GENERAL DATA PROTECTION REGULATION (GDPR) POLICY
As part of our services, TILDE LLC d/b/a FANBUCKET (hereinafter the “Company”, “we”, “us” or “our”) collects and processes personal data relating to the User (Hereinafter “You” or “Your”). The organization is committed to being transparent about how it collects and uses that personal data of users and to meeting its data protection obligations. The provisions of the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Data Protection Act will apply to personal data from which any living individual is identified or identifiable (by anyone) whether directly or indirectly.
PLEASE READ THIS POLICY CAREFULLY BEFORE SUBMITTING YOUR PERSONAL DATA THROUGH OUR WEBSITE AND/OR APP OR ACCESSING, BROWSING OR OTHERWISE TRANSACTING OR USING OUR WEBSITE/APP. IF YOU SUBMIT YOUR PERSONAL DATA ON OUR WEBSITE/APP, YOUR DATA WILL BE PROCESSED AS PER TERMS OF THIS POLICY.
The need to retain data varies widely with the type of data. Some data can be immediately deleted and some must be retained until reasonable potential for future need no longer exists. Since this can be somewhat subjective, a retention policy is important to ensure that the Company's guidelines on retention are consistently applied throughout the organization.
The purpose of this policy is to specify the Company's guidelines for retaining different types of data. This policy sets out the obligations of company regarding data protection and the rights of User (“data subjects”) in respect of their personal data under the General Data Protection Regulation (the “Regulation”) and the Data Protection Act (the “Act”).
a) Personal Data: Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject: Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
c) Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing: Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling: Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
f) Controller or controller responsible for the processing: Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
g) Processor: Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
h) Recipient: Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with laws and regulations shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
i) Third party: Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
j) Consent: Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
This policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company. We are committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
5. THE DATA PROTECTION PRINCIPLES
This policy aims to ensure compliance with the Regulation and Act. The Regulation and Act sets out the following principles with which any party handling personal data must comply. All personal data must be:
- processed lawfully, fairly, and in a transparent manner in relation to the data subject;
- collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject; and
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
6. ACCURACY OF DATA
The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
7. USER TESTIMONIALS AND COMMENTS
We post user testimonials and comments on our website/app, which may contain Personal Information. You hereby give your consent for posting your name and testimonial.
8. USE OF PERSONAL DATA
When you visit our website or download our app, you may be asked to enter your personal details including Real Name, Alias/Username, Contact Number, E-mail, Date of birth, Photo, Your Bio, Address, Driver’s License Number, Passport Number or other similar IDs and Other personal information including credit card/debit card details (through our payment processing partners) for business billing or other purpose. We collect information about you if you make use of any of the interactive features within our website/app that rely on a personalized response, or where you ask us to respond to a query you have. The information we collect is limited to the details we need to provide the specific service you have asked for. The types of information we collect includes:
- Real Name, Alias/Username, Contact Number, E-mail, Date of birth, Photo, Your Bio and Address;
- Driver’s License Number, Passport Number or other similar IDs;
- Race, Color, Religion, Sex/gender, Gender identity, gender expression, Sexual orientation, Marital status, Medical Condition, Military or veteran status, National origin, Ancestry, Disability (mental and physical including HIV/AIDS), Genetic information, and Age;
- Internet activity information, including browsing history and search history;
- Professional or employment-related information;
- Other personal information in content you provide to us, such as through emails you send us.
A. Information that you voluntarily provide to us: You can visit our website without sharing your name and contact information. In certain places on this website and/or after downloading the app, you may be asked to provide your name, date of birth, contact information and/or email address to use our website/app features. Opening an account may require information, for example real name, alias, contact number, e-mail, date of birth, and address. It is your option to provide the information requested. However, if you do not provide details that are essential, it would be impossible to use all of the features and functions of the website/app and/or to benefit from our services. We collect the following information when you use our services, including:
- Account Information: If you create an account on Fanbucket, we may require you to provide a username and password.
- User Content: This includes: posts, comments, videos, messages and other communications including text, links, images, and gifs.
- User Actions: This includes: liking, voting, saving, hiding, and reporting any User or Content. We also collect your subscription and other information.
- User Transactions: This includes credit card/debit card details (through our payment processing partners) for business billing or other purpose.
B. Information collected automatically: When you visit our website/app, our information technology systems automatically collect information about the equipment you are using and about your use of our website/app and services. Examples of the information we collect and analyze include the Internet Protocol (IP) address (with location) used to connect your mobile/computer to the Internet, the login name and password for the website if you sign in for access through website, the email address which you use to communicate with us, and your mobile/computer and connection information (for example, browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform). We may also use browser data such as cookies for fraud prevention and other purposes. We may use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (for example scrolling, clicks, and mouse-over), and methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and for dealing with diagnostic purposes relating to our website/app. We also use Google Analytics to help us understand how our customers use the Site/App.
Use of Google Analytics
C. Other information we might receive: We may also receive personal information about you from third parties including from our service providers and/or social media service provider (like Facebook, TikTok, Instagram).
9. HOW WE USE THIS INFORMATION
We may use the information described above to:
- send you quotes, promotional materials, newsletters and other communications;
- create and manage your account;
- providing customer service, processing or fulfilling transactions, verifying your identity, and processing payments;
- Serve you relevant offers and ads;
- respond to your inquiries;
- perform data analyses (including market and consumer research, economic impact analyses, demographic analyses and aggregation of personal information);
- operate, evaluate and improve our business;
- protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other criminal activity; and
- Comply with and enforce applicable legal/federal requirements, relevant industry standards and our policies, including our Terms & Conditions.
We also may use the information in other ways for which we provide specific notice at the time of collection.
10. WHAT ARE COOKIES?
Cookies are small text files sent to your browser and stored by your browser on your computer or other device by the websites that you visit, or by certain emails that you open. Cookies allow our websites to “remember you” when you return and allow us to deliver relevant page to you on our websites. Cookies save data such as your IP address or MAC address, the city associated with your IP or MAC address, the date and time you visited our website, pages or posts you viewed, the URL of the website you viewed prior to visiting our website and the type of browser you use.
11. WHAT ARE THE DIFFERENT TYPES OF COOKIES?
Our website uses the following types of cookies:
A. Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features. These are known as “First Party” cookies. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided.
B. Functionality cookies
These cookies allow our website to remember choices you make and provide enhanced, more personal features. The information these cookies collect may be removed and they cannot track your activity on the other website.
An HTTP Cookie cannot be used to get data from your hard drive, get your email address or steal sensitive information about your person. We believe cookies to be harmless, and will eventually be to everyone's benefit (end users, as well as site builders) from the World Wide Web Consortium: "Cookies cannot be used to steal information about you or your computer system." By using this website you consent to us deploying cookies as described above.
- Support the functioning of our websites;
- Enhance your experience on our websites by remembering your preferences (including recent searches);
- Understand how our websites are functioning and inform improvements to our websites and services; and
- Gather data that helps us to deliver information relevant to your interests.
13. HOW TO MANAGE COOKIES
You can manage cookies on your computer or device through your browser settings. Please refer to your browser’s “help” section for more information on how to delete saved cookies and allow or block cookies.
14. DATA WE SHARE
We will not share the personal data you provide except (a) as otherwise permitted under our Privacy/GDPR Policy (b) if it is for the purpose(s) you provided it; (c) with your consent; (d) as may be required by law or as we think necessary to protect our company or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or about to cause, injury to or interference with the rights or property of another); (e) with other persons or companies or affiliated or related organizations with whom we contract to carry out internal Site operations or our business activities (for example, third-party contractors (f) and/or to notify you when we make changes to any of our terms or this policy. Our business needs may change from time to time and we reserve the right to make changes to our Policy. We will not use your personal data in a manner inconsistent with our Privacy/GDPR Policy, however, without first obtaining your consent to do so. If intended uses differ from this policy, we will seek to obtain your consent at the place where the data is collected either by an “opt-in” or “opt-out” method or by other means (such as sending to you an email).
15. DATA PROCESS AND CONSENT
We need to process data to take steps at your request. We may also need to process your data to enter into an agreement with you. In some cases, we need to process data to ensure that we are complying with its legal obligations. Company has a legitimate interest in processing personal data during the service process and for keeping records of the process. Processing data allows us to manage the service process. We may also need to process data received from user to respond to and defend against legal claims.
Company may keep your personal data on its server for any specific purpose. We will ask for your consent before we keep your data for any specific purpose and you are free to withdraw your consent at any time.
We may use your Personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send.
17. DATA ACCESS
Your data may be shared internally. This includes employees involved in the service process and IT staff, if access to the data is necessary for the performance of their roles.
18. DATA PROTECTION
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees or partners in the proper performance of their duties. If in the future we intend to process your personal data for a purpose other than that which it was collected we will provide you with information on that purpose and any other relevant information.
19. HOW SECURE IS DATA YOU GIVE US?
Our Website/app is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our website as safe as possible. We use regular Malware Scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL)/TLS/HTTPS or higher technology. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of their personal information. All transactions are processed through ___________ and are not stored or processed on our servers.
20. DATA RETENTION
The criteria used to determine the period of storage of personal data is the respective statutory retention period. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed.
21. PAYMENT PROCESSING PARTNER AND LEGAL DISCLOSURE
We may share your information with third party service providers (for example: ________) for your ID verification or processing payments made by credit or debit card in connection with transaction with us. We may disclose your information to our business partners and if we have a good faith belief that the disclosure is required by law, is required in order to enforce the Terms and Conditions, or is necessary to detect, prevent or address fraud or security issues or to prevent harm to Company or others.
22. DATA TRANSFERS
23. YOUR RIGHTS
As a data subject, you have a number of rights. If you would like to exercise any of these rights, please contact our Data Protection Officer. You have:
- The right to be informed including the identity and contact details of the data processor; the purpose and legal basis for processing the data, how the data is to be processed; the parties involved in processing the data and how long the data will be kept;
- The right to request that any personal data held is rectified if inaccurate or incomplete;
- The right to restrict processing;
- The right to object or stop processing personal data, including for direct marketing purposes;
- You have the right to access your personal data to see what data is held and how it is being processed;
- You have the right to request for delete or remove your personal data if it’s no longer needed, consent is withdrawn, the data was unlawfully processed or to comply with a legal obligation;
- You may request a copy of the data, and may also request that this data be sent to another data controller in a format they can use.
24. YOUR STATUTORY OBLIGATION
You are under no statutory or contractual obligation to provide data to us during the service process. However, if you do not provide the information, we may not be able to provide our services to you properly or at all.
25. CHILDREN’S PRIVACY
This Site is not intended for use by children under the age of 18. Minors under 18 should handle their personal data under the supervision of their guardians. The Site does not knowingly collect or store personal data from children under the age of 18. If you have concerns about this Site or its services, if you believe that your child has gained access to our website/app without your permission, you may contact us at: email@example.com
26. LINKS TO OTHER WEBSITES
From time to time, our website/app may contain links to and from websites/apps of our partner networks, advertisers, social media sites etc. If you follow a link to any of these websites/apps, please note that these websites/apps may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites/apps.
If you have a complaint in relation to the collection, storage, use or disclosure of your personal information, please contact us.
28. DO NOT TRACK
We currently do not use any cross-site tracking technologies and do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.
29. MOBILE/EMAIL NOTIFICATION
We may send promotional and non-promotional push notifications or alerts to your Email/mobile device. You can deactivate these messages at any time by changing the notification settings on your user account.
30. USE OF INFORMATION OUTSIDE YOUR COUNTRY OF RESIDENCE
At this time, some or all of the data in the service is stored and processed in the State of California, United State. Your use of the website/app represents your consent and agreement to these practices.
This Policy shall be deemed effective as of ___________________, 2022. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date. We may update this Policy from time to time by posting a new version online. You should check this page occasionally to review any changes in GDPR and Data Protection Laws.
32. IDENTITY AND CONTACT DETAILS OF CONTROLLER & PROCESSOR
Controller & Processor: Controller and Processor for the purposes of the General Data Protection Regulation (GDPR), Data protection Act, and other provisions related to data protection are:
|Controller: TILDE LLC d/b/a FANBUCKET|
2108 N ST STE 4059,
|Processor: DATA DEPOT ASIA PTE LTD|
79, AYER RAJAH CRESCENT,
#05-08 SINGAPORE – 139955
Data Protection Officer: Data Protection Officer for the purposes of the General Data Protection Regulation (GDPR), Federal Data protection Act, and other provisions related to data protection is: __________________- (name); ____________________@____.com (email)
Last Reviewed date:
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