Fana - Application privacy policy
version 1.0 effective 11th August 2022
PLEASE READ THIS POLICY CAREFULLY
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this document and it is important that you read this information carefully.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details and device information) as described in this policy.
By installing this App you consent to the installation of the App for the purposes of using the Fana App to support charities of your choice on the Fana App.
Fana will store Primary Account information to https://api.myfana.com.
HOW YOU CAN WITHDRAW CONSENT
Once you provide consent, you may change your mind and withdraw consent at any time by contacting us at privacy@myfana.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent. By installing this App and agreeing to this policy you consent to processing of your Location Data (including details of your current location disclosed by GPS technology so that location-enabled Services are activated and we may recommend relevant charities to you.
LOCATION DATA
Fana is committed to protecting your personal data and respecting your privacy.
INTRODUCTION
This policy our Terms of Use applies to your use of: • The Fana v1.0.0 mobile application software (App) available on our site (www.myfana.com) OR the Apple App store once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device). • Any of the services accessible through the App (Services) that are available on the site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
IMPORTANT INFORMATION AND WHO WE ARE
My Fana Europe Ltd is made up of different legal entities. When we mention "Fana”, we are referring to the relevant company in the Fana Group responsible for processing your data which will be clear to you when you use our App. My Fana Europe Ltd is the controller responsible for this App. We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
● My Fana Europe Ltd
● Data Privacy Manager
● privacy@myfana.com
● 1 Lyric Square London, W6 0NB, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on 11th August 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by App notification or by email. The new policy may be displayed onscreen and you may be required to read and accept the changes to continue your use of the App or the Services. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
THIRD PARTY LINKS
Our Sites may, from time to time, contain links to and from the websites of our partner networks. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
• Identity Data.
• Contact Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect and process the following data about you:
• Information you give us. This is information (including Identity, Contact and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services or search for an App or Service, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• analytics providers such as Google;
• advertising networks from time to time;
• search information providers;
• Contact and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from data brokers or aggregators; and
• Identity and Contact Data from publicly available sources.
COOKIES
We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances: • Where you have consented before the processing. • Where we need to perform a contract we are about to enter or have entered with you. • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. • Where we need to comply with a legal or regulatory obligation. We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Purpose/activity Type of data Lawful basis for processing To install the App and register you as a new App user Identity Contact Device Your consent To process in-App purchases and deliver Services including managing payments and collecting money owed to us Identity Contact Transaction Device Marketing and Communications Location Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) To manage our relationship with you including notifying you of changes to the App or any Services Identity Contact Profile Marketing and Communications Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) To enable you to participate in a prize draw, competition or complete a survey Identity Contact Device Profile Marketing and Communications Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business) To administer and protect our business and this App including troubleshooting, data analysis and system testing Identity Contact Device Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App Identity Contact Device Content Profile Usage Marketing and Communications Location Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)
DISCLOSURES OF YOUR PERSONAL DATA
We will not disclose your personal data unless required to by law.
DATA SECURITY
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or alternative encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We use caches to remember users’ settings as well as for authentication and analytics. These technologies may be used in analysing trends, administering the Application, as well as improving the Application for our user base as a whole. These Caches help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how our visitors reach our Application. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
DATA RETENTION
We have different periods of retention for different aspects of your personal data. By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In the event that you do not use the App for a period of twelve months then we will treat the account as expired and your personal data may be deleted.
YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data: • Request access to your personal data. • Request correction of your personal data. • Request erasure of your personal data. • Object to processing of your personal data. • Request restriction of processing your personal data. • Request transfer of your personal data. • Right to withdraw consent. You also have the right to ask us not to continue to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us at privacy@myfana.com.
GLOSSARY LAWFUL BASIS
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Fana Group acting as joint controllers or processors and who are based globally and provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
Service providers acting as processors. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to: • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
DESCRIPTION OF CATEGORIES OF PERSONAL DATA
• Identity Data: first name, last name, username or similar identifier, date of birth. • Contact Data: billing address, delivery address, email address and telephone number. • Transaction Data: includes details about payments to and from you. • Device Data: includes the type of mobile device you use, a unique device identifier mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting. • Profile Data: includes your username and password, in-App history, your interests, preferences, feedback and survey responses. • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. • Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences. • Location Data: includes your current location disclosed by GPS technology.
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