Last modified: 08/08/2020
In case you’re not familiar, Pool is an app that helps you do more things with your friends and family.
💌 Important information
Before you read on, we would like to highlight important information.
- When you use our services you share information with Pool and companies within our corporate family. Pool SAS is the data controller and responsible for processing your data.
- To create your account we only require a name and email. The name is used to identify you on Pool and your email is used to authenticate your account.
- In order to offer our services we may need to transfer your information to third parties based outside the EU. More information can be found in the section How we share information and Transfers outside of the European Union.
- We have a data deletion and retention policy in place that details how long we store your information. As a general rule, we store the information we collect as long as you are actively using the Pool app. If you haven’t opened or used the app for more than 12 months we will delete most of the data collected by us. For details, have a look at How long we keep your information.
- If you’re based in the EU, you can always file a complaint with the supervisory authority in your Member State. For example, if you’re based in France you can file a complaint with the CNIL.
- You have the right to provide us with instructions on how to handle the deletion and retention of your personal data after your death.
📦 Information we collect
There are three categories of information we collect:
- Information you provide
- Information we may get when you use Pool
- Information we collect from third parties
✌️ Information you provide
When you interact with our services, we collect information that you choose to share with us.
- Registration. When you register through the app you provide us with a name (which could be your first and/or last name, or a pseudonym…it’s totally up to you) and email.
- Profile picture. If you want, you can also add a profile picture to make it easier and more fun to interact with your friends. Of course, you're free to change your photo and name anything you’d like: just go to Profile in the app 📸
- Communications. You also provide us with any other information you send through our services, such as messages and emojis to your friends and/or our support team (firstname.lastname@example.org).
🤓 Information we may get when you use Pool
When you use our services, we collect information about how you use those services so we can provide you with a better experience. Here are some examples:
- Usage information. We collect information with regard to your activity on Pool. For example, how you communicate with your friends: names, usernames, times and dates of communications, the number of messages and emojis you exchange, your fave friends, the time at which you open messages, when you take a screenshot, and so on. This helps us understand what you like, and what we should improve!
🐴 Information we collect from third parties
We may collect information that other users provide about you when they use our services. We may also obtain information from other companies that are owned or operated by us—or any other third-party sources—and combine that with the information we normally collect through our services.
🔮 How we use information
Our main goal is to offer the best possible service so you and your friends can do more things in life together. Specifically, we may use your information to…
- …develop, operate, improve, deliver, maintain, and protect our services.
- …send you communications, including by email. For example, we may use email to respond to direct support inquiries (protip: it’s quicker and easier to use in app support!)
- …personalize the Pool service. For example, suggesting friends or profile information or giving you recommendation of things to do 🏝
- …enhance the safety and security of our products and services, for example by detecting and preventing excessive friend requests. Nobody likes spam! 👮🏻👮🏿
- …send you push notifications. Of course, if you don't want to receive push notifications, just turn them off in the Settings or look at the Pool Notification preferences.
- …verify your identity to prevent fraud or other unauthorized or illegal activity.
- …enforce our Terms of Service and other usage policies.
- …store some information locally on your device, so that you can open the app and view content faster.
📃 Bases for using your information
As an EU based company, we are only allowed to use your personal information when certain conditions apply. These conditions are called “legal bases” and, at Pool, we typically rely on one of four:
- Contract. One reason we might use your information is because it’s necessary to provide our services to you as described in our Terms of Service.
- Legitimate interest. Another reason we might use your information is because we have a legitimate interest in doing so. For example, we need to use your information to provide and improve our services, including protecting your account, delivering Pool’s services, providing customer support, and helping you find friends. An important point to understand about legitimate interest is that our interests don’t outweigh your right to privacy. So we only rely on legitimate interest when we think the way we are using your data doesn’t significantly impact your privacy or would be expected by you, or there is a good reason to do so.
- Consent. In some cases we may ask for consent to use your information for specific purposes. If we do, we’ll make sure you can revoke your consent in our services or through your device permissions. Even if we’re not relying on consent to use your information, we may ask you for permission to access data like contacts and location.
- Legal obligation. We may be required to use your personal information to comply with the law, like when we respond to valid legal process or need to take action to protect our users.
🤝 How we share information
We may share your information in the following ways:
- With other Pool users. Specifically, we may share the following information:
- Information about you, such as your name and profile picture.
- Information about how you have interacted with the service such as the day you joined, the day you became friends with another user, and messages you’ve both sent and received.
- When you are sending a friend request, we will share your city, profile name, friends you have in common, so the receiver can make a better decision on whether or not to accept the friend request.
- Any other information you have consented for us to share.
- With third parties. Specifically:
- With service providers and partners. We may share information about you with service providers who perform services on our behalf and business partners that provide services and functionality.
- With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
- Comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
- Investigate, remedy, or enforce potential Terms of Service violations.
- Protect the rights, property, and safety of us, our users, or others.
- Detect and resolve any fraud or security concerns.
- Other third parties. We may also share aggregated, non personally identifiable or de-identified information.
- With the world 🌎 If you decide to publicly share information, for example if you decide to explicitly share your Footsteps using a web link.
- With third parties as part of a merger or acquisition. If Pool SAS gets involved in a merger, asset sale, stock sale, share sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes. Things like this can happen in the wild world of tech!
- 🚨 Also be aware that your friends may take screenshots of the app and/or share some information about their interactions with you on Pool.
👽 Third-Party Content and Integrations
Our services may also contain third-party links and include third-party integrations. Through these links and third-party integrations, you may be providing information (including personal information) directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. As always, we encourage you to review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through our services.
💇 How long we keep your information
We store your information as long as necessary and as long as you’re a user of our service. We have different retention protocols in place depending on the information. As a general rule, we store the information we collect as long as you are actively using Pool. If you haven’t opened or used the app for more than 12 months we will delete most of the data we’ve collected. Don’t want us to delete your data? Don’t worry, we won’t remove data if you’re still using the app. Also note that we aggregate or anonymize information for certain purposes such as data analytics. Once we've anonymized the data we retain it indefinitely.
The following data is stored as long as you are actively using the Pool app:
- Your name and email
- Your profile picture
- Friend requests
- Your chats and images
- Your device and usage information
Of course, we also respect your requests for account deletion. The following section, Control over your information, provides more information on how to delete your account.
We take data deletion and retention very seriously and have created a dedicated page with more information on how data deletion and retention works at Pool. As a basic principle, we only keep the data we need to provide you with our awesome services.
🎛 Control over your information
It is very important to us that you have control over your information! Here are some ways we establish just that:
- Access. We strive to let you access and update most of the personal information that we have about you. Most of this can be done in the profile section of the app. If you need to access, update, or delete any other personal information that we may have, you can contact email@example.com. Note however that, we may ask you to verify your identity or provide additional information before we can provide access to your information.
- Account deletion. We don’t like seeing you leave us but if, for some reason, you want to delete your account you can always contact us at firstname.lastname@example.org to request account deletion.
- Account un-deletion. If you’ve asked us to delete your account… and then you changed your mind and totally want it back you will have up to 30 days to restore your account before we delete your information from our servers. During this period, your account will not be visible to other users 😎
- Right to object. You have the right to object to our use of your information. With many types of data, we’ve provided you with the ability to simply delete it if you don’t want us processing it anymore. For other types of data, we’ve given you the ability to stop the use of your data by disabling the feature altogether. You can do these things in the app. If there are other types of information you don’t agree with us processing, you can contact us at email@example.com.
🇪🇺 Transfers outside the European Union
We would like to draw your attention to the fact that if your friends are outside the European Union, your information will be available to them. Similar to our transfer of your data to third parties as described in How we share information, your data may be transferred and be accessible to third parties and users outside of the European Union, including to countries that may not have the same level of protection of your information as those within the European Union. Whenever we share your information outside the European Union with third parties we make sure adequate mechanisms are in place to protect your data, such as the Standard Contractual Clauses and the EU-US Privacy Shield. We have included more details in the table below.
|Purpose||Type of data||Country||Recipient||Transfer Mechanism|
|Data analytics||App usage data and user data||U.S.||Data analytics providers||Standard Contractual Clauses|
|Data storage||All user data||U.S.||Cloud storage provider||Standard Contractual Clauses|
|Support||Messages from users||U.S.||Support provider||Privacy Shield|
We’re always happy to answer any questions you may have about data sharing to countries outside the European Union. If you do have any questions simply let us know at firstname.lastname@example.org.
Complaints? If you’re based in the EU, you can always file a complaint with the supervisory authority in your Member State. For example, if you’re based in the France you can file a complaint with the CNIL.
Our services are not intended for—and we don’t direct them to—anyone under 13. And that’s why we do not knowingly collect personal information from anyone under 13. Additionally, you must be old enough to consent to the processing of your information in your country.
🏊♂️ That’s all for now
If you have any questions feel free to let us know at email@example.com