PRIVACY POLICY NOTICE

1. PRIVACY  NOTICE  
2. Last updated May 15, 2024 

To learn more about what information we collect and what we do with the information we collect, please take the time to review this Privacy Notice .

1. This privacy notice for Koffa ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use and access our website located at koffa-app.com, our mobile applications or any other website, mobile applications, pages, blogs, features or any content we own or operate to provide grocery and retail delivery services to you as a customer, vendor-store and delivery driver (collectively “Service”).  
2. Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices or do not feel comfortable with any of this Privacy Policy, you should immediately stop accessing or using our Services.   By accessing and using our Services, you agree to accept the terms written here. If additional prior consent to process your personal information is necessary to use our Services, we will ask for your consent.
3. If you have any questions about our Privacy Policy, please contact us at - contact@koffa-app.com.
4. From time to time as required by applicable laws and our operating procedures, we may modify our privacy policies. We will notify you of changes by noting the date of changes at the top of this page. In the case of substantial or material changes to the Privacy Policy, we will notify you prior to the effective date of the change, at the email you have specified in your account.
5. SUMMARY OF KEY POINTS
6. This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.
7. What personal information do we collect and process? 
8.  When you visit, use, or navigate our Services, we may collect and process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
9. Do we collect sensitive personal information? 
10. No, we do not collect or process any sensitive personal information prohibited under applicable law. For example, Tunisian law prohibits collection of ethnic, racial, genetic, religious, health, criminal background or philosophical and trade union belonging information.
11. Do we receive any information from third parties?
12. Yes, we may receive information from public databases, marketing partners, social media platforms, and other outside sources. 
13. How do we process your information?
14.  We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other lawful purposes.  
15. What information do we share? 
16. We may share information only as necessary to provide our Services. We share information, limited to your name and location with our delivery and store partners. We do not share or sell your information for any reason. If and when we do, we will inform you in advance and obtain your consent. 
17. What are your rights?  
    Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
18. How do you exercise your rights? 
19. The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us on the contact form on App or our website, through our Chatbox or by email -contact@koffa-app.com. We will act upon any request in accordance with applicable data protection laws.
20. TYPES OF INFORMATION WE COLLECT

      1.  Information Provided Directly By You. We collect the following types of Personal Information directly from you:

•              - Contact information. When you use or interact with the Services, we collect or obtain relevant contact details from you, including your name, telephone number, address, email address, social media address and other personal information including but not limited to birthdate and workplace and identification information. We do not collect any sensitive information as defined by applicable Tunisian law including directly or indirectly any information that reveals racial, genetic origins, religious beliefs, political, philosophical and trade union belongings, health or data relating to offenses, convictions, criminal prosecutions, sentencing and penalties and security measures or any previous criminal records.
•          - Account information. When you set up a Koffa account, we collect your username and password, and other relevant information we request necessary to provide the Services.
• If you place an order through the Services, we collect information necessary to fulfill the order, including your delivery address, the date and time of the order, the items you ordered and any special instructions; and for curbside pickup orders, we may collect your vehicle license plate number(s).
•         - Payment information. If you place an order through the Services, we collect your billing address and method of payment. Additional details regarding the processing of your payment information can be found below.

1.        - Other information.  When you place an order for delivery, you may communicate with our Services about product replacements and other questions you may have regarding the order. We collect the information contained in those communications.
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3.       2. Public Information. If you post in a public space on the Services or otherwise choose to make your Personal Information public on the Services, we collect such information. If you choose to share Personal Information publicly through the Services, please understand that we cannot control the actions of third parties who may access or collect this information.
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5.        3. Other information you provide to us. We collect any other information that you choose to provide, including your responses to surveys that you choose to participate in (for example your taste preferences or customer satisfaction surveys) and information that you provide during your interactions with our Services and customer service representatives. We may also collect information that you provide directly to us regarding an experience with one of our retail partners.
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7.       4.  Information you provide about others. In some cases, you may provide information to us about other people. For example, you may refer a friend to us, to send a gift delivery or gift card to someone. In these cases, we may collect the recipient’s name, email, and delivery address. You may also participate in Family Accounts and provide us information about your association with another Koffa customer. When you provide someone else’s information via the Services, you are responsible for ensuring that you have permission to share their information with us. You may not provide personal information about children under the age of 18.
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9.       5.  Information collected by automated means.  When you use and interact with our Services, we automatically receive certain information about your device, browser, and/or activity including:

•           - Device and usage information. Our servers will record information about the device you use to connect to the Services and your usage of the Services. This information includes your device’s IP address, your device type, browser type, internet service provider, operating system, and unique device identifiers. It also includes activity information, such as the frequency with which you use the Services, the duration of such usage, the pages that you navigate to, links that you click, information related to your shopping services for Instacart (such as orders accepted, items found, and items replaced), and other ways that you interact with the Services. We also may use third party services that employ software code to record users’ interactions with the Services. Session replays include users’ clicks, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement.
•        - Location Information. When you access the Services, we may collect information about your device’s location. For instance, if you allow the Services to access location services through the permission system used by your device's operating system or browser, we may collect the precise location of your device. We use your location information to facilitate the prompt hand-off of pickup orders (where available), to assist you in finding nearby stores for which pickup or delivery are available, and for other similar purposes. We may also use such information for analytic purposes. You can choose whether or not your device’s location information is shared with us by adjusting the settings on your device or browser, or when prompted by the Instacart application. We may also infer your general location, for example by using your device’s IP address.
•       - Cookies, Pixels, and Other Tracking Technologies. When you visit our or otherwise interact with our Services, we (and our partners, advertisers, and third-party advertising networks) may automatically collect information about you using device identifiers, cookies, pixels, and similar technologies. We use this information for various purposes, including to: make the Services function properly; understand how you use the Services; personalize your experience; and measure, manage, display, and customize the advertisements you see. Our partners, advertisers, and third-party advertising networks may also use these technologies to collect information about your online activity over time and across different websites or online services. Browsers provide choices with respect to these technologies. For example, by modifying your browser preferences, you have the choice to accept all cookies or to be notified when a cookie is set. You can learn more about cookies and how they work at www.allaboutcookies.org.
•       - Analytics. We use third-party analytics providers who may deploy cookies, pixels, and similar technologies to analyze traffic to the Services and understand the usage of the Services as well as the performance of advertisements. For example, we use Google Analytics, an analytics tool that helps us understand how our customers engage with the Services. To learn more about Google Analytics’ data practices, please visit Google’s support page.
•     - Interest-Based or Online Behavioral Advertising. To make your experience on Koffa-App and website more engaging, we may participate in interest-based advertising using cookies, pixels, and other tracking technologies. This means that you may see advertisements while using the Services that are tailored to you, or you may see advertisements for Koffa on other online services, based on your use of the Services or your browsing behavior across other online services. Some services where we may advertise belong to ad networks that use your web browsing history to choose which advertisements to display on their network services, which may include advertisements from us. You can learn more about interest-based advertising, and navigate to options that will allow you to exercise your rights to opt-out of online behavioral advertising, by visiting the Network Advertising Initiative’s Learn More Page or the Digital Advertising Alliance. In addition, some internet browsers, websites/platforms, and mobile devices allow you to exercise certain choices with respect to interest-based advertising. Please refer to the website that you are visiting, your browser, and/or your mobile device settings for additional information.

1. Please note that even if you opt-out using the tools listed above, you may continue to see advertisements from us and/or our partners; however, these advertisements will not be as relevant to you. Do Not Track. “Do Not Track” (“DNT”) is a developing standard for web browsers that aims to inform the websites you visit that you do not want information about your online activity collected over time and across third-party websites or online services. Although we do our best to honor the privacy preferences of our users, we do not interpret or respond to DNT or other similar signals from your browser at this time. For more information, visit  http://www.allaboutdnt.com.
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3.  6.  Information received from third parties. We may receive Personal Information about you from third parties. For example:

•      - Third Party Services. If you log in to the Services through a third-party service, we may receive some information about you and your use of that third party service. For example, if you choose to log in to the Services with your Facebook account, we may receive information from these companies, such as your name and email address.
•      - Koffa Partner Sites. Partners who have implemented certain Services on their websites may also let us collect information about your use of their sites or applications or share such information with us. 
•      - Other third parties: We also may collect or receive personal Information relating to you from our payment processors and partners; partners who assist us in fraud prevention or in connection with claims or disputes; other Koffa customers if they refer you to our Services, send you a gift or other order delivery through our Services; Koffa personal shoppers or drivers in connection with your delivery; partners with whom we work for advertising measurement, attribution, and analytics; companies that offer co-branded services or products; law enforcement, public health, and other governmental authorities; and
• publicly available sources.

1. 7. Payment Processors and Partners.  When you pay for orders using a credit card or other payment method on our Services, your credit card or other payment information is collected and processed by our third-party payment processors. For example, if you pay with a credit card, the payment information that you provide through the Services is transmitted directly to our payment processor. We may receive limited information about your payment card from our payment processors, such as the last 4 digits of your card number and its expiration month and year.
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3. 8.  How We Use Your Information
4. We use the Personal Information we collect or otherwise obtain about you for the following purposes:
5.      - Provide and manage the Services. We use your Personal Information in connection with the provision, administration, and management of the Services to process your transactions. If you place an order through the Services, we will use your Personal Information to process your payment and facilitate the delivery of your order. This may include information provided to us by our payment processors and partners.
6.      - Provide customer support. We use your Personal Information to respond to your customer support communications and inquiries and assist you in your use of the Services.
7.      -Communicate with you. We use your Personal Information to provide you with relevant information about us or our Services (including details about our community affairs efforts) or to request information or feedback. These communications include sending you from time-to-time important updates about the Services, communications about changes to this Privacy Policy or other applicable terms and policies.
8.     - Carry out our marketing and advertising activities. We use your Personal Information to send you marketing and promotional materials and communications, including interest-based and other advertisements, and to analyze and measure their effectiveness.  We use your Personal Information to help us understand which parts of the Services are of most interest to you and customize or personalize your experience. Based on how you browse, use, or otherwise interact with the Services, we display content, advertising, recommendations and otherwise personalize the Services to you.
9.      - Identify usage trends and improve the Services. We use your Personal Information to help us (or our service providers and partners) conduct research and analytics about your use of the Services and identify usage trends. We also use your Personal Information to identify issues, test new features or changes in our features, and improve the Services.
10.     - Maintain security and prevent fraud. We use your Personal Information to (a) help maintain the security and integrity of the Services, (b) detect, prevent, investigate, and protect you, our business, our users, and others from fraud, unauthorized transactions, and other unsafe activity, and (c) protect the safety, rights, or property of any person, the public, or Koffa.
11.      - Satisfy our legal obligations. We use your Personal Information to comply with applicable laws and regulations, respond to legal process, and/or respond to requests and communications from law enforcement authorities or other government agencies.
12.      - Other Uses.  Please note that we may combine Personal Information that we collect (as described above) with information from other sources and use the combined information for the purposes providing you with our Services.   
     
    9.  Information Disclosure
13.        We may disclose your Personal Information to the categories of recipients listed below:
14.      - Our affiliates and subsidiaries. We may disclose your Personal Information to our affiliates, subsidiaries, and other companies under our common control and ownership for purposes consistent with this Privacy Policy and other business and operational purposes.  
15.     - Our service providers and third-party partners. We disclose your Personal Information to third parties that provide services to us, including: cloud storage services; system hosting, services; research partners; data security services; fraud prevention; payment processing services; delivery services; analytics services; legal services; map services.  
16.     - Our marketing and advertising partners. We may, with your consent, disclose your Personal Information to our marketing and advertising partners, including social media platforms, third-party advertising networks, and other parties to assist in serving and measuring our, or their advertisements. 
17.        - Shoppers/Delivery Drivers. If you place an order through the Services, we will disclose your Personal Information to our shopper or delivery driver who will pick it up and deliver it to you. Please note that the shopper and driver will no longer have access to your Personal Information once your order has been delivered.
18.         - Our retail partners. We may disclose your Personal Information to our retail partners in order to provide and maintain the Services.  
19.          - Other users of the Services. We may disclose your Personal Information to other users of the Services if you choose to make such information public or you select sharing features on the Services. For example, if you share a recipe publicly on the Services, the recipe, along with your first name and last initial, will be viewable by other users. In addition, if you select to participate in a Family Account, the other Family Account member will see some of your information and carts.
20.           - Legal and Regulatory Compliance. We may share your information when we believe that the disclosure is reasonably necessary to comply with applicable laws, regulations, legal processes, or legal requests.  
21.         - Third parties in connection with a sale or business transaction. We may sell or purchase assets during the normal course of business. If another entity acquires us or any of our assets, information that we have collected may be transferred to such entity and its advisors leading up to and/or following the transaction. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, information that we hold may be considered an asset of ours and may be sold or transferred to third parties.  
22.        - Co-Branded Products. We offer services or sell product lines jointly with third-party businesses and may share your Personal Information with companies that offer co-branded services or products.  
23.       - Other Third parties. We may disclose your Personal Information to other parties at your direction and with your consent. We may also disclose your Personal Information to other parties if we believe it necessary or appropriate either: (a) under applicable law; (b) to protect our operations and those of any of our affiliates; (c) to protect our rights, privacy, safety, or property, and/or those of others; or (d) to allow us to pursue available remedies or limit damages that we may sustain.
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25. We may disclose certain non-sensitive personal information as otherwise necessary or appropriate for research and development, and community events or activities we sponsor, or for any purpose to which you consent.
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27. Please note that we may also combine Personal Information that we collect (as described above) with information from other sources and use the combined information for the purposes described in this Privacy Notice.
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29. 10.  Children's Privacy
30. We understand the importance of protecting the privacy of children, especially in the online environment. The Services are not designed for or intentionally directed to children under the legal age of consent, and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have received Personal Information from an individual under the legal age, we will take reasonable steps to remove the individual’s Personal Information from our records.
31. 11. Third-Party Websites
32. Some links on the Services may redirect you to third-party websites and services that we do not operate. We may also offer social sharing tools that let you share actions on the Services with other websites and vice versa. The privacy practices of these websites and services will be governed by their own privacy policies. We encourage you to review and understand their privacy policies before disclosing any Personal Information to them.
    12.  Information Security
33. We employ and maintain reasonable administrative, physical, and technical measures designed to safeguard and protect Personal Information under our control from unauthorized access, use, and disclosure.
34. Information Retention
35. We keep Personal Information only for as long as necessary to fulfill the purposes for which we have collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we use the Personal Information; whether we can achieve those purposes through other means; and the applicable laws that require us to retain information for regulatory purposes or permit us to retain the information to preserve our legal rights.
36. Your Choices and Data Rights
37. Under applicable law, you may be able to make certain choices and exercise certain rights with respect to our use of your Personal Information. Please note that rights and requests may be subject to applicable exceptions. We will not discriminate against you if you decide to exercise these rights. Your rights include:
38.       - Correct or update your account information and settings.  If you have created an account through the Services, you may review, correct, or update your information (including your name, telephone number, delivery address, and payment information) at any time by logging in to your account and visiting the “Account Settings” page. Please note that changes to your settings may require some time to take effect.
39.     - Exercise your marketing choices. We may send you periodic marketing and promotional emails, push notifications and/or text messages to your mobile device, and we will obtain your consent to do so, where required by law. If you no longer wish to receive our marketing and promotional communications, you may opt out of receiving them by following the opt-out instructions included in any communication that you receive from us or by visiting your Account Settings. Please note that even if you opt out of receiving marketing and promotional communications from us, we may still send you administrative and transactional messages from which you cannot opt out.
40.     - Request to Access or Delete your Personal Information.  You may request that we provide you with a copy of your Personal Information or request that we delete your Personal Information. Prior to processing your requests, we must verify the identity of the requestor to help ensure that we do not for example provide your information to another person. To do so, we require you to submit up to three pieces of Personal Information that we then match against the account information we have on file for you.
41.     - Opt-out of the Sales or Sharing (Targeted Advertising). We sometimes share information about you with certain partners including social media publishers, to enable Koffa or those partners to bring your personalized ads on third party sites or applications. We may also share information with other partners in a manner that may be considered “sales” under certain privacy laws. You have the right to opt-out of this information sharing or information sales. You may also have the right to opt out of “Targeted Advertising,” as such term is defined in applicable privacy law.
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43.  Changes to this Privacy Policy
44. We may occasionally update this Privacy Policy to reflect changes in our practices with respect to the collection, use, and disclosure of Personal Information and/or changes in applicable law.  The “Last updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make changes, we will revise the date at the top of this Privacy Policy and, in the case of material changes to this Privacy Policy, we may provide you with additional notice (such as a notice posted on the Service, or a message delivered to the email address that we have on file for you).  We encourage you to review this Privacy Policy periodically to remain informed about our information handling and privacy practices.
45. How to Contact Us
46. You may direct questions, comments or complaints about this Privacy Policy or our information handling practices to:
47. contact@koffa-app.com
48. Our Account Settings also allows you to set your communication preferences and make individual rights requests relating to your personal information. We strongly encourage you to make any individual rights requests through the Account Settings because it ensures that you have been authenticated already (based on the information you have provided to open your account and by providing the necessary login credentials and multi-factor authentication to access the account). Otherwise, when we receive an individual rights request via other intake methods, we may take steps to verify your identity before complying with the request to protect your privacy and security.