Controller: Tradlinks International, S.A.
Registered office: Rua da Prata 80, 1100-415, Lisbon
Sole registration and taxpayer number: 516 720 457
Contact: support@bloop.eu
Hereinafter simply "controller"
This section of the Privacy Notice covers situations in which Bloop is an independent controller, pursuing only its own purposes in processing personal data.
To that extent, it applies to the processing of Clients' personal data carried out by Bloop in the course of its activity on the Platform. In situations where one of these parties is specifically identified in the table below, the purpose of processing applies only to that party.
1. Purposes, legal basis and storage periods applicable to the processing of personal data processed by Bloop as an independent controller
Purpose of processing | Legal basis | Storage period |
Managing the opening and maintenance of Client and Business accounts. | Performance of a contract to which the data subject is a party ("performance of a contract"). If the party to the contract is a legal person, our legitimate interest in performing the contract executed. | Until the purpose for which the data was collected ceases. |
Management of publications made by Clients on the Platform. | Performance of a contract, in the case of natural persons. Bloop's legitimate interest in analyzing the publications made, in the event that they contain any identification of a data subject. | Until the purpose for which the data was collected ceases. |
Allocation of credits obtained by the Client following product evaluations, as defined in the T&Cs. | Performance of a contract. | Until the purpose for which the data was collected ceases. For tax-relevant data: 10 years. |
Sending marketingcommunications. | Consent. | 3 years or until the data subject withdraws consent. |
Management of requests for clarification of doubts and questions sent to Bloop. | Bloop's legitimate interest in analyzing and responding to requests for clarification of doubts. | Until the purpose for which the data was collected ceases. |
Analysis of complaints submitted to Bloop (general or through the Complaints Book), as well as requests to remove content. | Bloop's legitimate interest in analyzing complaints and requests to remove content. Compliance with a legal obligation. | In the case of general complaints submitted to Bloop, until the purpose for which the data was collected ceases. In the case of complaints made in Bloop’s Complaints Book, 3 years. |
Access to the User's telephone contact list, so as to: (i) confirm which of the User's contacts are already registered and (ii) enable the dispatch of invitations to contacts who are not yet registered. | Consent. | Until the purpose for which the data was collected ceases or until the owner stops using the app. |
Publication of information on accumulated credits (up to 100%) through each publication on the Platform. | Performance of a contract. | Until the purpose for which the data was collected ceases or until the owner stops using the app. |
There are, however, instances of personal data processing on the Platform regarding which Bloop is not an independent controller, insofar as the purposes and means of the processing are determined jointly with another entity: the Business.
For the purpose of processing designated immediately below, Bloop is a joint controller with the Business with whom the consumer interacts or from which they purchase a certain product. The identification of the Business can be found on their respective page as indicated in Bloop's T&Cs.
To this extent, the processing of data carried out for the purposes below is the responsibility of Bloop and the Business, as joint controllers.
2. Purposes, legal basis and storage periods applicable to the processing of personal data processed by the joint controllers
The joint controllers have entered into a joint responsibility agreement for the processing of personal data, to ensure compliance with the applicable legislation.
If you would like to review the essence of said agreement, please send an email with such a request to the following address: support@bloop.eu
Purpose of processing | Legal basis | Storage period |
Management of consumer orders. | Performance of a contract. Legitimate interest in managing and handling orders placed. | Until the purpose for which the data was collected ceases. |
Analysis of the publications made by Clients on products sold by Businesses for the allocation of credits. | Performance of a contract. Legitimate interest in analyzing the publications made. | Until the purpose for which the data was collected ceases. |
Handling orders placed by the Client and the related payment. | Performance of a contract. Compliance with a legal obligation. | Until the purpose for which the data was collected ceases. For tax-relevant data: 10 years. |
Processing for tax and invoicing purposes; collections. | Performance of a contract. Compliance with a legal obligation. | Until the purpose for which the data was collected ceases. For tax-relevant data: 10 years. |
Handling product complaints from consumers for non-conformity, forwarding requests. | Performance of a contract. Legitimate interest of the joint controllers in analyzing the complaints submitted. | Until the purpose for which the data was collected ceases. |
Handling withdrawal requests. | Compliance with a legal obligation. Performance of a contract | Until the purpose for which the data was collected ceases. |
The personal data processed on the basis of the performance of a contract (identified in points 1 and 2) is necessary for you to enter into a contract with us and, in this sense, for you to be able to use all the features of the Platform. Failure to provide this data will prevent the User from registering an account and using the Platform.
Your consent is freely revocable at any time, without, however, compromising the lawfulness of the processing carried out on the basis of that consent up to that point.
We likewise collect cookies on the Platform, which also constitutes data processing. For more information on the matter, please check our Cookie Policy.
3. Recipients and potential recipients of personal data and international data transfers.
The provision of certain services may involve the transfer of your data to third party service providers, such as accounting, database management, order handling, Platform management, dispatching communications related to statistical ends ("processors"), and only for the strict fulfillment of the purposes identified in this Notice, both in the processing referred to in points 1 and 2.
In this context, your personal data may be transferred outside the EU/EEA, namely for the management of the Platform and the execution of its proper functioning. International transfers will be carried out under a European Union Adequacy Decision or, alternatively, using the European Union Standard Contractual Clauses, and only for the strict fulfillment of the processing purposes identified in this Notice.
More information on EU Standard Contractual Clauses can be found here: https://eur-lex.europa.eu/legal-content/PT/TXT/HTML/?uri=CELEX%3A32021D0914. More information on the countries covered by Adequacy Decisions can be found here: https://www.edpb.europa.eu/sme-data-protection-guide/international-data-transfers_pt.
Your data may also be provided to judicial or administrative authorities, at your request, in order to comply with our legal obligations.
Finally, please note that anyone who has your telephone contact will be able to confirm whether there is a Platform account associated with your telephone number.
4. Data subject rights
You have the following rights, as a data subject:
Access: to obtain information as to whether we are processing your personal data, as well as to consult your personal data, the purpose and nature of the processing, as well as to obtain a copy in order to verify the information held by the controller.
Rectification: updating or changing your personal data when it is inaccurate, as well as completing incomplete data.
Erasure: request the erasure of your personal data when, among other reasons, the personal data is no longer necessary for the purposes for which it was collected.
Restriction of processing: request the restriction of the processing of your personal data in the following situations: (a) during the contestation of the accuracy of your personal data, (b) when the processing is unlawful and you have opposed the erasure of the personal data and requested the limitation of its use instead, (c) when we no longer need to process personal data, but we need it for the exercise or defense of rights in an administrative, judicial or extrajudicial proceeding, (d) when you have objected to the processing of your personal data, but it is necessary for the fulfillment of an obligation of public interest or for the satisfaction of a legitimate interest, as long as it is verified that these legitimate grounds for the processing prevail over your reasons.
Objection to processing: In certain situations you may request that your personal data is no longer processed. We will stop processing your personal data, except where there are legitimate grounds or for the establishment, exercise or defense of rights in an administrative, judicial or extrajudicial proceeding.
Portability of personal data: In certain situations you will have the right to receive, in a structured, commonly used and machine-readable format, a copy of the personal data you have provided us and that which was obtained as a result of your relationship with us, as well as to transmit them to another entity.
You also have the right to lodge a complaint with the competent supervisory authority, which, in Portugal's case, is the National Data Protection Commission (www.cnpd.pt).
Both the rights related to the processing carried out for the purposes of points 1 and 2 must be exercised before Bloop, at the following address: support@bloop.eu
Without prejudice, we note that for the purposes of point 2, the data subject may exercise their rights before the joint controller, if they wish. To exercise their rights before the Business, the data subject should contact it through the contact details provided on the Business' page, on the Platform.
In any case, we recommend that before filing a complaint with the National Data Protection Commission, you always contact Bloop to exercise your rights. You can exercise your rights at the following email address: support@bloop.eu