Privacy Policy

Last updated: March 13th, 2023

Meero S.A.S is a company registered with the Trade and Companies Register of Paris (RCS) under the number 800 523 664, with registered offices at 18 rue du Quatre Septembre, 75002 – Paris, France (“Meero” “Us,” “We,” “Our”). We respect the privacy of Our users. This Privacy Policy describes how Meero collects and processes personally identifying information (“Personal Data” or “Data”) in connection with the Meero Suite services developed by Meero and the individuals who purchase, access, use and/or have an account to those services.

What Services does this Privacy Policy Apply To

Meero has developed a suite of services on the software-as-a-service model, under the name “Meero Suite”.

Meero Suite is composed of (i) Meero mobile applications for the guided creation and editing of visual content in the fields of real-estate and food delivery platforms (“Meero Mobile Applications”), (ii) a Meero web platform for the management of visual content (“Meero Web Platform”) and (iii) meta-application services which allow businesses to create a customizable multi-environment experience between the Meero Mobile Applications and the Meero Web Platform (“Meero Meta-Application Services”).
The Meero Meta-Application Services allow Meero to propose a comprehensive and customizable offering around the Meero Mobile Applications and the Meero Web Platform where user accounts are generated and visual content is created with the Meero Mobile Applications and both are managed on the Meero Web Platform by two (2) types of users with access to different functionalities:

• Meero client businesses are content managers (“Content Managers”), and
• clients’ internal end users as content producers (“Content Producers”).

The functionalities of the Meero Web Platform for each user are:

• Content Producers: management of the visual content they have created on the Meero Mobile Application they use and the management of their own user account,
• Content Managers: management of the visual content created by all of their Content Producers and management of their Content Producers’ licenses, if applicable. Additional artificial intelligence driven moderation and enhancement tools are available to Content Managers.

Together, these software-as-a-service offerings are referred to as the “Meero Suite Services”.

Who does this Privacy Policy Apply To

This Privacy Policy applies to all the users of the Meero Suite Services, who may be:

• businesses to whom Meero provides the Meero Suite Services (“Clients”) under a commercial agreement (“Commercial Agreement”),
• the Client’s authorized employees,
• the Client’s registered end users (employees, agents, contractors, partners),

together, the “User(s)”, “You”, “Your”.

The Privacy Policy applies to the Users’ access to the Meero Suite Services on any device and for any purpose (purchase, access, use of the Meero Suite Services).

What is the Purpose of this Privacy Policy

The purpose of this Privacy Policy is to provide Users with information regarding how We process Personal Data, including:

• what Data We collect;
• what We’re going to do with it;
• what processes We’ll follow;
• and what Your rights are in relation to that Data.

Personal Data will be collected and processed in compliance with the applicable national or state legislation and/or regulation, including but not limited to the European Union Data Protection Regulation 2016/679 (the “GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”).

This Privacy Policy is part of the Application Terms of Use published on the Meero Mobile Applications, the Web Platform Terms of Use published on the Meero Web Platform, the Commercial Agreement and/or the Meero Realtors Terms of Sale for End Users, whichever applies to You, and describes Our policies and procedures on the collection, use and disclosure of Your information when You purchase a subscription, access or use the Meero Suite Services and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Meero Suite Services. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not purchase, access or use the Meero Suite Services.

This Privacy Policy is not..

The terms of use of the Meero Suite Services nor the commercial terms and conditions of sale of the Meero Suite Services You are bound by, if applicable.

The terms of use of the Meero Mobile Applications and the Meero Web Platform shall be published on the applications and the platform and outlines the rules for using the Meero Suite Services

The commercial terms that govern Your purchase, access and use of the Meero Suite Services are either governed by the Commercial Agreement between Meero and the Client and/or the Meero Realtors Terms and Conditions of sale for End Users You have accepted when You purchased the Meero Suite Services.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions
For the purposes of this Privacy Policy:

“Affiliate” means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

“Authorized User” means an individual person who is registered with Meero and permitted by the Client (e.g. Client’s employee, contractor, partner, agent) to use and/or purchase a subscription to use the Meero Suite Services under the terms and conditions negotiated by the Client in the Commercial Agreement has the meaning given to it above, it being specified that Authorized Users are either “Content Managers” with administrator accounts or “Content Producers” with unique user accounts. Clients may choose to have both.

“Data” or “Personal Data” means any information relating to a natural person, including any information deemed personal information under the applicable regulation regarding data protection and/or information through which a person may be identified directly or indirectly (e.g. by reference to a user ID, an identification number, location
data, an online username or one or several specific elements related to a person’s physical or health status, nationality, cultural or social identity).

“Data Controller”, for the purposes of the GDPR (General Data Protection Regulation), refers to Meero’s Client as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For the purpose of this Privacy Policy, Meero’s Client is the Data Controller.

“Device” means any device that can access the Meero Suite Services such as a computer, a cellphone or a digital tablet.

“Processing” or “Process” means any operation or set of operations carried out by Us and Our Meero Suite Services Providers for the purpose of providing the Meero Suite Services, regarding Data, such as collection, registration, organization, retention, adaptation or modification, extraction, consultation, use, disclosure by transmission, distribution or any other form of making available, matching or interconnection as well as archiving and/or deletion.

“Meero Suite Services” has the definition provided above.

“Service Provider” means Meero and any natural or legal person who needs to process the data for the provision of the Meero Suite Services. It may therefore refer to third-party companies or individuals whose Meero Suite Services are used by Meero to facilitate the provision of the Meero Suite Services or to assist Meero in analyzing how the Meero Suite Services is used. For the purpose of this Privacy Policy, Meero Suite Services Providers are considered Data Processors.

“Usage Data” refers to data collected automatically, either generated by the use of the Meero Suite Services or from the Meero Suite Services infrastructure itself (for example, the duration of a page visit).

“User Account” means a unique account created for You to access our Meero Suite Services, the User Account may be a Content Manager Account (administrator account) and Content Producer Account (unique user account). Content Manager Accounts give access to information shared by Content Producers on their Content Producer Accounts.

“You/Your” “User” “Authorized User” or “Data Subject” means all Users accessing or using the Meero Suite Services on behalf of Our Client.

Types of Data Collected

Personal Data

To enable You to use Our Meero Suite Services, We will be required to obtain certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• The access ID to your User Account
• The name of the company holding Your User Account
• Feedback and survey responses
• Usage Data
• Payment and Purchase Data

Unless specified otherwise, all Data requested by the Meero Suite Services is mandatory and failure to provide this Data may make it impossible for this Meero Suite Services to provide its Meero Suite Services. In cases where this Meero Suite Services specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Meero Suite Services.

Any use of Cookies – or of other tracking tools – by the Meero Suite Services or by the owners of third-party Meero Suite Services used by the Meero Suite Services serves the purpose of providing the Meero Suite Services required by the User, in addition to any other purposes described in the present document. Users are responsible for any third party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Usage Data

Usage Data is collected automatically when using the Meero Suite Services.

Usage Data may include information such as Your Device’s Internet Protocol address (i.e. IP address), browser type, browser version, Device information, the pages of our Meero Suite Services that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Usage Data may include:

• Meero Suite Services metadata. When a User interacts with the Meero Suite Services, metadata is generated to provide additional context about their use of the Meero Suite Services.
• Log data. Like most websites and services delivered over the Internet, Our servers automatically collect information when You access or use Our Meero Suite Services, recording this information in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Meero Suite Services, the pages of Our Meero Suite Services that You visit, the time spent on those pages, Your browser type and settings, the date and time the Meero Suite Services were used, information about browser configuration and plugins, and language preferences.
• Device data. Meero collects information about Devices accessing the Meero Suite Services, including the type of device, operating system used, device settings, application IDs, unique device identifiers and crash data.

Payment and Purchase Data

If you make any purchase for the Meero Suite Services, You will need to provide Your payment data. This data will include:

• Name, surname,
• Payment method,
• If using a debit or credit card, the card type, expiration date, Your card number,
• Billing address,
• VAT number,
• Mobile phone number,
• Organisation name,
• Details of your purchase,
• Price and payment history.

Data Received from Third Parties

Meero will receive some Personal Data from the Meero Suite Services Providers who are Our payment partners in order send You invoices, charge You for Your purchase, process Your payment, provide You with Your purchase.

Information Collected while Using the Meero Suite Services

While using Our Meero Suite Services, in order to provide features of Our Meero Suite Services, We collect:

• content that is transmitted to it, and information about that content, i.e. photographs/images,
  metadata.

We use this information to provide features of Our Meero Suite Services, to improve and customize the Meero Suite Services. The information may be uploaded to Meero servers and/or a Meero Suite Services Providers’ servers.

Use of Your Personal Data

We may use Personal Data for the following purposes:

• To provide, update, maintain and protect Our Meero Suite Services, the Meero Suite Services and business. This includes the use of Personal Data to support delivery of the Meero Suite Services under the Commercial Agreement, including to prevent or address service errors, security or technical issues, and to analyze and monitor usage, trends and other activities.
• To develop, test and provide additional features. Meero tries to make the Meero Suite Services as useful as possible. For example, We make Meero Suite Services suggestions based on historical use and predictive models, identify organizational trends and insights, customize Your experience of the Meero Suite Services, or to create new features and products.
• To manage Your Account: to manage Your registration as a User of the Meero Suite Services. The Personal Data You provide can give You access to different functionalities of the Meero Suite Services that are available to You as a registered User.
• To support and manage Your requests: To attend and manage Your requests to Us.
• To protect the security of the Meero Suite Services, Our company, Our clients and You.
• To contact You: as part of Our Meero Suite Services, We provide our Users with certain communications and updates, We may send You service, transactional, technical and other administrative communications, such as communications about Your User Account, Our Meero Suite Services offerings, changes to the Meero Suite Services, and important Meero Suite Services-related notices, such as security and fraud notices. We consider these communications as part of Our Meero Suite Services to You.
• To provide You with news and general information about other goods, Meero Suite Services and events which We offer that are similar to those that You are using unless You have opted not to receive such information.
• To conduct market and user research. To improve Our Meero Suite Services and troubleshoot new products and features, we may carry out research. For example we may survey Clients and Authorized Users (including Content Managers and Content Producers) or third parties about client satisfaction, user experience, the effectiveness of our marketing campaigns, and their broader interests.
• As required by applicable law, legal process or regulation.
• To send You invoices, charge You for Your purchase, process Your payment.
• To establish, exercise or defend legal claims.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, evaluate and improve Our products, the Meero Suite Services, marketing and Your User experience.

We may share Your personal information in the following situations:

• With Meero Suite Services Providers and their Affiliates (see Appendix I – list of Meero Suite Services Providers): We may share Your Personal Data, including Usage Data and Payment and Purchase Data, with Meero Suite Services Providers to provide, facilitate and maintain the Software Meero Suite Services, to monitor and analyze the use of Our Software Meero Suite Services, to contact You.
• With Our Affiliates: We may share Your information with Our Affiliates, in which case we will require those Affiliates to honor this Privacy Policy.
• With other users: if You are a Content Producer and You share personal information on the Meero Suite Services, such information may be viewed by the Content Managers on their Content Manager Accounts.
• As required by applicable law, legal process or regulation.
• We may disclose Your personal information for any other purpose provided we obtain Your consent.

Legal Basis for Processing Personal Data

We may process Personal Data for the purposes and with the persons mentioned under “Use of Your Personal Data”, pursuant to the following legal basis:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of an agreement: provision of Personal Data is necessary for the performance of the Commercial Agreement between Meero and its Client, any agreement in place between You and the Client and the agreement You enter into with Meero by signing up and/or using the Meero Suite Services.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Meero is subject.
• Our Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Meero, such as:
  – improving the Meero Suite Services and the functioning of the Meero Suite Services for its Clients and User experience,
  – monitoring the Meero Suite Services for fraud and/or other illegal or impermissible use.

In any case, Meero will gladly help to clarify the specific legal basis that applies to the Processing.

Retention of Your Personal Data

Meero keeps Your Personal Data only as long as necessary to provide the Meero Suite Services and for Meero’s legitimate and essential business purposes such as:

• Maintaining the performance of the Meero Suite Services,
• Making data-driven business decisions about new features and offerings,
• Complying with Our legal obligations,
• Resolving disputes.

The length of time week Data depends on:

• The nature of the Data,
• Why we’re processing the data (the purpose),
• Any guidelines or recommendations from the relevant data protection authorities,
• Any relevant legal obligations.

Your Personal Data will be deleted upon Your request or as soon as it is no longer required to achieve the purpose for which the Personal Data has been collected, namely, to provide the requested Meero Suite Services. If legal regulations (e.g., by fiscal, commercial, or contractual law) apply that require longer storage of Your Personal Data, or if We need Your Personal Data to assert legal claims or defend against legal claims, We will store Your Personal Data until the expiration of the corresponding storage period or until the settlement of the claims.

Meero will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Meero Suite Services, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Meero operating offices and in any other places where the parties involved in the Processing are located. Data may therefore be transferred or transmitted to, or stored and processed in, countries outside where You live, for the purposes stated in this Privacy Policy.

Specifically, Personal Data of the Data Subjects will be hosted on servers located in the following regions/countries: European Union, United States.

These Data transfers are necessary to provide the Software Meero Suite Services.

Your express consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

In the event of a change in the recipient countries, Meero shall inform the Client and all its Users and provide them with an updated list of recipient countries.

Meero will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy. All transfers of Personal Data made for the purpose of the Commercial Agreement, the provision of the Software Meero Suite Services and under this Privacy Policy, from the European Union, the European Economic Area (EEA), their Member States and Switzerland to other countries shall only be made in accordance with the Standard Contractual Clauses and/or an adequacy decision in order to ensure each Data transfer complies with applicable EU legislation.

Disclosure of Your Personal Data

Law enforcement

Under certain circumstances, Meero may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

Meero may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation,
• Protect and defend the rights or property of Meero,
• Prevent or investigate possible wrongdoing in connection with the Meero Suite Services,
• Protect the personal safety of Users of the Meero Suite Services or the public,
• Protect against legal liability.

Security of Your Personal Data

Meero protects Your Personal Data by establishing reasonable technical and organizational measures to ensure the security of the processing of Personal Data and its confidentiality.

In this regard, Meero takes every suitable precaution regarding the nature of the data and the risks presented by the processing to preserve the security of the Personal Data and especially to avoid that the Personal Data is distorted, damaged or that non-authorized third parties have access to the Personal Data: physical protection of locations, authentication procedures with personalized and secure access via identifiers and confidential passwords, encryption of certain data, etc.

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Your Rights under this Privacy Policy

Meero undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data,
• Request correction of the Personal Data that We hold about You,
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data,
• Request the transfer of Your Personal Data,
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Meero Suite Services.

Exercising of Your Rights under this Privacy Policy

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us.

You may exercise Your rights by sending a request to privacy@meero.com. If You make a request, We will try Our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data.
For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

You may file a claim with the CNIL (French Information Commissioner’s Office):
– Directly online;
– By letter: 3 Place Fontenoy – TSA 80751 – 75334 Paris Cedex 07.

For the sole purpose of providing the Meero Suite Services, improving the Meero Suite Services and the features of Our Meero Suite Services and ensuring the best quality User experience, other Meero Suite Services Providers We use may have access to Your Personal Data.

We, or Our Meero Suite Services Providers, may use tools such as, or with the purpose of:

• Analytics,
• Infrastructure monitoring,
• User database management.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Meero Suite Services in accordance with their Privacy Policies

Meero is committed to protecting Our Users’ Personal Data. We put in place appropriate technical and organisational measures to help protect the security of Your Personal Data. However, please be aware that no system is ever completely secure.

To protect Your User Account, We encourage You to:

• Use a strong password which You only use for you User Account,
• Never share Your password with anyone,
• Limit access to Your devices,
• Log out once You have finished using the Meero Suite Services.

If other individuals have access to Your User Account, then they can access Your Personal Data.

It is Your responsibility not to allow other individuals to use Your User Account or access the Software Meero Suite Services.

Our Meero Suite Services does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent
from a parent, We may require Your parent’s consent before We collect and use that information.

Meero may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or We may make changes to Our Meero Suite Services or business. We will post the changes to this page and we encourage you to review our Privacy Policy to stay informed. If We make changes that materially alter Your privacy rights, We will provide additional notice, such as via email or through the Meero Suite Services. If You disagree with the changes to this Privacy Policy, You should deactivate Your User Account.

Contact the relevant Client if You wish to request the removal of Your Personal Data under their control.

Changes to this Privacy Policy are effective when they are posted on this page.

Meero has appointed a DPO:

• Alexandra Lachowsky
• which You may contact with the following email address: privacy@meero.com

For any additional information on the protection of Your Personal Data, You may contact Us: privacy@meero.com or legal@meero.com.