LEGAL
Last updated: 11 May 2023
In the event of any inconsistency between languages or any other dispute, the English version shall prevail.
Thank you for using www.figtion.com and the associated mobile application (collectively, the “Site“). The Site is an Internet property of FIGTION LIMITED (“Company,” “we,” “our” or “us“). This Privacy Policy (“Privacy Policy“) covers our treatment of personal information and other information that we collect when an end-user visitor to the Site (“User,” “you” or “your“): (a) accesses or uses the Site; (b) accesses and/or views any of the: (i) links to third-party resources and other information (“Third-Party Links“); and/or (ii) blog posts, text, video and/or other information made available on the Site (the “Informational Content,” and together with the Third-Party Links, the “Content“); (c) accesses the comments sections associated with the blog posts and/or other interactive features made available on the Site (“Interactive Services“); and/or (d) utilizes the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by, Company and/or Company’s third-party service providers and online aggregators (“Third-Party Service Providers”) (collectively, the “Contact Services,” and together with the Site, Content and Interactive Services, the “Site Offerings“).
Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us
at: emailing us at: contact@figtion.com
Capitalized terms not defined herein shall have the meanings set forth in the Website Terms and Conditions (“Terms and Conditions”). IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS. THESE TERMS ARE BINDING IN EVERY JURISDICTION IN THE WORLD EXCEPT TO THE EXTENT THEY ARE INCONSISTENT WITH AND SUPERSEDED BY APPLICABLE LOCAL LAW.
PRIVACY POLICY SUMMARY
This is a summary of our Privacy Policy. To review our Privacy Policy in full, please click here, or scroll down.
1.What does this Privacy Policy cover?
This Privacy Policy is designed to describe:
●How and what type of personal information we collect and use
●When and with whom we share your personal information
●What choices you can make about how we collect, use, and share your personal information
2. What personal information do we collect and use, and how do we collect it?
We collect personal information when:
●You give us the information
●We collect it automatically
When you create an account on the Site, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit the Site or download and use our App. As discussed in greater detail below, we may ask you to submit some or all of the following information: (a) your e-mail address; (b) your full name; (c) your telephone number; (d) any other information collected via the Contact Services form; (e) your date of birth; (f) your mailing address; (g) your ID copy; (h), your credit card number; and (i) any other information requested by the Company.
3. How is your personal information shared?
The full Privacy Policy details how personal information is shared.
4. What are your rights and choices?
You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service. Our Privacy Policy has more information about the options and data protection rights available to you.
5. How to contact us
More information about our privacy practices is in our full Privacy Policy. You can also contact us as described below in the “Contact Us” section to ask questions about how we handle your personal information or make requests about your personal information.
PRIVACY POLICY
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of the State of California, certain other privacy-related rights may apply to you, including the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the names and addresses of those third-parties. Please see our Additional Provisions for California Residents below for a more complete description of your rights as a California resident.
YOUR EUROPEAN AND U.K. PRIVACY RIGHTS
If you are a resident of the European Union, certain other privacy-related rights may apply to you, including the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the names and addresses of those third-parties. Please see our Additional Provisions for European and U.K. Residents below for a more complete description of your rights as a resident of the European Union.
PERSONAL INFORMATION COLLECTED
For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information when you access certain of the Site Offerings and complete the required information request form and/or otherwise provide such information to us. Where a User attempts to utilize the Contact Services, that User may be required to submit, and Company may collect, some or all of the following information: (a) the User’s e-mail address; (b) the User’s full name; (c) the User’s telephone number; (d) account information for signing up, subscribing for premium services and setting up 2-step verification, and (e) any other information collected via the Contact Services form.
Upon entering Contact Data and clicking on the applicable submission button on the Site: (i) Company may pass your Contact Data along to one (1) or more of its marketing partners and/or affiliates (collectively, “Marketing Partners”) or Third-Party Service Providers; (ii) you may be contacted by Company and/or one (1) or more of its Marketing Partners or Third-Party Service Providers regarding your request; and/or (iii) you may be contacted by one (1) or more Marketing Partners with third-party offers that Company feels may be of interest to you. Where Company contacts you in connection with your submission of Contact Data, a Company representative may request additional information including some or all of the following: (A) User date of birth; (B) User mailing address; (C) User ID copy; (D), User credit card number; and (E) any other information requested by the applicable Company representative.
USE OF PERSONAL INFORMATION
By submitting your personal information by and through the Site Offerings, you agree that we may share or otherwise provide that personal information to any third-party for any purpose permitted by law, and we may work with other businesses to bring selected third-party offers to you. These businesses and third-parties may include, but are not limited to: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); (d) direct marketers; (e) art galleries and auction houses. We may also use your personal information to send you promotional messages regarding various Company products and/or services, as well as third-party products and/or services that we think may be of interest to you.
Without limiting the foregoing, with your permission, we may share your User Data with those Third-Party Service Providers that you request to contact you. These Third-Party Service Providers may use your User Data to offer you products and/or services, including verifying the provenance of art objects registered with us, and for any other lawful purposes, subject to any restrictions contained herein. The information that you supply directly to any Third-Party Service Provider shall be governed by the applicable Third-Party Service Provider’s privacy policy. Where you submit personal information, we use the personal information that you make available to personalize your experience with the Site and to facilitate the delivery of the applicable Site Offerings to you, including to respond to any inquiries made by you. Our Services may also contain links to Third-Party Service Providers with social media features such as Facebook, Twitter or Discord and we may record your interaction with these links.
We may also provide your information to third-party companies and individuals to perform certain functions on our behalf. Examples include reconciling information about the purchasers of art objects registered with us, verifying and securing information stored in blockchain form, sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users’ personal information as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.
We will also use your personal information with your permission, for customer service, to provide you with information that you may request, to customize your experience with the Site Offerings and/or to contact you when necessary in connection with your use of the Site Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site Offerings. We may also combine the information we have gathered about you with information from other sources. When you sign in to the Service, we will also collect and store authentication information for 2-step verification purposes.
We reserve the right to release current or past personal information: (A) in the event that we believe that the Site Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (C) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.
You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time. Users should also be aware that courts of equity in any jurisdiction, including without limitation U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission.
IP ADDRESSES/BROWSER TYPE
We may collect certain non-personally identifiable information about you and your desktop or laptop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site Offerings.
COOKIES
When a User visits the Site, we may send one (1) or more cookies and/or gif files (collectively, “Cookies“) to assign an anonymous, unique identifier to the applicable User’s computer. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Site Offerings, including for storing User preferences and tracking Site-User trends (such as pages opened and length of stay at the Site).
Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a User rejects a Cookie, he or she may still use the Site Offerings; provided, however, that certain functions of the Site Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.
Company reserves the right to transfer and/or otherwise use as set forth above aggregate or group data about Users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Site Offerings Users as a group, without disclosing personally identifiable information.
BEHAVIORAL TRACKING/ADVERTISING
Company, as well as third party entities such as Google®, use Cookies, pixels, beacons, and other tracking technology (collectively, “Tracking Technology”) in connection with the Site for purposes of tracking Users’ activities (such as websites visited, advertisements selected and pages viewed) after they leave the Site. Company, and its third-party partners, may use this Tracking Technology to target applicable Users with advertisements featuring Company products and/or services, as well as third-party products and/or services, that may be of interest to applicable Users. In addition, Company may use one or more Third-Party Service Providers in order to better understand our Users’ needs and to optimize the Company Offerings. Each such Third-Party Service Provider is a technology service that helps us better understand our Users’ Site-related experience (e.g. how much time they spend on which Site pages, which links they choose to click on, what Users do and do not like, etc.) and this enables us to build and maintain our Company Offerings with User feedback. Each such Third-Party Service Provider may use cookies and other technology to collect data on our Users’ behavior and their devices (in particular, the various devices’ IP addresses (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only) and preferred language used to display our website). Neither the Third-Party Service Provider nor Company will ever use this information to identify individual Users or to match this information with additional data on an individual User.
In general, Users may be able to disable some, or all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, Users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative, https://optout.networkadvertising.org/?c=1
or Digital Advertising Alliance, https://optout.aboutads.info/?c=2&lang=EN; for our mobile app, the AppChoices opt-out is available at https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en_US and https://apps.apple.com/app/appchoices/id894822870
Further, Users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Site.
INTERACTIVE SERVICES
If you engage in any interaction with Company, other Users or any third-party via the Interactive Services, you should be aware that the personal information that you submit by and through the Interactive Services may be read, collected and/or used by other Users of these services, and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire. We are not responsible for the personal information that you choose to submit via the Interactive Services.
THIRD-PARTY WEBSITES
This Site may contain links to third-party owned and/or operated websites including, without limitation, websites owned and/or operated by Company’s Third-Party Service Providers and/or Marketing Partners. Company is not responsible for the privacy practices or the content of such entities and/or websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites and entities have separate privacy and data collection practices and Company has no responsibility or liability relating to them.
DATA SECURITY
We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts Users to enter sensitive information (such as financial information, driver’s license/ID card/passport number, or Social Security Number), and when we store and transmit such sensitive information, that information is encrypted at rest and in transit with TLS, AES RSA and/or blockchain.
Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our Users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need User personal information to perform a specific job are granted access to User personal information. Our employees are dedicated to ensuring the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers on which we store User personal information on are kept in a secure physical environment. We also have security measures in place to protect against the loss, misuse or alteration of personal information under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; note, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.
In compliance with applicable laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
MINORS
Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Company does not knowingly solicit or collect information from visitors under eighteen (18) years of age.
OPT-OUT/UNSUBSCRIBE
To opt-out of receiving e-mail and other forms of communications from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: contact@figtion.com.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from Company, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to Company, as applicable.
DELETING, MODIFYING AND UPDATING YOUR INFORMATION
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: contact@figtion.com. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your personal information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the personal information that we have on file for you.
Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
TRANSFER OF PERSONAL INFORMATION INTERNATIONALLY
If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international borders. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.
CHANGES TO THIS PRIVACY POLICY
Company reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, Company will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) by any other reasonable means acceptable under applicable law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.
CONTACT US
If you have any questions about this Privacy Policy or our privacy practices in general, you may email us as at: contact@figtion.com
ADDITIONAL PROVISIONS FOR CALIFORNIA RESIDENTS
These Provisions for California Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the State of California (“CA Users”), and are to be interpreted in a manner consistent with the provisions of California Consumer Privacy Act (“CCPA”)(2020) and the California Online Privacy Protection Act (“CalOPPA”) (2004), as applicable
CATEGORIES OF INFORMATION WE COLLECT
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). We have not, however, collected the following categories of personal information from CA Users within the last twelve (12) months (category definitions are from the CCPA definition of “personal information”) :
Category A -- Identifiers.
Category B -- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Category C -- Protected classification characteristics under California or federal law.
Category F -- Internet or other similar network activity.
Category I. -- Professional or employment-related information
Personal information does not include:
●Publicly available information from government records.
●De-identified or aggregated User information.
●Information excluded from the CCPA’s scope, such as:
■health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
■personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
●We may obtain such personal information from the following categories of sources (with the specific categories of personal information indicated in parenthesis.
●Directly from our CA Users. For example, from online registration forms that our CA Users submit to us related to the products and/or services that we offer by and through the Site. (Category A, B, C and I)
●Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, C, F and I)
●Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners, such as Google®. (Category F)
●When our CA Users interact with us on our social media accounts, including commenting on and/or liking our posts. (Category F)
●Directly from CA Users via online registration forms that our CA Users submit to us in order to enter a promotion or sweepstakes featured on the Site. (Category A, B, C and I)
●From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Category A, B, C and I)
●From third-party data brokers or aggregators. (Category A, B, C and I)
●From publicly available sources, such as Internet search engines. (Category A, B, C and I)
USE OF PERSONAL INFORMATION
We may use or disclose the personal information that we collect (including the following specific items of personal information: (a) e-mail address; (b) full name; (c) telephone number and (d) account information for signing up, subscribing for premium services and setting up 2-step verification; for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis) to fulfill or meet the reason for which the information is provided, such as:
●To provide you with information, products or services that you request from us. (Category A, B, C, F and I)
●To create, maintain, customize and secure your account with us for 2-step verification purposes. (Category A, B, C and I)
●To enable you to enter a promotion featured on the Site. (Category A, B, C and I)
●To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Category A, B, C, F and I)
●To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, C, F and I)
●To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Category A, B, C, F and I)
●To improve the Site and better present its contents to you. (Category A, B, C, F and I)
●For customer service purposes and to respond to inquiries from you, including links to Third-Party Service Providers with social media features such as Facebook, Twitter or Discord. (Category A, B, C and I)
●For testing, research, analysis and product development. (Category A, B, C, F and I)
●As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, C, F and I)
●To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, F and I)
●As described to you when collecting your personal information or as otherwise set forth under applicable law. (Category A, B, C, F and I)
●To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Category A, B, C, F and I)
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.
SHARING PERSONAL INFORMATION
Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information with/to third parties for marketing purposes, as well as other business purposes. The specific items of personal information that we may sell include: (a) e-mail address; (b) full name; and (c) telephone number. When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
None. In the preceding twelve (12) months, we have sold the following categories of personal information to third parties
None.
We may disclose your personal information for a business purpose to the following categories of third parties (Category A, B, C, F and I)
●Service providers. (Category A, B, C, F and I)
●Third parties who provide products and/or services featured on the Site. (Category A, B, C, F and I)
●Third parties who purchase and/or license your personal information for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. (Category A, B, C, F and I)
●Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Category A, B, C, F and I)
●In the preceding twelve (12) months, we have not : (a) sold personal information (including (i) e-mail address; (ii) full name; or (iii) telephone number; to the third parties who purchase and/or license your personal information for marketing purposes; or (b) shared your personal information for the business purposes set forth above.
In the preceding twelve (12) months, we have received no requests for access to specific information and to exercise data portability rights, or to delete personal information, or to opt-out from the sale of personal information.
YOUR RIGHTS AND CHOICES
The CCPA provides California residents (CA Users) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Opt-Out from the Sale of Your Personal Information
You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:
●Emailing us at: contact@figtion.com;
Where you make a request to opt-out of the sale of your personal information through an Authorized Agent, we will require that you or the Authorized Agent provide us with a valid written authorization executed by you and that Authorized Agent, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by
●Emailing us at: contact@figtion.com;
We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:
●The categories of personal information we collected about you.
●The categories of sources for the personal information we collected about you.
●Our business or commercial purpose for collecting or selling that personal information.
●The categories of third parties with whom we have shared that personal information.
●The specific pieces of personal information we collected about you (also called a data portability request).
●If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
●sales, identifying the personal information categories that each category of recipient purchased; and
●disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1.Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
2.Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
3.Debug products to identify and repair errors that impair existing intended functionality.
4.Exercise free speech rights, ensure the right of another CA User to exercise their free speech rights or exercise another right provided for by law.
5.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6.Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7.Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
8.Comply with a legal obligation.
9.Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:
●Emailing us at: contact@figtion.com;
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information. Where you make a data deletion request, data portability request and/or information access request through an authorized agent, we will require that you or the authorized agent provide us with a valid written authorization executed by both parties, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by:
●Emailing us at: contact@figtion.com;
You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:
●Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
●Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
●Deny you goods or services;
●Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
●Provide you a different level or quality of goods or services; and/or
●Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to these Provisions
We reserve the right to amend these Provisions in our discretion and at any time. When we make changes to these Provisions, we will notify you by email or through a notice on the Site’s homepage.
Contact Information
If you have any questions or comments about these Provisions, the Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:
●Emailing us at: contact@figtion.com
Additional Provisions for European and U.K. Residents
These Additional Provisions for European and U.K. Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the United Kingdom, the European Union or the European Economic Area (“EU Users”), to the extent required by local law in those jurisdictions.
is considered the “Data Controller” (“Data Controller” or “Controller) for its website as defined within Regulation (EU) 2016/679 (General Data Protection Regulation)(“GDPR”). You, the User, are the “data subject.” The following agreement applies solely to personal data held within the website at www.figtion.com and the associated mobile application (collectively, the “Site“), or the Data Controller’s internal records relating to the Site.
1. Lawful Basis for Processing
Your data can only be processed if there is at least one lawful basis to do so. The lawful bases for processing data are:
●the data subject has given consent to the processing of his or her personal data for one or more specific purposes.
●processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
●processing is necessary for compliance with a legal obligation to which the Controller is subject.
●processing is necessary in order to protect the vital interests of the data subject or of another natural person.
●processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
●processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
If you are a non-paying User, (and you have requested information from us, or have established an account), you hereby give us your consent to the use of your personal data to provide information that you have requested regarding our products and services, and to use your data as set forth in our Privacy Policy.
If you are a paying User, the processing of your data is needed for the performance of the contract between you and us, and you hereby consent to our use of your data as set forth in our Privacy Policy.
2. Responsibility and accountability
It is the responsibility and liability of FIGTION., as the Data Controller, to implement effective measures and to comply with applicable law in its data processing activities, and FIGTION hereby acknowledge such responsibility, even if the processing is carried out by a data processor on FIGTION.’s behalf.
3. Consent
We obtain the following personal information with your consent on our Site:
● Users entering information into any customer inquiry form, or establishing an account, consent to have their name, email address, country and other voluntarily-provided data stored by FIGTION. for a period of up to two years unless consent is withdrawn. This is for the purpose of providing useful information in response to their enquiry
● Users purchasing products or services from FIGTION. consent to have their name, email address, physical address, phone number, and IP address stored by FIGTION. for the purposes of providing their product or service and communicating service updates and other contractual information with them.
● Users making posts or otherwise communicating to or through the Site consent to have their name, email address, and country stored in our systems.
● Users consent to the collection, storage and use of their information as set forth in our Privacy Policy.
● Users consent to the collection of account information for signing up, subscribing for premium services and setting up 2-step verification.
● Users consent to clicking links and sharing information to Third-Party Service Providers with social media features such as Facebook, Twitter or Discord and consent to collection of interaction with these links by us.
4. Right of access
As described in section (3) above, depending on how you interact with our Site, and what consent you have given, we may have the following personal data stored about you:
● First, Last Name, Middle Initial
● Email Address
● Country
● IP Address
● Mailing Address
● Phone Number
● Any other information identified in our Privacy Policy
5. Right to erasure
If you as a User of our Site request in writing that we delete your personal data, upon verification of the request being genuine, we shall delete or render illegible all your requested personal data within a reasonable time (not to exceed five (5) business days). Should this request result in the inability for us to provide a contracted service to you, we will inform you of the potential impact prior to performing the erasure.
In addition, visitors to the Site who are not contracted customers will have their personal data erased automatically after two (2) years if they do not continue to interact with the Site or with emails sent by us.
6. Data portability
If you as a User of Our Site request in writing that we provide you a copy of your personal data, upon verification of the request being genuine, we will provide your personal information in an industry standard format that will allow you to use it somewhere else.
7. Data protection by Design and by Default
We have designed the security of Our infrastructure to support and enhance operational security. User data is encrypted with MD5 Message-Digest Algorithm, and stored in our secured server.
8. Records of processing activities
FIGTION. maintains records of its data processing, which include the purposes of the processing, the categories of data involved and the duration of the data retention period. These records are available to the applicable supervisory authority on written request to ss.
9. Data breaches
We will report to the relevant supervisory authority within 72 hours, as well as to affected Users, if we determine that there has been a data breach of our Site.
10. Data Protection Officer
We do not, as our core activity, handle the data processing of operations that require regular and systematic monitoring of data subjects, therefore we do not have a formal Data Protection Officer for our Site.
11. GDPR Representative
Because FIGTION. is not established in the EU, it designates the individual below as its representative in the EU with regard to its obligations under the GDPR. Supervisory authorities and data subjects should direct all communications regarding FIGTION.’s GDPR compliance to the following:
contact@figtion.com
Additional Provisions for Hong Kong SAR
These additional provisions for Hong Kong SAR (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply to data user who controls the processing of data in or from Hong Kong SAR and are to be interpreted in a manner consistent with the provisions of the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO”). Pursuant to PDPO, the following information is provided to you in connection with your dealings with and provision of data or information to us, and/or any of our affiliates and/or service providers (hereafter collectively known as the “Data User”) relating to the Site Offerings.
(a) From time to time, it is necessary for clients and various other individuals ("data subjects") to supply the Data User with data in connection with various matters such as account opening or continuations, or provision of services to clients and other individuals. The kinds of data that may be collected includes, but are not limited to, name, contact details (including address, contact/mobile phone number, email address), occupation, town/city and region/country of birth, date of birth, nationality, identity card numbers, passport numbers, country/jurisdiction of tax residency, tax identification numbers, account information and details of financial status.
(b) It is also the case that data are collected or received from data subjects from time to time in the ordinary course of the continuation of the Data User's relationship with them, for example, when clients write cheques, effect transactions, attend seminar/events or generally communicate verbally or in writing with the Data User.
(c) Although it is not generally obligatory for a data subject to provide personal data, failure to supply such data may result in the Data User being unable to open an account or continue services to clients or comply with any laws, regulations or guidelines issued by regulatory or other authorities ("Applicable Laws").
(d) The purpose for which data relating to a data subject may be used will vary depending on the nature of the data subject's relationship with the Data User. These purposes may comprise any or all of the following:
1) the processing of an application for an account and for signing up, subscribing for premium services and setting up 2-step verification;
2) the daily operation of the services provided to clients;
3) marketing services and products (please see further details in paragraph (e) below);
4) complying with an order of a court or meeting disclosure, reporting, compliance and any other legal and regulatory requirements (including but not limited to tax reporting) under any Applicable Laws or regulatory requirements (including local and foreign taxation authorities) applicable to the Site Offerings and/or the Data User and/or any Data Transferee (as defined below) in Hong Kong or elsewhere from time to time;
5) complying with any Applicable Laws binding or applicable to the Site Offerings and/or the Data User and/or the Data Transferee within or outside of Hong Kong existing currently and in the future, as well as any present or future contractual or other obligations or requirements with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities that is assumed by or imposed on the Site Offerings and/or the Data User and/or the Data Transferee by reason of their respective financial, commercial or business activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, including but not limited to:
i. compliance with obligations binding on the Data User and/or the Data Transferee in Hong Kong or elsewhere pursuant to the arrangements in relation to Chapter 4 of Subtitle A of the United States Inland Revenue Code of 1986 as amended or supplemented from time to time ("FATCA"), to the extent FATCA is relevant and applicable to the relevant Site Offerings; or
ii. compliance with requirements applicable to the Site Offerings and/or the Data User and/or the Data Transferee pursuant to the Hong Kong Inland Revenue Ordinance (Cap.112 of the Laws of Hong Kong), its provisions and guidelines or requests issued or given by the Inland Revenue Department, including those concerning automatic exchange of financial account information on tax matters (“AEOI”); or
iii. establishing whether you are a citizen of the United States, resident of the United States for its federal income tax purposes or otherwise subject to tax in the United States and/or to substantiate whether your account has US status for the purposes of FATCA, to the extent FATCA is relevant and applicable to the relevant Site Offerings.
6) any purpose related to the administration of the relevant Site Offerings or the data subject's participation therein;
7) researching, designing, and launching new products and services to you;
8) designing and organising seminars/events/forums to you;
9) providing alerts, newsletter, leaflets and communications with contents relevant to Site Offerings and/or other products and services including market information and materials, including links to Third-Party Service Providers with social media features such as Facebook, Twitter or Discord;
10) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering products and services provided by us; and
11) purposes directly related or incidental to the above including seeking professional advices.
(e)USE OF DATA IN DIRECT MARKETING. The Data User intends to use the data subject's data (as may be collected by the Data User) in direct marketing and the Data User requires the data subject's consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
1)the name, contact details (including address, contact/mobile phone number, email address), products and services information, transaction pattern and behaviour, financial background, online behaviour and demographic data of the data subject held by the Data User from time to time (collectively referred to as "member data") may be used by the Data User in direct marketing;
2)the following classes of services, products and subjects may be marketed in direct marketing:
A.Site Offerings and related services and products offered by the Data User;
B.invitations to seminars/events/forums; and
C.reward, loyalty or privileges programmes, and promotional offers.
(f)Data collected may be maintained for such period as may be required by Applicable Laws or as otherwise prudent in relation to administration of the relevant Site Offerings and may be retained after the data subject ceases to be a client or have a beneficial interest in the relevant Site Offerings.
(g)Data held by the Data User relating to a data subject will be kept confidential but the Data User may provide such information to the following parties whether inside or outside Hong Kong for the purposes set out in paragraph (d) ("Data Transferee"):
1)the ultimate holding company of the Data User and/or their subsidiaries and/or affiliates;
2)the service providers of the Data User, including the professional advisors and the auditor of the Data User or of each relevant Site Offerings or such other service providers engaged by the Data User to assist and act on behalf of the relevant Site Offerings with the fulfilment of its obligations under AEOI;
3)persons appointed to design, research, launch or promote products or services of the Data User;
4)the employees, officers, directors and agents/delegates of the Data User or any of the parties in (1) to (3) above;
5)external service providers (including but not limited to printing houses, mailing houses, telecommunication companies, public relation companies, advertising agency, telemarketing companies, data processing and data storage companies, cloud providers, storage companies, call centres, market research firms, software development and application companies and information technology companies that the Data User engages for the purposes set out in paragraph (e);
6)the employer (or former employer) and/or any agent appointed by the employer (or former employer) of any member participating in a relevant Site Offerings, subject to any prohibitions or restrictions in Applicable Laws;
7)any third-party service provider employed to provide administrative, computer, data storage, telecommunications, software development and application, printing, letter-shopping, mailing or other services to the Data User in connection with the operation of its business or meeting the obligations;
8)any applicable regulatory authorities/bodies, governmental authorities/bodies, industry recognised bodies such as future exchanges, fiscal and monetary authorities, securities associations, credit reference agencies, securities exchanges and tax authority of any jurisdictions (whether within or outside of Hong Kong), including but not limited to (a) the Hong Kong Inland Revenue Department for the purpose of, for example, compliance with AEOI, and (b) the United States Internal Revenue Service for the purpose of, for example, compliance with FATCA, to the extent FATCA is relevant and applicable for such Site Offerings and to the extent not prohibited by the laws of Hong Kong; and
9)without limiting the generality of paragraphs above, any party to whom the Data User is under an obligation to make disclosure by Applicable Laws or voluntary arrangements binding on the Data User.
Personal data stored or processed in any jurisdiction outside Hong Kong may also be accessible to government authorities in that jurisdiction and may not enjoy the same protection as in Hong Kong.
(h)Under PDPO, any individual has the right:
1)to ascertain the Data User's policies and practices in relation to data and to be informed of the kind of personal data held by the Data User;
2)to require the Data User to correct any data relating to him/her which are inaccurate;
3)to check whether the Data User holds data about him/her and of access to such data; and
4)to object to the use and/or provision of his/her personal data for direct marketing purposes.
Pursuant to PDPO, the Data User is entitled to charge a reasonable fee for the processing of any data access request.
(i)You should indicate in the appropriate form or write to the following person(s) (i) make a request for access to data or correction of data or for information regarding policies and practices and kinds of data held, or (ii) object to the use and/or provision of your personal data for direct marketing purposes:
The Data Protection Officer
Nothing contained herein shall limit the rights of data subjects under PDPO.
ADDENDUM: PRIVACY POLICY FOR NFT MARKETPLACE
Last Updated: 14 July 2021
INTRODUCTION
The Privacy Policy in this addendum (“Privacy Policy”) apply in addition to our main Privacy Policy (“Main Policy”) and govern your access to and use of the NFT (as defined below) marketplace of the Company’s website (“Marketplace”) including without limitation (i) the creation, purchase, sale, exchange, or modification of NFTs, (ii) our online and/or mobile services, and (iii) software provided on or in connection with those services (collectively, the “Service”). References to “NFTs” in these Teams shall mean unique cryptographic non-fungible tokens minted by artists and implemented on the Ethereum blockchain using smart contracts. NFTs sold on our Marketplace include, without limitation, visual works, audiovisual works, animations, audio, photographs, 3D works, GIFS, and other creative digital works with or without physical counterparts such as physical trading cards (collectively, “Artworks”).
The terms of Privacy Policy in this addendum replace or modify the corresponding sections in the Main Policy (as follows):
- “What personal information do we collect and use, and how do we collect it?”
replaces the last paragraph with the following:
When you create an account on the Site, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit the Site or download and use our App. As discussed in greater detail below, we may ask you to submit some or all of the following information: (a) your e-mail address; (b) your full name; (c) your telephone number; (d) any other information collected via the Contact Services form; (e) your date of birth; (f) your mailing address; (g) your ID copy; (h), your credit card number; (i) your wallet address; (j) your user names and passwords (including the Company’s Website); and (k) any other information requested by the Company
- Use of Personal Information
adds the following after the last paragraph:
We may also provide your information to provide the Services you request, including but not limited to facilitating your cryptocurrency transactions through Metamask or other wallets. Your interactions with Metamask and/or any third-party electronic wallet extensions are governed by the applicable privacy policies.
ADDENDUM: PRIVACY POLICY FOR AUGMENTED REALITY
Last Updated: 4 August 2021
INTRODUCTION
The Privacy Policy in this addendum (“Privacy Policy”) apply in addition to our main Privacy Policy (“Main Policy”) and govern your access to and use of the augmented reality (“AR”) function in relation to any of the Company products, websites and apps (“Services”). To make our Services work well for you, we offer tools that apply filters and video effects fitting the contours of objects, modifying its size and shape and following its movements. In order to enable these Services, we have to distinguish patterns of shape and form that compose a digital image of a still or moving object.
We use TrueDepth API technologies to create AR effects within the Services. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves the user’s device. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. Information provided via TrueDepth API technologies is stored on the device only for the duration of creating AR effects within the Services. When the effect is rendered, the data is discarded.
The terms of Privacy Policy in this addendum replace or modify the corresponding sections in the Main Policy (as follows):
- “What personal information do we collect and use, and how do we collect it?”
When you are using the Services, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit the Site or download and use our Services. We may collect some or all of the following information:
a)Images and videos from your device. In order to use the Services, you need to enable your device camera. However, all images taken by your mobile phone camera shall be processed solely on your device and shall not be sent to our servers, i.e., we do not have access to such images (we will not collect, share or store them).
b)Your IP address, location and device identifier. Without a device identifier, we are not able to provide Services to you, as we are not able to identify your device across the devices of other users. We collect location data and IP addresses for security (we store that data to protect against cyberattacks), as well as to know your geographic location to stay aware of legislation applicable to you, so we could follow its requirements. Location data, IP addresses or device identifiers will not be associated with other identifying information about you such as e-mail, address.
c)Biometric identifiers. Our detection algorithms used within the processing of your images are not able to identify a specific person and, therefore, generally should not be considered as collecting biometric information. However, in case the applicable law stipulates that images captured by the camera or any geometry generated by our Services are considered as biometric identifiers, biometric information or similar legal category, hereby you express your informed written consent on their processing as described in this Privacy Policy.
d)Statistics data collected by Third-Party Service Providers. Third-Party Service Providers may collect IP address, advertising IDs assigned by Third-Party Service Providers, browsing behavior and location data about users of the devices. Such information shall be collected directly by Third-Party Service Providers and subsequently be shared with us. Third-Party Service Providers may combine such information with other personal information they have in their procession and may use it for behavioral tracking/advertising. If you do not wish your data to be processed for behavioral tracking/advertising and analytical purposes you may opt-out as described in the Main Policy.
e)Cookies. We also use cookies to help us improve the performance of our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options of our Services.
f) Certain information about your mobile device , including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed. These data will not be directly associated with you or other individuals.
g) Data on how you are using the Services. These data are needed to enable proper operation of the Service, e.g., to identify and fix the problems, and will not be personalized or linked to the device you are using.
In case we start collecting other categories of your personal data, we shall first explain why we collect it and ask for consent for such collection and further processing. We do not collect information which identifies or allows to identify you, unless you voluntarily provide us with such data (in particular, when communicating with our support team, leaving feedback regarding your experience with the Services) or when certain parts of our Services require you to provide personal information voluntarily.
- Use of Personal Information
We processing your personal information in order to:
a) deliver the Services to you (including, maintaining and monitoring the proper operation of, fixing any problems in, the Services);
b) ensure and protect the safety and security of the Services, protecting our intellectual property rights and other rights;
c) conducting statistical and analytical surveys and researches, in particular for improving the Services and your user experience;
d) improve the performance of our business and provide you with information and Services requested, understand and respond to your feedback, and improve your customer experience;
e)prevent, detect, or investigate unauthorised use of the Services and ensure our Services are kept secure;
f)attribute and track the performance of advertising campaigns and applications, including their effectiveness, usage, installations and downloads, and conduct behavioral tracking/advertising;
g)allow you to utilize features and personalized content within our Services when you grant us access to information from your device, including location-based services;
h)provide social features, including storing your communications, content, photos, videos and other information shared with your friends, including through imported contacts, and sharing your experience. If you elect to upload content, such as photos or videos from your mobile device, into our Services or to be shared with other social network platforms, we will, with your permission, access your device’s media storage. You can change your mind and disable access to your media storage at any time in your device settings; and
i)ensure compliance with applicable law and our policies, and manage any disputes and accidents and take legal or other professional advice.
- Data Sharing
Your information may become available for the following categories of recipients:
a)our employees and the companies being in the same corporate group with us;
b)data storage, networking and security providers and providers assisting us with a client support;
c)Third-Party Service Providers;
d)law enforcement agencies or any regulatory authorities as required by applicable laws and regulations; and
e)any other providers assisting us with delivering and improving the Services.
All third parties with which we share your data only get the minimum amount of data that are reasonably required in order for them to provide their service to us and therefore to you. The use of the shared information by such third parties is strictly limited to the purposes of use of personal information as set out in this Privacy Policy and is not permitted for any other purpose. All third parties with which we share your data are required to protect such data in accordance with all relevant laws and regulations and in a manner similar to the way we protect the same. We will not share your data with third parties which are considered as not being able to provide its clients and potential client with the required level of protection.
- Data Retention, Protection and Your Rights
We respect the privacy rights of our users, and to the extent required by applicable law, will make reasonable commercial efforts to allow you to access, correct, object to the processing of, delete or port any of your personal data, provided that we are able to properly verify your identity and link it to any personal data in our possession. We limit access to data we hold about you to employees who we believe reasonably need to come into contact with that information to provide Services to you or in order to fulfill their official duties. These employees are bound by confidentiality obligations and we will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this Privacy Policy.
You may refer to the Main Policy for further details with respect to you rights in relation to the personal data collected by us, including opting-out or revoking your consent for the use of your personal data or unsubscribing from our marketing emails. If you cease to consent or affirmatively revokes consent for collection, use or disclosure of your personal information by us and/or any Third-Party Service Provider, we and/or the relevant Third-Party Service Provider will promptly use reasonable efforts to cease all such use.
Through your account settings, you can access, view, edit, and delete certain personal information (the information you can view, edit, and delete may change from time to time). We will also ask for your separate permissions to enable your camera. If you change your mind, you will be able to revoke the given permission any time afterward by changing settings on your device. However, please note that rejecting or switching off this permission might negatively affect the use of our Services or even effect its full functionality.