PRIVACY POLICY — RISE (Recode Group B.V.)
1.1 This Privacy Policy describes how Recode Group B.V., having its registered office at Schiekade 189, 3013 BR Rotterdam, The Netherlands (“Company”), collects, uses, stores, and protects personal data in connection with the RISE platform (“Platform”).
1.2 The Company processes personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).
1.3 By using the Platform, the user (“User”) acknowledges and accepts this Privacy Policy.
2.1 The Company may collect and process the following categories of personal data:
(a) Identification data: name, email address, account credentials;
(b) Account data: login details, preferences, subscription status;
(c) Transaction data: payment status, billing details (processed via third-party providers);
(d) Usage data: interactions with the Platform, content accessed, activity logs;
(e) Technical data: IP address, browser type, device identifiers, operating system;
(f) Marketing data: communication preferences, opt-in records;
(g) Any other data voluntarily provided by the User.
2.2 The Company does not intentionally collect special categories of personal data unless explicitly provided by the User.
3.1 Personal data is processed for the following purposes:
(a) Performance of Agreements and delivery of Services;
(b) Account management and authentication;
(c) Customer support and communication;
(d) Processing payments and preventing fraud;
(e) Sending marketing communications where consent has been provided;
(f) Improving, analyzing, and optimizing the Platform;
(g) Ensuring security, preventing abuse, and enforcing Terms;
(h) Complying with legal obligations.
4.1 The Company relies on the following legal bases:
(a) Performance of a contract (Article 6(1)(b) GDPR);
(b) Consent (Article 6(1)(a) GDPR), where applicable;
(c) Legitimate interests (Article 6(1)(f) GDPR), including business development, security, and platform improvement;
(d) Compliance with legal obligations (Article 6(1)(c) GDPR).
4.2 Where processing is based on consent, the User may withdraw such consent at any time without affecting prior lawful processing.
5.1 Personal data may be shared with:
(a) Payment service providers (e.g., Stripe);
(b) Hosting providers and IT infrastructure partners;
(c) Analytics and tracking providers (e.g., Google, Meta);
(d) Email and marketing service providers;
(e) Professional advisors or authorities where legally required.
5.2 The Company ensures that third-party processors are bound by appropriate contractual and security obligations.
5.3 Personal data is not sold to third parties.
6.1 Personal data may be transferred to countries outside the European Economic Area (EEA).
6.2 Where such transfers occur, the Company ensures appropriate safeguards, including Standard Contractual Clauses or equivalent mechanisms.
7.1 The Platform uses cookies and similar technologies to ensure functionality, analyze usage, and support marketing activities.
7.2 Cookies may include functional, analytical, and marketing cookies.
7.3 Tracking technologies may include Google Analytics, Meta Pixel, and similar tools.
7.4 Non-essential cookies are used only with the User’s prior consent via opt-in mechanisms.
7.5 The User may withdraw consent or adjust cookie settings at any time through browser or platform settings.
8.1 Personal data is retained only for as long as necessary for the purposes outlined in this Policy.
8.2 The Company may retain data longer where required for legal, tax, or administrative purposes, or for the establishment, exercise, or defense of legal claims.
8.3 Upon expiration of retention periods, data will be deleted or anonymized.
9.1 Subject to applicable law, Users have the following rights:
(a) Right of access;
(b) Right to rectification;
(c) Right to erasure (“right to be forgotten”);
(d) Right to restriction of processing;
(e) Right to data portability;
(f) Right to object to processing;
(g) Right to withdraw consent at any time;
(h) Right to lodge a complaint with a supervisory authority.
9.2 Requests may be submitted to the Company and will be handled within applicable legal timeframes.
9.3 The Company reserves the right to verify identity before fulfilling requests.
10.1 The Company implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration.
10.2 Measures include, but are not limited to, encryption, access controls, and secure storage systems.
10.3 No system is completely secure; the Company does not guarantee absolute security.
11.1 The Company does not engage in automated decision-making or profiling that produces legal or similarly significant effects without appropriate safeguards.
12.1 The Platform is not intended for individuals under the age of 18.
12.2 The Company does not knowingly collect personal data from minors.
13.1 The Company reserves the right to amend this Privacy Policy at any time.
13.2 Updated versions become effective upon publication on the Platform.
13.3 Continued use of the Platform constitutes acceptance of the updated Policy.
Recode Group B.V.
Schiekade 189
3013 BR Rotterdam
The Netherlands