FETHR PRIVACY POLICY

This Privacy Policy is current as of 01/09/2021.​​

​Welcome to Fethr’s Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information, and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

  1. WHO IS FETHR?

  2. GENERAL INFORMATION

  3. WHERE THIS PRIVACY POLICY APPLIES

  4. HOW CAN YOU KEEP YOUR PERSONAL INFORMATION SECURE?

  5. HOW WE COLLECT PERSONAL INFORMATION

  6. INFORMATION WE COLLECT

  7. HOW WE USE INFORMATION

  8. DISCLOSURE OF INFORMATION

  9. HOW WE SHARE INFORMATION

  10. HOW LONG DO WE KEEP PERSONAL INFORMATION?

  11. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

  12. CROSS-BORDER DATA TRANSFERS

  13. BEHAVIOURAL TARGETING

  14. YOUR RIGHTS

  15. HOW WE PROTECT YOUR INFORMATION

  16. PRIVACY POLICT COMPLAINTS

  17. CHILDREN’S PRIVACY

  18. CHANGES TO THIS PRIVACY POLICY

  19. MATTERS OUTSIDE THE SCOPE OF THE PRIVACY POLICY

  20. CONTACTING US

​WHO IS FETHR?

 

This Privacy Policy applies to Fethr Ltd (Company Number 12567575) and its related bodies corporate (referred to as “Fethr”, “we” and “our”).

 

 

GENERAL INFORMATION

 

This Privacy Policy explains how Fethr Ltd generally handles your personal information.  We may also provide more specific information relating to particular products or services in our privacy collection notices. We will update this policy on our website if we change the way we handle personal information. This Privacy Policy does not apply to Fethr employee records and contractor records.


Controller of Personal Information

Any personal information processed by Fethr Ltd in connection with this Privacy Policy is controlled by Fethr Ltd, which is considered the “data controller” of your personal information under European Union and UK data protection law. Our address is;

 

Data Protection Officer

Fethr Ltd, 71-75 Shelton St

London UK, WC2H 9JQ.

What do we mean by personal information?

Personal information means details which identify you or could be used to identify you, such as your name and contact details, as well as the interactions you conduct on the Fethr platform. It may also include information about how you use our websites and mobile applications.

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to personal information about you that we collect, use and otherwise process regarding your relationship with us as a customer or potential customer, including when you use our services, our websites or mobile applications.

Where we reference that others are data controllers in the sections ’Controller of Personal Information’ and ’Who do we share your personal information with?’ you should consult their privacy policies for further information.

HOW CAN YOU KEEP YOUR PERSONAL INFORMATION SECURE?

There are some simple things you can do to ensure your details are safe and secure online. Take a look through our easy tips to ensure you are using  safely and securely.

 

  • Passwords

    • Think of passwords as keys. Use a different one for each account, as if it is stolen it can be used to take over all your accounts.

    • Make it strong by using a mixture of upper and lower case letters, numbers and special characters. The longer it is, the better.

    • Avoid using personal information, dictionary words and consecutive numbers as these can be guessed.

  • Secure your device

    • Ensure you have anti-virus protection installed, and that it is up to date.

    • Keep your operating system and software up to date as these protect against the latest security threats.

    • Protect your device with a password and keep the password or PIN a secret.

    • Look for ‘https’ at the start of the web address (the ‘s’ stands for secure).

    • Check that a padlock is displayed when entering personal or financial information.

    • A green bar may also appear which means that the website has a valid security certificate.

  • Wi-Fi hotspots

    • Wi-Fi hotspots in public places are convenient but are often not secure.

    • Many hotspots do not encrypt information sent over the Wi-Fi network and might be accessed by someone else.

    • Don’t log in to personal or financial accounts when using public wireless networks.

    • Don’t log on to sites that don’t seem legitimate. Always ensure the site is fully encrypted.

    • When you have finished using an account, remember to log out.

 

  • Privacy and identity

    • Treat your personal information like cash.

    • Don’t hand personal information out to just anyone.

    • Only provide this information over encrypted websites (look for 'https' at the beginning of the web address).

    • Use password protection for securing personal data.

    • Protect your passwords. Keep them secure and out of plain sight.

    • Do not use the same password for multiple accounts, as if it is stolen it can be used to take over all your accounts.

 

Specific types of interactions with us

In addition to the general information in this Privacy Policy, we have included specific sections that you should read if you are based in the European Economic Area (the EEA) during your interactions with us (other than when you are in the EEA solely for travel purposes)

HOW WE COLLECT PERSONAL INFORMATION

How we collect personal information about you will depend on our relationship or interactions with you.

 

Directly from you

We mainly collect information directly from you, for example, when you use our website or social media, you call or write to us, we interact with you in person, such as when you use our products and services or participate in promotions, or market research.

 

Indirectly

There may be occasions when we collect information about you from someone else, such as;

  • Our service providers, including providers of data analysis services

  • Third parties that provide us with marketing leads

  • Businesses for whom we provide marketing and data analysis services

  • Providers of third party websites, apps and social media platforms

  •  

We may also collect information about you via data matching activities conducted by us or our trusted service providers.

 

If you provide us with information about other individuals, you are responsible for telling those individuals and letting them know that they can find a copy of this Privacy Policy on our website.

 

 

INFORMATION WE COLLECT

The types of personal information that we collect and process about you will depend on our relationship with you.  It will include some or all of the following:

 

Information you give us

  • General information about you. your name, title, gender, date of birth, contact details, passport or other identification details (which may include your image) and your answer to a security question (for example, your favourite colour)

  • Contact details. such as phone number, address, email address, and social media handle

  • Our interactions with you. such as any feedback, complaints, compliments, claims you have made, responses to market surveys, records of any correspondence and interactions with us and our staff (including in person, online, by telephone or email and via social media)

  • Your interests and attitudes, such as interest in sporting codes, political affiliations, or engagement with specific products and services.

  • Website and mobile apps. if you use our website or mobile applications, your geo-location, IP address, mobile telephone number or ID, and details of how you use the website or app and any third party sites that you have accessed from them.

  • Account Credentials. In order to use the Fethr Services, you are required to provide an Account Authentication Mechanism (email, phone number, or a third-party social log-in like Facebook or Google). When creating an account, Fethr stores a secure version of your Account Authentication Mechanism for authentication and/or verification purposes.

  • Community Profile Information. When you create a Fethr account, you choose to provide us Personal Data about yourself for your public profile. For example, you may voluntarily provide your Personal Data, such as your photo, name, or display name. You should carefully consider what Personal Data to include in your Community Profile, and you can review and change that information at any time by accessing the “My Account” section.

  • Feedback/Support. If you provide us feedback or contact customer support, we collect your name and e-mail address and possibly other Personal Data (e.g. IP address), as well as any other content that you send to us in order to reply and address any issue. If you contact customer support, we also collect and retain certain technical diagnostic data, such as your phone model. We may keep records of our communication with you, including any complaints we receive from you about other users (and from other users about you).

  • Mailing List. When you sign up for Fethr services, we collect your email address to send you news, service updates, and the latest information on products and services with your consent.

  • Surveys. When you participate in a survey, you provide us additional Personal Data through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Unless noted otherwise, we use Typeform for surveys. You can view Typeform’s privacy policy here.

  • Photos. If you upload a photo while using Fethr services, you will be required to permit Fethr to access your camera, and photo gallery, in which case Fethr will have access to the photos and videos stored in your photo gallery.

  • Messages. When you send a message using the Fethr services (which could include content such as photos, location, audio, video, emoji, etc.) to other users of Fethr services, we may collect Personal Data that includes the content of the message. We process your chats with other users as well as the content you publish, as part of the operation of the services.

  • User Activity. We collect certain Personal Data that is generated through your use of Fethr services. This Personal Data includes information about whose user profiles you have viewed, how you’ve interacted with the Fethr services, and how you communicate with other users.

  • Promotions - When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.

Sensitive personal information

  • Under privacy laws, certain categories of personal information are considered particularly sensitive and therefore as needing additional protection under European data protection law. These categories may include information about health, racial or ethnic origin, political opinions, religious beliefs, or your sexual orientation.

 

We may collect and handle your sensitive personal information, for example, when you complete market research studies or explicitly tell us in the general course of business.

 

Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.

 

We will ask you for your consent to handle this type of personal information, to the extent required under applicable laws, for example under the Data Protection Act 2018 (UK) or the European General Data Protection Regulation (GDPR).

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

  • Other Users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

  • Social Media - You may be able to use your social media account (such as Facebook Login) to create and log into your Fethr account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.

  • Other Partners - We may receive info about you from our partners, for instance where Fethr ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

  • Information collected when you use our services - When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

    • Usage Information - We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches or search parameters, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

    • Device information - We collect information from and about the device(s) you use to access our services, including:

      • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); and

      • information on your wireless and mobile network connection, like your service provider and signal strength.

 

Other information with your consent

  • If you give us permission, we will be able to collect your precise geolocation (latitude and longitude) in order to offer you features that make use of it. Such geolocation is collected through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it.

Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

 

​ 

HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

 

We may use your personal information for the following purposes:

  • To provide and administer our products and services:

    • To verify your identity, to contact you about your bookings, and to fulfil your meet arrangements and deliver the services you have asked for.

    • To send status updates and service communications to you. 

    • To keep track of you in advance of and on your meet.

    • To send you status updates and service communications.

    • To improve our websites, products, and services. 

    • For management and administrative purposes.

  • To help you connect with other users

    • Analyse your profile and usage behaviour and that of other users to recommend meaningful connections. For more information on our profiling and automated decision-making, please see our FAQ

  • Show users’ profiles to one another

  • For marketing purposes: to provide you with updates and offers, if you have chosen to receive these; to operate our competitions, promotions and events; to distribute our newsletters and other communications.  We may also use your information for marketing Fethr and our selected business partners’ products and services to you by email and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.  We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you.

  • To provide services tailored to your requirements and to treat you in a more personal way.

  • To comply with our legal obligations and for safety and security purposes: to ensure the safety and security of all customers when engaging with us, including investigating security and screening issues. We may disclose your personal information to third parties, the court service, regulators, or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.

  • To conduct analysis, market, consumer and other research: to improve our products, services and marketing activities, including our websites, and to generate consumer insights that help us to market more efficiently and to be more relevant to you.

  • To ensure website content is relevant: including to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.

  • We may also augment the information that we collect and hold about you, by associating and combining data collected from third parties with the Member’s personal information and using and disclosing that combined information to create aggregated segments for the purposes of customer analytics and marketing and to tailor the Member’s experience and content, including third party content and otherwise in accordance with these Terms and Conditions.

  • To improve our services and develop new ones: Administer focus groups and surveys, conduct research and analysis of users’ behaviour to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour), and develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users)

  • To prevent, detect and fight fraud or other illegal or unauthorized activities: Address ongoing or alleged misbehaviour on and off-platform, perform data analysis to better understand and design countermeasures against these activities, and retain data related to fraudulent activities to prevent against recurrences

DISCLOSURE OF INFORMATION

  • We may disclose your personal information to third parties in connection with:

    • services that you have secured through us or that we provide to you

    • our legal obligations, responding to complaints and claims, and fraud detection and prevention, Including:

      • various law enforcement agencies, regulatory authorities and governments around the world and their service providers

      • such other third parties mentioned in the “How we use your personal information” section above

 

  • In addition to the above third parties, we may use service providers for the services listed below, many of whom handle your personal information on our behalf.

  • Market research and analysis

  • Social media platforms

  • Marketing, printing, and distribution (including mailing and email) services

  • Information technology services such as data storage, communication networks, software and system development, maintenance and support, incident investigation and resolution, and information processing, analysis and reporting

We may disclose your personal information to comply with our legal obligations, respond to complaints and claims, and investigate and protect ourselves and third parties against any activity that we reasonably suspect to be fraudulent.  We may also disclose your personal information to law enforcement agencies, regulatory authorities and governments around the world and their service providers in connection with their investigations, screening or other functions.

We may transfer your information between our related bodies corporate who comply with this Privacy Policy.

In addition to how we collect and use your personal information set out above, see ‘How we share your personal data’ for more information about how your data is shared securely.

HOW WE SHARE INFORMATION

  • Contact Information. The Fethr platform is designed to allow users to share mutually share Contact Information. Contact Information is private to the user and will not be displayed in your profile to other users' on the Fethr platform. Should you elect to share your details through the Fethr mechanism for unlocking chat functionality, or the mutual sharing of contact details that are securely stored, Fethr will in every instance seek the users consent to do so.

  • Third-Party Tracking Companies. When you sign up for Fethr services, we may share a portion of your Profile Information, Location Information, and demographic information with analytics partners. These third parties may also collect information directly from you as described in this Privacy Policy (e.g., IDFA/IDFV, device information) through tracking technologies such as cookies or SDKs. Our analytics partners are aware that such data is being transmitted from Fethr. The privacy policies of these third-party companies apply to their collection, use and disclosure of your Personal Data. For example, one of our partners is Google Analytics, whose privacy policy can be found here. Google Analytics collects information and reports website trends without identifying individual visitors. See Your Choices for information on your ability to opt-out of Google Analytics. Another partner, Wix, provides us with the technology to allow us to collect certain information and reports on usage trends without identifying individual visitors (e.g., daily active users, monthly active users, time on platform, etc.) and tools which allow us to communicate with users (via inbox messages) within the Fethr platform or out of the platform (e.g. via push notifications or email).

  • Third-Party Advertising Companies. We share the Identifier for Vendor associated with your device (“IDFV”), your device's advertising identifier (“IDFA”), a portion of your Profile Information, and Location Information, with our advertising partners. These third parties may also collect information directly from you as described in this Privacy and Cookie Policy through tracking technologies such as cookies or SDKs. Our advertising partners are aware that such data is being transmitted from Fethr. The privacy policies of these third-party companies apply to their collection, use and disclosure of your Personal Data.

  • Third-Party Service Providers. We share your Personal Data with third-party service providers to: provide you with Fethr services; conduct quality assurance testing; monitor activity on Fethr services; provide technical support; and/or to provide other services to Fethr. Except as otherwise stated in this Privacy Policy, these third-party service providers are required by contract not to use your Personal Data other than in connection with the services requested by Fethr.

  • Business Transactions. If another company acquires, or plans to acquire our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy and Cookie Policy.

  • Other Disclosures With Your Consent. We may explicitly ask if you would like us to share your information with other third parties who may not be described elsewhere in this policy. For example, we may ask you if you would like to back-up your account, or the information stored within your local device, to a third-party service such as Apple or Google cloud backup.

  • Legal Obligations. Fethr may preserve or disclose Personal Data in response to a lawful legal request, including: subpoenas, warrants, or court orders; in connection with any legal process; to comply with relevant laws; to establish or exercise our rights to defend against legal claims; if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, or a violation of our policies; or as otherwise required by law.

HOW LONG DO WE KEEP PERSONAL INFORMATION?

We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you book an event with us we will keep the information related to your event, so we can fulfil the specific arrangements you have made and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the event. The information may also be retained so that we can continue to improve your experience with us.

We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 7 years.

COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

 

What are cookies?

  • Cookies are small pieces of information sent to your browser to authenticate, track, and maintain specific information about your interactions with a site. Fethr uses cookies to remember who you are, and to remember saved search criteria for your searches. For example:

    • Our cookies will remember your chosen language and country so that when you visit our website the pages are in that language and the departure airports are in that country.

    • If you're halfway through a booking our cookies will allow you to browse other areas of the website and then return back to your booking with the relevant booking data still in place.

​How we use cookies

 

The type of information we collect depends on what services you sign up for. You can instruct your browser to refuse cookies, although this may prevent access to or limit access to some services on the site.

 

We use cookies to help us to make our website more useful and personal for you.

 

By using this website and our other online services you agree that we can store and access cookies and data about your use of our website as described on this page.

 

You can learn more about cookies and how we use them, as well as how to change your personal cookie settings below.

 

What cookies do we use?

  • Our cookies fall into the following categories:

    • Strictly necessary cookies are essential in order to help you efficiently move around the website and use its features, such as accessing secure areas of the website. Without these cookies, we cannot provide certain services. Examples of how we use strictly necessary cookies include:

      • balancing website traffic to ensure users receive a consistent and reliable service.

      • limiting traffic to key parts of the website to maintain performance levels.

      • storing your acceptance of our privacy policy, cookies policy and website terms of use, without which access is not granted to our website.

      • managing the performance of the website during high traffic periods.

    • Performance/statistics cookies collect information about how visitors use our website and are only used to improve how our website works. Without these cookies, you are less likely to receive invitations from us to complete surveys, and we will receive less detailed information about how you use our website. Examples of how we use performance/statistics cookies include:

      • collecting statistics about which pages visitors go to most often.

      • reviewing any error messages users see while browsing.

      • gathering feedback through customer satisfaction surveys.

      • gaining insight into how visitors use our website.

    • Functionality/preferences cookies allow our website to remember choices you make and information you provide, and to offer enhanced personal features. These cookies may also be used to enable services you have asked for such as watching a video. These cookies cannot track your browsing activity on other websites. Without these cookies you may find that certain non-essential features on our website don’t work, and you may find that our website is less convenient and reliable. Examples of how we use functionality/preferences cookies include:

      • remembering your language and country of choice and presenting relevant content.

      • personalising your experience so you receive content that is relevant to you.

      • testing different designs before making them permanent for all users to optimise the design experience so you find our site easier to use.

      • remembering who you are when you come back to our website.

    • Targeting/marketing cookies remember your visits to our website and are used to help us and our partners to deliver advertising that is more relevant to you and your interests. They include third-party cookies placed by our partners and other advertisers who share cookie data with us. These cookies can also help us to limit the number of times you see an advertisement and to measure the effectiveness of an advertising campaign. Without these cookies you are likely to see less personalised advertising on websites and some of our partner offers may not work as expected. Examples of how we use targeting/marketing cookies include: 

      • allowing our website to serve up different versions of a page for marketing purposes.

      • allowing third parties to display appropriate advertising and to track its effectiveness.

      • displaying messages which offer a selection of products based on your viewing behaviour on our website and other selected websites.

      • understanding our customers and members (including their online behaviour) that then drives all kinds of data-led usage. This may include sharing and receiving cookies with third parties from time to time.

Controlling and deleting cookies on your device

You can use your browser settings to disable or delete cookies. If you disable cookies in your browser, some areas of our website may not function properly or be accessible. If you delete your existing cookies:

  • We will no longer know that you've opted out of online behavioural advertising, so the banners from our third-party advertisers will reappear when you visit other selected websites.

  •  We will no longer automatically remember some information that you have provided to us (such as your language and country preferences) and you may be asked to provide this information again.

CROSS-BORDER DATA TRANSFERS

What countries will your personal information be sent to?

Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and outside the European Economic Area and the UK.

The nature of our business means it is often necessary for us to send your personal information outside the European Economic Area or the UK to fulfil your bookings. This occurs because our business and the third parties identified in ’Who do we share your personal information with?’ have operations in countries across the world.

In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us.

This may involve sending your data to countries where under their local laws you may have fewer legal rights.

Where your personal information is transferred outside the European Economic Area or the UK because we are using a service provider in a third country, we will implement safeguards so that your personal information continues to be protected to the standards set out in this privacy policy.

Disclosure of information across borders

 

When we disclose personal information in accordance with this Privacy Policy, it may be accessed from, transferred to, and/or stored outside the country in which you are located. The data protection laws in that country may be of a lower standard than those in your own country.  We will, in all circumstances, safeguard the personal information as set out in this Privacy Policy.

Refer to the section on European Data Protection Laws for information about the export of personal data from the EEA to outside the EEA.

 

 

If you would like more information on these safeguards, please contact the Data Protection Officer, Fethr Ltd, 71-75 Shelton St, London UK, WC2H 9JQ.

 

 

 

BEHAVIOURAL TARGETING

 

What is behavioural targeting?​

  • Online behavioural advertising (also known as interest-based advertising) is a way of serving advertisements on the websites you visit and making them more relevant to you and your interests.

  • Behavioural advertising works by grouping web users with shared interests together based on their previous browsing activity, and then serving advertisements to those users to match their interests. In this way, advertising can be made as relevant and useful as possible.

  • Relevant advertisements can also be delivered based upon the website content you have just been viewing. This is known as retargeting.

 ​

How to opt out of third-party online behavioural advertising

  • You can use the sites below to opt out of behavioural advertising from certain third-party advertising networks:

  • Opting out of online behavioural means that advertising that you do see is likely to be less relevant to your interests. However, opting out

    • does not mean that the advertising of our products and services on our own websites will stop being personalised to your interests.

    • may not stop all online behavioural advertising because it only applies to those third-party advertising agencies that have signed up to those services.

    • does not mean that there will be no more advertising on this website or other websites you access.

 

YOUR RIGHTS

 

We want you to be in control of your information, so we have provided you with the following tools:

  • Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help at support@fethr.app.

  • Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

  • Deletion. You can delete your account by using the corresponding functionality directly on the service.

  • We want you to be aware of your privacy rights. Here are a few key points to remember:

    • Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request support@fethr.app.

    • Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us support@fethr.app.

    • For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

    • Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

    • Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

    • Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

    • Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

 

HOW WE PROTECT YOUR INFORMATION

  • IT Security

    • We hold your personal information in a combination of hard copy and electronic files. We use third party information system providers who may store or have access to your personal information. Secure Sockets Layer (SSL) encrypts the information you send through this website.

    • No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain physical, electronic, and procedural safeguards to protect your personal information in accordance with data protection legislative requirements and industry standards.

    • If we have given you (or you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures notified to you. We require that you do not disclose your passwords to anyone else.

 

  • ​Our service providers

    • We may also disclose your personal information to data processors (including but not limited to operators of social networking, card payments, and general technology services). The countries in which these third parties are located include the United Kingdom, and the United States.

  • Access to, and correction of, information about you

    • In some countries you have the right to access, or correct, the personal information that we hold about you. If you would like to request access to, deletion, or correction of, your personal information that we hold, please contact us using the details in the section titled 'Contact Us'.

    • To the extent required by applicable law, we will provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, within a reasonable timeframe (or any time frame stipulated by the laws that apply to your request). If we are permitted to withhold some of your personal information and we choose to do so, we will advise you when responding to your request. If we refuse to provide you with access to, or to amend, the information, to the extent required we will notify you of our reasons for the refusal and how you may complain about the refusal.

    • Where permitted by law, we may recover from you our reasonable costs of supplying you with access to this information. However, we will not charge you for the making of the request or to correct or update your personal information.

PRIVACY COMPLAINTS AND FURTHER INFORMATION

If you have a concern about your privacy or you have any query on how your personal information is collected or used please contact us using the details below. We will respond to your query or complaint within a reasonable time.

If you are not satisfied with our response, you may also contact the body responsible for administering the privacy laws in your country.

In the United Kingdom you may contact the Office of the Information Commissioner.

​CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

 

​CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy as our business requirements or the law changes. Any changes to this Privacy Policy will be updated on this website, so please visit periodically to ensure that you have our most current privacy statement. 

 

MATTERS OUTSIDE THE SCOPE OF THE PRIVACY POLICY

Our website may contain links to other companies’ websites or materials. If you choose to access such third-party websites, our privacy policy will not apply, and the privacy policy of the third-party website will apply instead. 

 

 

EUROPEAN SPECIFIC DATA PROTECTION LAWS

This section applies if you are based in the European Economic Area (EEA) during your interactions with us and sets out the additional information that we are required to provide to you under European data protection laws.

Under European data protection laws, use of personal information must be based on one of a number of legal grounds and we are required to set out the grounds in respect of each use. Companies may process personal data only when the processing is permitted by the specific legal ground set out in the law.

Below, we have set out the relevant grounds that apply to each purpose of data processing that is mentioned in this Privacy Policy.

The purpose of data processing and it's uses;

Purposes of the data processing

  • To provide and administer our products and services;

    • contract performance

    • legitimate interests (to allow us to perform our obligations and provide services to you)

  • For sensitive Personal Data

    • Consent

  • For marketing purposes

    • legitimate interests (in order to market to you) and consent (which can be withdrawn at any time)

  • To provide customer support

    • contract performance

    • legal obligation

    • legitimate interests (to allow us to correspond with you in connection with our services)

  • To comply with our legal obligations and for safety and security purposes

    • legal obligation

    • legal claims

    • legitimate interests (to cooperate with law enforcement and regulatory authorities)

  • For sensitive Personal Data

    • legal claims

    • vital interests

    • substantial public interest

    • public interest in area of public health

  • To prevent and detect fraudulent activity

    • legal claims

    • legitimate interests (to prevent, detect and take action in response to fraudulent activity, including fraudulent transactions)

 

  • To conduct market, consumer and other research

    • legitimate interest (to ensure that we understand our clients’ requirements)

  • To ensure website content is relevant

    • legitimate interests (to allow us to provide you with the content and services on our website)

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Legal grounds for use of personal information

The principal legal grounds for our use of your personal information are as follows:

  • Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use and may withdraw your consent).

  • Contract performance: where we are required to collect and handle your personal information in order to provide you with the services that we have contractually agreed to provide to you.

  • Legal obligation: where we need to use your personal information to comply with our legal obligations.

  • Vital interests: where we need to process your personal information in order to protect the vital interests of you or another natural person, e.g. where you require urgent assistance.

  • Public interest: where we need to process your personal information in order to carry out a task that is in the public interest.

  • Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

 

The legal grounds for our use of the sensitive categories of personal information are:

  • Consent: where you have explicitly consented to our use of your personal information. You may withdraw your consent to the use of your personal information.

  • Vital interest: where we need to process your personal information in order to protect the vital interests of you or another natural person where you or the other person is physically or legally incapable of giving consent.

  • Legal claims: where your personal information is necessary for us to establish, exercise or defend any legal claims.

  • Substantial public interest: where we need to process your personal information for reasons of substantial public interest set out in EU law or the laws of the member state in which you are based.

  • Public interest in area of public health: where we need to process your personal information for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, set out in EU law or the laws of the member state in which you are based.

Disclosure of information outside the EEA

When we transfer personal information from inside the EEA to outside the EEA, we may be required by law to take specific measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information from the EEA to these jurisdictions. In countries which have not had these approvals, we will use appropriate safeguards to protect any personal information being transferred, such as EU Commission-approved model contractual clauses or binding corporate rules permitted by applicable legal requirements.

Please refer to the section “Contacting Us” if you would like to see a copy of the specific safeguards applied to the export of your personal information.

Retention period

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either securely destroy it, or irreversibly anonymise the data (and we may further retain and use the anonymised information).

​​

Marketing

You have the right to ask us not to process your personal information for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not opting in when we invite you to participate in our marketing activities. You can also exercise the right by contacting us as set out in the “Contacting Us” section.

Additional Rights Under EU Law

In addition to the rights outlined elsewhere in this Privacy Policy, under certain conditions you may have the right under EU data protection law to ask us to:

  • Provide you with further details on how we use and process your personal information;

  • Delete personal information we no longer have grounds to process; and

  • Restrict how we process your personal information while we consider an inquiry you have raised.

In addition, under certain conditions, you have the right to:

  • Where processing is based on consent, withdraw the consent;

  • Lodge a complaint with a supervisory authority;

  • Object to any processing of personal information that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights and freedoms; and

  • Object to direct marketing (including any profiling for such purposes) at any time.

You can exercise these rights by contacting us at the “Contacting Us” section below.

These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

Resolving your concerns

If you wish to gain access to your personal information, have a complaint about a breach of your privacy or you have any query on how your personal information is collected or used, please forward your request, complaint or query to the address below. We will respond to your query or complaint as soon as possible. Privacy complaints about our acts or practices may be investigated by the Privacy Commissioner who has the power to make a determination including a declaration that the claimant is entitled to compensation.

 

CONTACTING US

 

Please contact us to find out more about our procedures and policies in relation to the collection, use, disclosure, storage and handling of personal information.

If at any time you wish to know what information we are holding about you, believe we may hold information about you which is incorrect / out of date, would like to request we delete your personal information, or you have any questions about our Privacy Policy, you can contact us on:

  • Email: support@fethr.app

  • Phone: +44 7739 796 913

  • Post: C/- Data Privacy Officer, Fethr Ltd, 71-75 Shelton St, London UK, WC2H 9JQ

If you still require further information, then you should contact the Information Commissioners Office whose details follow: