Groots Consulting UG (haftungsbeschränkt) (“we,” “our,” or “us”) is a technology company that provides shop owners and their local retail businesses innovative user interfaces to provide data analytics and insights to enhance business performance and revenue streams. It does further provide localized insights and aggregated data from semi-urban and rural communities in emerging markets to public and private companies.
Our partners (“Partners”) are shop owners and local retail businesses that have access to certain customer information (“User Data”) and their own information (“Partners Data”) that they wish to use to improve their business performance. Our services include data analytics, insight and data aggregation (“Services”) by using our products: (i) Point of Sales Application and/or (ii) Data Terminal (“Products”). You can learn more about our Services on our website at https://groots.com/services/.
Our clients (“Clients”) are private and public companies and institutions, including NGOs, International Organisations (IO, such as e.g. UN institutions), Companies (such as e.g. insurance companies, Fast-moving-consumer-goods manufacturers, media, academics, consultancies), and Government Institutions (e.g. Health Ministries) that wish to have access to certain insights and aggregated data for successful project management, product design, implementation of interventions, and Monitoring and Evaluation (M&E) activities. By using our Services, our Clients may have access to (i) anonymised data and/or (ii) raw data and/or (ii) de-identified aggregated data sets helpful for statistical analyses, predictions, and insights for their own projects. These analyses can be descriptive in nature (e.g. estimates of averages of certain socio-economic indicators) or include inference (e.g. statistical comparisons of indicators across certain sub-groups). Analytical methods used to produce such estimates will be standard statistical approaches (e.g. regression analysis) or also borrow from modern data science methods (e.g. Machine Learning approaches such as random forests). Analyses will generally target population level or aggregate level estimands, answering questions at those aggregate levels. A typical question would be: “On average, what socio-economic characteristics of households are associated with higher probabilities of having access to clean drinking water?”. We will also sometimes conduct longitudinal studies, i.e. studies in which certain users or partners are tracked over time. The objective of such analyses will be to identify trends of indicators over time and to see whether these are influenced by any outside factors – such as e.g. the implementation of a certain programme or policy.
Users of the Products can be either the Partners themselves or customers of the shop owners and local retail businesses (together also defined as “Customers”).
We work to ensure that our Services respect users’ privacy rights. To accomplish this goal, we adhere to privacy-by-design and privacy-by-default principles throughout the process of designing, building, and delivering our Services.
The terms of this Policy apply to all User Data and Partner Data to the extent it contains your personal data as defined in the applicable laws and regulations.
This Policy does not apply to information collected by our websites https://groots.com and https://tabtap.shop. For our website privacy policies, go to the “https://groots.com/privacy-policy/” or “https://tabtap.shop/website-privacy-policy/” section respectively.
This Policy also does not apply to information collected by other additional third parties who may provide information to us, as their information handling practices are covered by their own privacy policies.
The Policy’s wording can be technical; in case you have any questions, do not hesitate to write to firstname.lastname@example.org.
Our external Data Protection Officer is
TechGDPR DPC GmbH (techgdpr.com)
Prenzlauer Allee 53
10405 Berlin, Germany
USER DATA AND PARTNER DATA THAT WE RECEIVE:
We receive the following categories of User Data and/or Partner Data from our Partners: (i) geographic information (such as e.g. geolocation, city, region, province) (“Geographic data”); (ii) demographic information (such as e.g. age, gender or sex, household member composition, language spoken) (“Demographic data”); (iii) socio-economic information that broadly describes the living conditions of individuals and households (such as e.g. income, consumption, education level, infrastructure conditions, housing conditions) (“Socio-economic data”); (iv) purchase and sales data (such as e.g. number of items sold, number of times certain items were bought) (“Sales data”) ; (v) names, email addresses, and phone numbers (“Identity data”); (vi) self-reported health data (such e.g. on the appearance of certain symptoms related to the flu) (“Health data”); (vii) knowledge, attitudes, and practice (KAP) data on certain topics (such as e.g. knowledge, attitude, and practices of water treatment in a household) (“KAP data”) (viii) biometric data (e.g. finger prints – or facial topography) for the purposes of identifying users using the Services (“Biometric Data”). In some instances, we might receive voice recordings (e.g. as answers to specific questions) or pictures of certain objects (e.g. water installations in house). We will also be requesting business and revenue information from Customers such as livestock and crop composition, farm productivity, and seasonal crop incomes.
Our Partners have access to the User Data and/or Partner Data while conducting their businesses, recording and tracking their daily sales (“Point of Sales Application”), and/or collect them directly from users through the usage of the terminal installed at their premises that run simple surveys (“Data Terminal”). In addition to the product sales and survey related information being harvested in the Point of Sales Application platform, Groots may ask Partners to survey their customers (“Users”) when they patronise their business. Certain types of information that our Clients request may not be readily available to Partners, and we may ask the them to prompt their Users for information. This prompt would come in the same form of a survey question(s) directed at Partners requesting the shop owner to survey their Users.
When we obtain different User Data and/or Partner Data, we aggregate them, and we enhance such User Data and/or Partner Data to create de-identified data segments or aggregate such segments into segment lists based on our Clients’ preferences. De-identified data refers to data from which any information that could be used to identify individuals or shops is removed or amended to such an extent that identification is not possible. This includes removal of “Identity data” and “Biometric data”, which means names, birth dates, addresses, and email addresses are removed. GPS location data will either be removed or modified to such an extent that it cannot be used to identify a specific location of a shop, associating it with aggregate administrative units (e.g. cities). We then share such lists with our Clients to enable them to effectively carry out their projects and interventions, including project monitoring and evaluation.
Below we describe the User Data and/or Partner Data categories in more detail.
(i) GEOGRAPHIC DATA
We may obtain information about the geographical location of shops and users’ households. This might include specific geolocation data collected via GPS technology (i.e. location measured in latitude and longitude). More commonly, this will include information on administrative areas a shop is located in (e.g. country, province, city, etc.) and on the addresses of a shop. It might also include information on certain characteristics of a location – e.g. whether this is an urban, semi-urban, rural location.
Groots uses this data to aggregate information and estimates at the appropriate geographical and administrative level, such as for example estimating the proportion of shops and households that have received electricity in the past week in a certain province or city. Similarly, Groots uses this information to compare estimates across geographic and administrative areas. Finally, Groots uses geographical information in multivariate analyses to control for potential biases introduced by geographical factors.
(ii) DEMOGRAPHIC DATA
We may obtain demographic User Data and/or Partner Data from our Partners, such as e.g. age, gender or sex, household member composition, language spoken in a household. Such demographic data is data commonly collected in surveys implemented e.g. by national statistics offices or international organizations, such as the World Bank. This data is used to describe the general demographic characteristics of a population.
Groots uses this information to create demographic segments about users, for example users who are “males, 30 to 34, have access to clean water”. It will use this information to compare estimates of certain indicators across groups of individuals (e.g. proportion of households with access to clean water among female and male-headed households). It will also use this data to assess representativeness of estimates by comparing aggregate demographic information of its users to demographic characteristics of a reference population, derived from publicly available data (e.g. census or survey data). Finally, it will use this demographic data in multivariate analyses to control for any variation that might be due to demographic characteristics.
(iii) SOCIOECONOMIC DATA
We may obtain information about the socioeconomic status of individuals and households. This will include information about e.g. income, consumption, education level, infrastructure conditions, housing conditions. Such socioeconomic data is commonly collected in surveys implemented by national statistics offices or international organizations, e.g. via the LSMS surveys of the World Bank. The data is used to describe livelihoods and wellbeing of individuals and households.
Groots uses this information to describe, at an aggregate level, the living conditions of individuals and households. It will also compare estimates of certain indicators across groups of households that share similar conditions. Finally – as before – it will include this information in multivariate analyses.
(iv) PURCHASE DATA
We may obtain purchase data from our Partners, such as items that have been bought in stores, the number of certain items sold over a period of time, and the prices of those items. Overall, this data will describe transactions in a shop – both in terms of sales but also in terms of purchases by shop-owners e.g. to restock items.
Groots uses this information to describe sales transactions across shops. It also uses price information to calculate price indices of certain items. Finally, Groots analyses individual Partners’ data and feeds results back to them in order to help them run an accounting system for their shop.
(v) NAMES, EMAIL ADDRESSES AND PHONE NUMBERS (“Identity data”)
We may collect such information to identify Customers, and to potentially contact them via messages and emails. This data will not be used in analyses. This “Identity data” will also not be shared with our Clients.
Partners who will be hosting the Data Terminal in their shop will be asked to provide: first and last name, phone number, fingerprint biometrics, GPS pin location, and (possibly) bank account details. Bank account details will be used to reward Partners for every of their customer that completes a survey. A portion of that reward will be passed onto the Users for their participation. Customers that provide answers to survey questions on the Data Terminal will be asked to provide first and last name, phone number and biometric information.
(vi) HEALTH DATA
We may collect self-reported health data. This means that we might ask our Users and Partners questions about health-related issues, e.g. whether they are experiencing any flu-related symptoms or symptoms of digestive problems. We will not collect any human bio samples or health measurement data directly.
Groots will use self-reported health data to produce aggregate estimates of the prevalence of certain self-reported health related conditions, such as for example the flu.
(vii) KNOWLEDGE, ATTITUDE, AND PRACTICES (“KAP DATA”)
We may ask Users and Partners about their knowledge of, views on, and behaviour with respect to certain issues that might be of interest to our Clients. For example, we might ask them about whether they know about certain hygiene practices (e.g. washing hands), whether they think they are important, and whether they implement them.
Groots will use this data to report, at an aggregate level, about the prevalence of certain KAP indicators and to compare these across different sub-groups of users. The results of such analyses will then be shared with Clients.
(viii) BIOMETRIC DATA
With previous explicit consent, we may collect and use biometric data (e.g. fingerprints) in order to identify users of our technology. This will ensure that individuals can enter data over time in a way that it can be back-linked to previously entered information. We will not use biometric data in our analyses.
Groots intends to collect biometric data on Partners and their customers that use the Data Terminal. The biometric data will come in one of two forms (either or) – optical fingerprint biometrics or facial recognition biometrics. We currently are planning on using only fingerprint data as the off-the-shelf systems available seem to be more reliable than facial recognition due to accuracy issues for non-Caucasian individuals. However, technological limitations with regard to camera resolution may necessitate the use of facial recognition systems instead.
The purpose of the biometric information is to allow low literacy individuals from registering onto the Data Terminal platform without the need to provide traditional login and password information. During the registration process, with prior explicit consent, we will also be requesting phone numbers for what we predict will be our client’s needs to follow up with customers – i.e. we will be sharing the phone numbers with our Client.
We will not be using the biometric data to identify individuals are who they say they are. We will not cross-matching biometric data with government databases or cross-matching biometric data with government issued IDs to be able to accurately say customer–X is John Smith. Instead the biometric data is to prevent fraud use of our Services by preventing repeat Customers from using the system to obtain a monetary or product incentive when we only need one response to the survey questions from each Customer. In other instances when there are more than one survey to complete (i.e. a single customer can use the platform multiple times to complete all the different surveys), then the biometric registration will be used to track individual Customers to sequentially present surveys for completion.
Biometric systems provide two options for data storage – 1. in device, or 2. cloud based. As we will not be sharing the biometric data with any third party, even in the case where the biometric data is stored on a cloud, it will be part of the Groots database platform. Since we do not use the biometric data to identify individuals are who they say they are and instead are simply using it to ease registration, there is a high probability that the biometric data will be stored in-device to allow for 1-N internal cross-checking of biometric information to that which is stored in tablet. When stored in-device, the biometric data would be structured and anonymised to prevent Customer identification in case the device is stolen. Names and phone numbers will also be anonymised within device and database to prevent access to information.
(ix) APP USAGE DATA
We use “Google Firebase” a platform for developing apps for mobile devices that provides us with the following features: (i) information on how the users interact with our App (such as, i.e. the first time an app is opened, the uninstalling of an app, updates, crashes or the frequency of use of the app are recorded); (ii) analytics reports based on such information. These data help us understand clearly how the Users behave while using our App, so that we can make informed decisions regarding our App features and performance optimizations. For more information on Google Firebase and privacy, visit https://www.google.com/policies/privacy/ and https://firebase.google.com/
LEGAL BASIS FOR PROCESSING PERSONAL DATA
Our Services enable our Clients to access to certain insights and aggregated data for successful project management, product design, implementation of interventions, and Monitoring and Evaluation (M&E) activities. To achieve this goal, we need to process your personal data. We base the processing of your Personal Data on your consent.
We process your personal data if you have consented to the processing activity according to Article 6(1) lit. (a) of GDPR. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent but will not impact the lawfulness of processing based on your consent before it was withdrawn.
WITH WHOM DO WE SHARE USER DATA
We share User Data with the following categories of third parties: (i) our hosting provider Amazon Web Services; (ii) NGOs, (iv) companies, (v) International Organisations, (vi) Government Institutions.
NGOs we work with might include international NGOs such as for example OXFAM, CIFF, and the Bill and Melinda Gates Foundation.
Companies we work with might include international insurance companies or consultancies, media outlets, FMCG manufacturers and distributors, academics and others.
International Organisations (IO) we work with might include those of the UN System (e.g. UNICEF), the World Bank, the European Union, and other IO working in International Development.
Government Institutions we work with might include ministries and other Government agencies, such as e.g. energy agencies, health ministries, etc.
These third parties may only see the list of segments created based on User Data and/or Partner Data. Data are not shared in a way that individuals can be identified – which means that any ‘Identity Data’ and other data that allows to identify individuals (e.g. birth dates, names of household members, etc.) will be removed from any lists shared. Where possible, only aggregated data will be shared with Clients. We will also disclose your User Data and/or Partner Data in response to valid legal processes, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements. We also may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. We are required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In addition, we may transfer your information to an entity or individual that acquires, buys, or merges with us, or our affiliates. In these cases, we will require the acquiring company to carry on the material terms of this Policy, including the requests for deletion.
WHEN WE TRANSFER USER DATA INTERNATIONALLY
When we share User Data and/or Partner Data with the recipients described above, such sharing may constitute a transfer outside of your home location. By law, we are required to ensure that the level of protection guaranteed for your personal data by the European laws is not undermined by such transfer. We enter EU Standard Contractual Clauses with respective User Data and/or Partner Data recipients.
HOW WE PROTECT PERSONAL DATA
We take appropriate technical and organizational safeguards to protect any personal data we receive from theft, loss, and unauthorized access. We follow generally accepted standards to protect personal User Data and/or Partner Data throughout the entire use cycle starting from the initial transfer until deletion. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
Your personal data belongs to you. You have the following rights with respect to your personal data: (i) right to request confirmation as to whether or not we process any of your data, and, where that is the case, right of access to your data; (ii) right to request rectification of inaccurate personal data; (iii) right to request erasure of your personal data; (iv) right to restrict processing of your personal data if certain conditions are met, e.g., if you believe the personal data we hold about you is not accurate; (v) right to object to us processing your personal data; (vi) right to data portability, which only applies, however, if you provided us your personal data directly.
The options to exercise these rights are described below.
To make us erase your personal data associated with a User and/or a Partner from our system, Users and/or Partners can submit your request to our Privacy Team at email@example.com. We will delete all User Data and/or Partner Data associated with such request. Alternatively, at any time Users and/or Partner can access the Data Terminal and delete all the information previously provided and made available in their account.
In particular, Partners can submit a deletion request to our Privacy Team at firstname.lastname@example.org and/or delete their account and uninstall the Point of Sales Application.
The deletion request will be forwarded to all Clients that might have received access to the relevant Users Data.
Some data will remain stored in anonymised form in order to allow future analyses to be carried out. This means that we will remove all information that allows to personally identify individuals or households. This relates to the “Identity data” but also to any geographic, demographic and socioeconomic data that could reasonably be used for identification purposes. Names, birth dates, addresses, GPS locations, biometric information, will be removed.
Apart from all the above rights, you can also lodge a complaint with a supervisory authority if you believe we or our Partners infringed upon your rights.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.We retain data until the occurrence of the following events: (i) request from a Partner to delete certain User Data; or (ii) the User submits a deletion request of associated data; or (iii) expiration of Groots defined retention period of:
- For each Partner: 24 months from the last usage of the Point of Sales Application.
- For each User: 24 months from the last data collection point. We might conduct longitudinal studies in which the same users will be asked to provide information about certain issues repeatedly over time. Generally, the pauses between such points in time will not be longer than 24 months. This means that we will get in touch with users within that time frame to ask them to provide information again. Hence, this data will generally not be stored beyond this time period after the last data collection point.
Some data might be stored for the purpose of future research without retaining any identifiable information. This means that we will remove any data that we consider to be data that can be used to identify individuals or households (e.g. names, birth dates, addresses, GPS locations, biometric information). The purpose of this is to ensure that future analyses can be conducted by referring back to longitudinal data as well – e.g. from a certain area. Where possible, we will store such information in aggregate form that will still allow to carry out key analyses.
We do not knowingly collect data directly from children, the features of the Data Terminal are intended to prevent any use by children (i.e. the height of the Terminal shall be unreachable by users under the age of sixteen (16)).
We might collect data of children from their parents and, in such cases, we take additional steps to protect children privacy, including: (i) re-notifying parents about the types of information we may collect on their children and related usage; (ii) obtaining their explicit parental consent.
If you have any questions or suggestions about this Policy and our privacy practices, please contact us at: email@example.com
Groots may from time to time change this Policy or change, modify, or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, Groots will post a notice advising of such change at the beginning of this Policy and on this site’s home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.