Last updated: April 27, 2023
WHICH DATA IS COLLECTED?
Information that identifies you or can be used to identify or contact you is defined as Personal Data. Examples may include your name, address, e-mail address, telephone number, birth date (primarily for eligibility purposes), and billing and credit card information.
We collect the following personal data:
your full name
your valid e-mail
your photo from a social media (Facebook)
your Identifier for Advertisers (IDFA)
your Identifier for Vendors (IDFV)
This data is stored on our secure web servers, provided to us by Amazon Web Services, Inc. under the Service Agreement and Data Processing Agreement.
HOW IS YOUR PERSONAL DATA USED?
If You Use Our Online Products:
We gather data; sometimes, it contains Personal Data that when you choose our Online Products is provided directly to us (available either for free or on a subscription basis) such as our Mobile Application "FreeFM".
We also gather data through surveys, questionnaires, self-assessment quizzes, contests which you provide directly to us. The information obtained in this way is used to tailor your customer experience while using our Online Products.
Additionally, we gather data automatically, including Personal Data, when you visit our website or use our Online Products. Such information includes your browser type, IP address, error logs, operating system, and other similar data.
This aggregated data cannot be used to identify you and is utilized by us to monitor trends, to monitor Online Products' use, administer the Online Products, and collect general information about how our Online Products are used.
The legal basis for such processing of your Personal Data is our legitimate interests (Art. 6(1)(f) GDPR) in customizing the content of our services in line with user preferences and in further improving our Online Products.
It is important to note that providing us with your personal data is not a legal requirement. However, we will not be able to provide you with a complete range of Online Products without such information.
If You Become A User
To be able to access some of our Services, you must first become a user. During this process, you are required to provide us with personal information such as your name, address, and e-mail address. Additionally, if you become a user of our Services, related data, including credit/debit card and billing information, will be processed. This data is used exclusively for billing and subscription purposes. The handling of such information is essential for our services to work for users correctly. The legal basis for such processing of your Personal Data is, therefore, Art. 6(1)(b) GDPR.
Regarding health-related information, we will only process such data with your prior consent, according to Art. 9(2)(a) GDPR, except where permitted or required by applicable law. To adhere to the contract, you are required to provide such information. Without this information, we will be unable to undertake the services previously stated above.
Sending you Service Updates
Your Personal Data will be used to keep you updated on important service announcements, Online Products' updates, and if you subscribe, such updates will also include your billing account status. In addition, we will communicate transactional information regarding your subscription or verify login details when you become a user. These updates include important information regarding the use of our Online Products.
To maintain the performance of our products, the handling of your Personal Data is crucial. The legal basis for such processing of your Personal Data is, therefore, Art. 6(1)(b) GDPR. We will be unable to provide you with service-related communication without the provision of such Personal Data, which you are contractually obliged to provide us.
Contacting our Customer Service
We will respond to your queries and manage services such as subscriptions should you contact our customer service. The communications channel will be according to your preference (telephone, e-mail, etc.) Such processing of your Personal Data is necessary for the performance of our services; the legal basis for such processing of your Personal Data is, therefore, Art. 6(1)(b) GDPR. We will be unable to provide you with customer service-related communication without the provision of such Personal Data, which you are contractually obliged to provide us.
Subscription to Newsletters and other Marketing Communications
You will have the option to agree to receive newsletters and additional information on our products and services when subscribing to our Online Products. For example, we will send you promotional newsletters and information regarding events and surveys by social media and e-mail if you choose to "opt-in". The legal basis for such processing of your data is your consent (Art. 6(1)(a) GDPR) or – if you are a user – our legitimate interest (Art. 6(1)(f) GDPR) in providing you with relevant marketing information.
Without your Personal Data, we will be unable to keep you informed on our products and services. However, please note that you are not legally required to provide your Personal Data. At any time of your choosing, you can opt-out of receiving such communication by following the steps regarding the handling of such information.
Using our Social Features
Features such as messages and other similar activities can be found on our Online Products where users can communicate with each other. A "Public Profile" feature is also offered in addition. This allows you to share information about yourself. Including Personal Data if you choose to do so within the "Social Features" section of our Online Products.
In utilizing this feature, you should be aware that we have no control over how others might use your personal data. This includes receiving unsolicited messages from other users.
You can contact us using the contact details below if you wish for specific content generated by you to be removed. Any Personal Data posted via the Social Features are processed in order to provide you with the respective service, and the legal basis is, therefore, Art. 6(1)(b) GDPR. Unfortunately, you will be unable to use the Social Features function without providing your Personal Data even though you are not legally required to provide us with said information.
SOCIAL PLUG-INS AND OTHER THIRD-PARTY FEATURES
To the extent certain third-party website features are available on our Online Products, the following terms apply:
We use plug-ins of several social networks like Facebook, Google, Twitter, Instagram, TikTok, etc., to allow our Online Products users to share content found on our Online Products easily and connect with their friends via such social networks.
Your device establishes a direct connection to the servers operated by the provider of the social network whenever you view a page of our Online Products containing such a plug-in. This means the social plug-in content is transferred by the network provider directly to your device and embedded in our Online Products being shown.
Visiting our Online Products while being logged in to your social network.
Your visit will be sent to the network provider, then the provider of the social network can match your visit to our site with your social media account. It is important to be aware that a data transfer is started when you visit our Online Products to interact with the plug-in. To avoid this, you have to log out of your social network account before visiting our Online Products. To be aware of the privacy policies of Facebook, Google, Twitter, Instagram, TikTok, etc., please refer to the respective privacy policies, data collection, and analysis of such websites. This will allow you to modify your settings to protect your privacy.
The option to connect your FreeFM account with third-party applications or devices may be offered by our Online Products. Should you use such applications by connecting your FreeFM account, the third-party provider, will receive the information from us that you have a FreeFM account.
HOW WE SHARE AND DISCLOSE PERSONAL DATA
Unless required by law, we will not sell, share, or transfer or otherwise distribute your Personal Data to third parties. Unless required by law according to Art. 6(1)(c) GDPR, unless required for the purpose of your contract according to Art. 6(1)(b) GDPR unless the third party acts as a data processor on our behalf according to Art. 28 GDPR or you have given us express consent to do so according to Art. 6(1)(a) GDPR.
In order to provide external analytical services, some of your Personal Data is collected and shared by the following companies:
The collection of such data occurs through the Software Development Kit (SDK) built into our products.
We do not gain access to such data and do not store it on our servers. Instead, the above companies assume full responsibility for the storage and processing of such data.
To exercise your legal rights according to the GDPR, you can make a request both directly to these companies and us. Rest assured, we will forward your request on time!
In order to facilitate or offer our services, we also use third-party service providers, and as such, we share your Personal Data with said service providers to allow them to perform their service on our behalf. For example, we use a mailing company to distribute marketing messages via e-mail; payment service providers for specialist providers for payment collection and fraud screening; to bill you for goods and services and for a shipping company to fulfill orders; social media, and other agencies to manage our social media and other advertising campaigns; a cloud provider for our CRM system and an external provider for the hosting of our e-shop; a call center provider to facilitate customer service.
Some of the companies described above are located outside of the European Economic Area with which we share your Personal Data.
In order to maintain sufficient protection of your Personal Data in this context, we use standard data protection clauses adopted by the European Commission according to Art. 46(2)(c) GDPR with such companies or certifications of such companies according to Art. 45(1) GDPR. You can request further details by contacting us on the contact details below.
Sharing of Personal Data with other Developer entities or service providers.
In order to respond to any claims, in protecting our rights or the rights of a third party, in ensuring the safety of any person or in preventing any illegal activity, or in pursuing our legitimate interest in applying or enforcing our terms and conditions, we can also disclose your information, (including for the purposes of fraud protection and credit risk reduction), according to Art. 6(1)(f) GDPR.
We will obtain your consent prior to sharing your Personal Data with other companies if required under applicable data protection laws. In such instances, the legal basis is Art. 6(1)(a) GDPR.
IS MY PERSONAL DATA USED FOR ANY OTHER PURPOSES?
YOU HAVE THE FOLLOWING RIGHTS:
Right of access (Art. 15 GDPR):
You have the right to request confirmation as to whether we handle your Personal Data and, where that is the case, to request access to the Personal Data we have about you.
Right to rectification (Art. 16 GDPR):
You have the right to request the correction of incorrect Personal Data.
Right to erasure (Art. 17 GDPR):
You have the right to request the erasure of Personal Data without undue delay under certain circumstances, e.g., if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Art. 6(1)(a) GDPR and no other legal ground for the processing.
Right to restriction of processing (Art. 18 GDPR):
You have the right to request us to restrict the handling of your Personal Data under certain circumstances, e.g., if you think that the Personal Data we handle about you is unlawful or incorrect.
Right to data portability (Art. 20 GDPR):
You have the right to receive your Personal Data you have provided us in a structured, commonly used, and machine-readable format, and you have the right to transmit that information to another controller without hindrance or ask us to do so under certain circumstances.
Right to object (Art. 21 GDPR):
You have the right to object to the handling of your Personal Data under certain circumstances, in particular, if we process your Personal Data on the legal basis of legitimate interests (Art. 6(1)(f) GDPR) or if we use your Personal Data for marketing purposes.
You can execute your abovementioned rights by contacting us on the contact details mentioned below.
RIGHT TO LODGE A COMPLAINT BEFORE THE DATA PROTECTION AUTHORITY
You have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at the contact details mentioned below, and we will assist you in identifying the respective competent supervisory authority.
Your Personal Data is stored along with other information for as long as it is needed to ensure you can use our Online Products to comply with relevant laws (including those regarding document retention) and provide services to you. Your Personal Data is also stored in order to resolve any disputes that may arise with any parties, which are otherwise deemed necessary for us to conduct our business. Please contact us on the contact details listed below if you have any questions regarding the specific retention times for certain types of Personal Data.
AUTOMATED INDIVIDUAL DECISION-MAKING
Based on the automated processing of your Personal Data. We do not use your Personal Data to make decisions with legal or similar effects for you.
WHOM DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
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