service, stores and disseminates to the public information, applications or services (Digital Services Act DSA 15/12/2020).
“Progressive Web App (PWA)”: means a web app that behaves and acts as if it was a mobile app on a mobile device.
“Push notification”: a notification send to any mobile device to communicate any kind of information to the User regarding the use of a service.
"Service" or "Services": access to our sites, including but not limited to www.goodbarber.com, it.goodbarber.com, es.goodbarber.com, pt.goodbarber.com, de.goodbarber.com, nl.goodbarber.com and fr.goodbarber.com as well as your subscription to and any Order of our services, products, goods, applications, tools, offline components and features (individually the "Service" or collectively, the "Services") provided by our company GoodBarber, together with its affiliates, officers, directors, employees, agents and subsidiaries (hereinafter " GoodBarber", "we", "our" or "us").
“Standard Contractual Clauses” ("SCC"): means according to the European Data Protection Supervisor (https://edps.europa.eu/data-protection/data-protection/glossary/s_en#standard_contractual_clauses): Standard contractual clauses are legal tools to provide adequate safeguards for data transfers from the EU or the European Economic Area to third countries. In principle no authorisation is required from data protection authorities to be allowed to use these clauses. A formal notification to the authority might nevertheless be necessary.
“Stripe”: means a third party digital solution allowing digital payments and transactions to be made via credit cards or any other digital payment method. GoodBarber has no link at all with Stripe or with any of its affiliates and hence has no liability or responsibility regarding Stripe’s operations or business.
"Subscription": any paid access proposed by GoodBarber allowing, upon due payment, the User to access features, add-on or options proposed within the BackOffice.
“Sub-processor”: means any processor engaged by the data importer or by any other sub-processor of the data importer who agrees to receive from the data importer or from any other sub-processor of the data importer personal data exclusively intended for processing activities.
“User Content”: any content uploaded by you (the User), including but not limited to any designs, images, animations, videos, audio files, fonts, logos, illustrations, compositions, artworks, interfaces, text, drawings, literary works and any other materials.
“User”: any person or entity having an account allowing access to our Services.
"Website User": Any person visiting one of our websites.
At GoodBarber we are convinced that data Privacy is a fundamental right that must be respected at any time when you use our Services or Application. This is why GoodBarber treats all data that are related to an identified or identifiable individual as personal data without consideration to the area of residency of this individual.
2. Information and data we collect at GoodBarber
Data collected by GoodBarber regarding its User in accordance to GDPR and other applicable laws and regulations.
The Data collected by GoodBarber depends on how you use and interact regarding our website, Services and Application. When you create an account or when you register on any of our previously mentioned websites we can collect any of the following data:
- Account information including unique Account ID
- Device, mobile device or computer information and details
- Contact information
- Name, Surname
- Phone number
- Localisation data
- Email address
- Physical address
- Company name, address and contact details
- Consent to receive newsletters and other promotional or marketing messages
- Payment method (for instance, credit card hash, PayPal account information)
- Social media profile and third party accounts details, if provided, (including but not limited to Google, Apple, Facebook, Twitter, Instagram, YouTube, Linkedin…)
- Data use and usage
- IP address including connection logs and data, navigator type, computer related information
- UDIDs for Android and iPhone, IDFA, IMEIs…
- Navigator information including metadata
- Connection Logs and data or information or crash logs
- Diagnostic data or performance data
- Advertising data
- Any kind of other data voluntarily given by the User to GoodBarber or any other Third Party or entity
- Login credentials (hashed)
- Subscriber name and contact information
- Financial or other transaction information and details other than banking details (hashed)
- Other Personal Data relating to the individual data subject as set by the User
We may receive information about how and when you use the Services and Application, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the Services. This type of information helps us to improve our Services for both you and for all of our Users and End-Users.
The User is not required to communicate any of this information or data to GoodBarber, but failing to do so might not allow GoodBarber to fully work nor it will allow the Customer Service or the DPO to give any help regarding any matter or subject. Also the use of our Services will be limited if some of the Data or information is missing, is partially communicated or is not communicated at all to GoodBarber by the User or End-User.
When you use our mobile apps (for instance My GoodBarber or GoodBarber News), we may collect certain information in addition to information described elsewhere in this Policy. For example, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account. If you have opted in to these notifications and no longer want to receive them, you may turn them off through your operating system.
We may ask for, access or track location-based information from your mobile device so that you can test location-based features offered by the Services or to receive targeted push notifications based on your location. If you have opted in to share those location-based information, and no longer want to share them, you may turn sharing off through your operating system. We may use mobile analytics software to better understand how people use our application. We may collect information about how often you use the application and other performance data.
3. Personal data and information collected by the User from the End-User directly via GoodBarber’s Services
The User might collect data including Personal Data or personal information about the End-User during the use of the Service created through GoodBarber’s BackOffice (“The BackOffice”).
As you use our Services, you may import into our system Personal Information you have collected from your End Users or other individuals. We have no direct relationship with your End Users or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. Consistent with the uses of Personal Information covered in this document, we may transfer Personal Information of you or your End Users to companies that help us promote, provide, or support our Services or the services of our Users (“Service Providers”). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about End users. We may share this information with third parties in line with the approved uses in this document.
Our Customers who have created an Application using GoodBarber are responsible for what they do with the personal information and personal data they collect, directly or through GoodBarber, about their End Users.
Hence the User while collecting data from the End-User will be entitled as Data Controller and will be legally liable to meet any legal obligation as required by law or regulation. GoodBarber is the Data Processor.
If you are an End User and no longer want to be contacted by one of our Users, please contact the User directly to update, modify, transfer or delete your data and personal data. If you contact us, we may remove or update your information within a reasonable time but no longer than one (1) month but never exceeding three (3) months in case of further investigations or difficulties and after providing notice to the User of your request.
We will retain Personal Information we process on behalf of our Users for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
You're solely and entirely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including personal information you collect about them using the Services or cookies or similar technologies.
We’re not liable nor responsible for your relationship with your End Users or how you collect and use personal information about them (even if you collect it from us or using GoodBarber functionality or cookies or similar technologies) and we won’t provide you with any legal advice regarding such matters.
When the End-User is using the Services made by one of our User, they will need to reach out directly to that User, the Data Controller, to discuss managing, deleting, accessing, transferring or restricting access to or otherwise withdrawing consent for use (if applicable) of, the information which you provided to them while using their Application and/or Service. GoodBarber, as the Data Processor, is not in a position to handle these requests. If you are having difficulties finding this User you can contact our DPO at email@example.com and we will try our best to help you.
Please note that, for technical reasons, there may be a delay in deleting your personal Information or personal data from our systems when you ask us to delete it but it can take no longer than thirty (30) days or one (1) month in accordance with law and regulation. In case of difficulties or in case we need more information regarding this request, this delay can reach up to three (3) months as allowed by the law. GoodBarber will also retain personal Information or personal data in order to comply with applicable law and regulation, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law or regulation. If you are not satisfied with the Data Collector or GoodBarber’s (Data Processor) answer regarding how your Personal Data and personal information is managed or treated you can send your complaint directly to the CNIL (Commission Nationale Informatique et Libertés) by sending a message via the CNIL website https://www.cnil.fr/fr/plaintes, or by sending a postal letter at CNIL - Service des Plaintes - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
GoodBarber will retain Personal Information or personal data, we process on behalf of our Users for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
4. Your Privacy Rights at GoodBarber
At GoodBarber we comply and strongly respect, as required by the GDPR and other regulations, your right to access, consult, correct, erase, transfer and your right to data processing limitation, if any applicable.
If you are a User:
You can access, update, change or delete personal information (or that of your End Users) either directly in your Account or by contacting us at firstname.lastname@example.org to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.
If you are a End User:
According to relevant law and regulation you have a right to access, modification, opposition, erasure (right to be forgotten), treatment limitation, consent withdrawal (if applicable) or data portability (if applicable or relevant). To exercise these rights you can write to our DPO by email at email@example.com. You can also communicate to our DPO your instructions concerning the fate of your data after your death. If you are not satisfied with GoodBarber’s answer regarding how your Personal Data or personal information is managed or treated you can send your complaint directly to the CNIL (Commission Nationale Informatique et Libertés) by sending a message via the CNIL website https://www.cnil.fr/fr/plaintes, or by sending a postal letter at CNIL - Service des Plaintes - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07. To find out more about your rights, you can consult the CNIL website https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles/.
GoodBarber, in some cases, might not be legally able to meet the User or End-User requests regarding their data privacy or personal data request. This can be justified by the fact that GoodBarber might be legally required to keep some data or information to meet legal obligations or requirements, this can include, but is not limited to, financial data, transaction records, anti fraud regulation, anti money laundering regulation or any kind of data or information that must be legally kept.
5. GoodBarber’s use of personal data
At GoodBarber we use personal data and information to enable our Services to technically work. We also use this information and data to enable commercial, marketing, financial transactions and payment to be handled directly by GoodBarber and by our Third Party or entities including but not limited to Stripe, Paypal, Apple Pay, Google Pay and Mercado Pago.
GoodBarber can use personal data for different purposes such as:
- Billing: To bill and collect money owed to us by our Users. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
- Advertising: To promote use of our Services to you and others. For example, if we collect your Personal Information when you visit our Website and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using.
- Customer Support: To communicate with our Users about their account and provide customer support.
- Third Party protection: To protect the rights and safety of our Users and third parties, as well as our own.
- Legal requirements: To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms. To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements. To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- User and End-User support: To provide, support, and improve the Services we offer. This includes our use of the data that our Users provide us in order to enable our Users to use the Services to communicate with their End Users. This also includes, for example, aggregating information from your use of the Services or visit to our Websites or Applications created with our Service and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your End Users with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
GoodBarber uses personal data or information in full compliance with law and regulations or only when GoodBarber has a valid legal basis to do so as required by law and regulation. These legal basis can include and are limited, in accordance with law and regulation, to:
- Contractual obligation
- Legal requirement
- Safeguard of person’s vital interest
- Public interest
- Legitimate interest
GoodBarber’s legal basis for data collection are, consent (when applicable), contractual obligation, legal requirement and its legitimate interest in accordance with article 6 (a), (b), (c) and (f) GDPR.
If our User or your End-User has any question, demand or request regarding these legal basis they can contact our DPO at firstname.lastname@example.org or through the form available online at https://www.goodbarber.com/contact/
If you are not satisfied with GoodBarber’s answer regarding how your Personal Data or information is managed or treated you can send your complaint directly to the CNIL (Commission Nationale Informatique et Libertés) by sending a message via the CNIL website https://www.cnil.fr/fr/plaintes/, or by sending a postal letter at CNIL - Service des Plaintes - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
6. GoodBarber’s sharing of personal data
GoodBarber may share personal data or information with Sub-Processors, Third-Party or with any other company or entity that is affiliated or that works with GoodBarber in relation to our activities, business or operations.
|Entity Name||Corporate Location|
|Amazon Inc. (AWS)||Washington, USA, London UNITED KINGDOM, Ireland, Stockholm, Frankfurt, Paris, Milan, EUROPE|
|Apple Inc.||California, USA|
|Atlassian||New-South Wales, AUSTRALIA|
|Google LLC.||California, USA|
|Google Ireland Limited||Ireland, EUROPE|
|Slack Technologies||California, USA|
|Paypal Inc.||California and Washington, USA|
|Mercado Pago||Buenos Aires, ARGENTINA|
|Stripe Inc.||California, USA|
|So You Start||Roubaix, Gravelines, Strasbourg, EUROPE|
|101 Domain||Vista, USA|
|Digital Ocean||New-York, USA|
|Kimsufi||Roubaix, Gravelines, Strasbourg, EUROPE|
|MaxCDN (Stackpath)||Dallas, USA|
|Pingdom (Solarwinds)||Austin, USA|
|Work4Cad (W4C)||Saône, EUROPE|
|Gaspard+Bruno>||London, UNITED KINGDOM|
|Zoho CRM||Chennai, INDIA|
7. Protection of data at GoodBarber
GoodBarber is and will implement and put in action all, state of the art, technologies including, but not limited to, administrative, technical and physical measures to fully meet and respect the legislation and regulation that are in force; this include, but is not limited to the GDPR. This includes the formation of its own employees, staff and personnel regarding data privacy, compliance and data protection.
GoodBarber will also ensure that its Sub-Processor and Third Party or entities will also ensure continuous formation of their employees and that they will implement all, state of the art, technologies including, but not limited to, administrative, technical and physical measures to fully meet and respect the legislation and regulation that is in force; this include, but is not limited to the GDPR.
While no service is completely secure, we have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.
More information can be found on the https://www.goodbarber.com/dpa/
8. Transfer of Personal Data between Countries within the European Union and outside of the European Union
GoodBarber is delivering and making it possible to access its Services, Applications and websites within the European Union as well as all around the World. Hence, your personal data and information might be transferred or accessed by Third Parties or entities located all around the World or in any country inside or outside of the European Economic Area (EEA).
Therefore, GoodBarber will comply with any law or regulation regarding Data Transfer and Data Processing within the European Union or outside the European Union. In order to comply with regulation about Data Transfer and Data Processing outside the European Union, GoodBarber will meet all the legal requirements by complying with any Adequacy Decision emitted by the European Commission on the basis of article 45 of the GDPR.
Also, GoodBarber will put in force "BCR" (“Binding Corporate Rules”) and "SCC" (“Standard Contractual Clauses”) with its Third Party companies or entities located outside of the European Economic Area (“EEA”) or when an Adequacy Decision does not exist.
9. Public information and Third parties
9.1   Blog:   We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information or personal data appears on our blogs and you want it removed, contact our DPO us at email@example.com. If we are unable to remove your information, we will tell you why.
9.2   Social media platforms and widgets:   Our Websites include social media features. These features may collect information and data about your IP address and which page you are visiting on our Website, and they may set cookies or tracking features to make sure the website feature functions properly. Social media features and widgets are either hosted by a third party or entity or hosted directly on our Website. We also maintain presences on social media platforms including, but not limited to, Facebook, Linkedin, YouTube, Twitter, and Instagram. Any information, data, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy or data protection. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies, data protection policy and cookies policy of the companies that provide them.
9.4   Service Providers Sometimes:   We share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enable a feature such as Social Profiles), then we may share your and/or your End-Users' Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information and personal data only for the provision of services to us and in a manner that is consistent with this policy and with law or regulations.
11. Your acceptance of these terms
12. Contacting us - Data Protection Officer (DPO)
GoodBarber designated its Data Protection Officer, as required by GDPR. GoodBarber's DPO located at CampusPlex, 12 Rue Général Fiorella 20000 Ajaccio, Corse, (FRANCE, EUROPE).
All Legal notices to GoodBarber shall be sent to: GoodBarber, CampusPlex, 12 rue Général Fiorella 20000 Ajaccio, Corse, (FRANCE, EUROPE) (for updated contact go to www.goodbarber.com