1. GENERAL PROVISIONS
- The Policy serves as an integral and substantive part of the Feedc User Agreement.
- The User hereby gives an unambiguous, clear and explicit consent to the processing of Personal Data and Special Categories of Data relating to them for specific purposes as provided herein.
- Personal Information/Personal Data shall mean any information connected to an identified or identifiable natural person. A person shall be identifiable when he/she may be identified directly or indirectly, in particular by an identification number or by any physical, physiological, psychological, economic, cultural or social features specific to this person.
- Special Categories of Data – data connected to a person’s racial or ethnic origin, political views, religious or philosophical beliefs, membership of professional organizations, state of health, sexual life, criminal history, administrative detention, putting a person under restraint, plea bargains, abatement, recognition as a victim of crime or as a person affected, also biometric and genetic data that allow to identify a natural person by the above features;
- Data Processing – any operation performed in relation to the personal data, whether or not by automated means, such as collection, recording, photographing, audio recording, video recording, organization, storage, alteration, restoration, request for access to, use or disclose by way of data transmission, dissemination or otherwise making them available, grouping or combination, locking, deletion or destruction;
- GDPR – the General Data Protection Regulation (EU Regulation 2016/679);
- Third Party means a natural or legal person, public authority, agency of 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;
- “Controller”, “Processor”, “Data Subject”, “Personal Data Breach” shall have the same meanings as in the GDPR.
3. PROCESSING OF PERSONAL INFORMATION BY FEEDC
- Irrespective of which country the User lives in, the User authorizes Feedc to collect and process their information in the Republic of Georgia and in any other country where Feedc operates and provides Services.
- The information which the User provides through Feedc Services is public for as long as they do not delete it.
- Feedc collects and processes the content and Personal Information which the User provides when they use the Services. The Personal Information of the User might include the following: name, username, password, email address, date of birth, current location (city/country), phone number and etc. The location (country, city) of the User is always publicly visible, when the User shares/posts anything through Feedc Services.
- The User might also provide Feedc with their Special Categories of Data, such as ethnic origin, religious or political views, etc. The User decides in their sole discretion what kind of Special Categories of Data (if any) to provide through Feedc Services.
- The name/username, photo and other personal/profile information of the User is listed publicly by Feedc on the User’s profile page and in search results.
- Feedc may use the User’s contact information to send them information about Feedc Services and to help prevent spam, fraud or abuse and to help others find the User’s account.
- Feedc collects the information about the type of content that the User views or engages with, the features they use, the actions they take, the people and accounts they interact with and the time, frequency and duration of their activities.
- If the User uses Feedc Services for purchases or other financial transactions, Feedc collects information about the purchase or transaction. This might include payment information, such as credit/debit card number and other card information, billing, delivery and other relevant contact details in this regard.
- Feedc also collects contact information if the User chooses to upload, sync or import it from a device, which Feedc uses to help the User and others find and connect with other users they may know.
- Feedc can also receive and analyze content, communications and information that other users provide when they use Feedc Services. This might include information about the User, such as when others share or comment on the User’s photo, send a message to the User or upload or import the User’s information.
4. ADDITIONAL INFORMATION
- When the User uses Services Feedc may collect and receive information from and about the computers, phones and other web-connected devices the User uses that integrate with Feedc Services and Feedc combines this information across different devices the User uses.
- Information which Feedc obtains from the devices as mentioned in article 4.1 includes the following:
- the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins;
- information about operations performed on the device;
- unique identifiers, device IDs and other identifiers, such as from games, apps or accounts that the User uses or other identifiers associated with the same device or account;
- bluetooth signals, information about nearby Wi-Fi access points and mobile phone masts;
- data/information that User allows Feedc to receive through device settings that the User turns on, such as access to the User’s GPS location, camera or photos;
- information such as the name of the User’s mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on the User’s network;
- data from cookies stored on the User’s device.
5. PROCESSING OF PERSONAL INFORMATION BY THIRD PARTIES
- Feedc may use third-party services to provide Feedc Services. These third-party service providers may collect information sent by the User’s device as part of a web page request, such as cookies or the User’s IP address.
- The third-party service providers provide Feedc with information about the User’s activities, including information about the User’s device, websites they visit, purchases they make through Feedc Services, the ads they see and how they use third-party services.
- Third-party service providers receive the User’s Personal Data when they visit or use their services. Feedc requires third-party service providers to have lawful rights to collect, use and share the User’s Personal Data before providing Feedc with any data.
- Feedc shares the User’s payment information with payment service providers to process payments, to prevent, detect and investigate fraud or other prohibited activities.
6. PURPOSE OF DATA PROCESSING
- Feedc uses and processes the User’s Personal Data (as described in articles 3-4) for the following purposes:
- to provide and support the Feedc Services;
- to provide and manage the User’s account;
- to process any transactional or ongoing payments;
- for analytics, market research and business development, including to operate and improve Feedc’s app, associated applications and associated social media platforms;
- to run competitions and/or to offer additional benefits to the User;
- to develop, test and improve Services, including by conducting surveys and research and testing and troubleshooting new products and features;
- to provide and personalize ads, offers and other sponsored content that Feedc shows to the User;
- to verify the User’s account and activities in order to promote safety and security;
- to enable the functionality that helps Feedc provide the Feedc Services;
- to enable Feedc to provide the User with the best experience possible;
- to better understand how people use the Feedc Services so that Feedc can improve them;
- to send the User information about Feedc Services and to help prevent spam, fraud or abuse and to help others find the User’s account;
- To contact the User by email or telephone with information, news and offers on the Services. Feedc will not send any unlawful marketing or spam and will always work to protect the User’s rights fully and to comply with the obligations under the GDPR and applicable Georgian laws. The Users will have the opportunity to opt-out.
7. DELETING AND MODIFYING THE USER’S PERSONAL INFORMATON
- The User is entitled to access, modify or delete the Personal Information they provide to Feedc at any time.
- The User can also permanently delete the account. Once the account is deleted, it is not viewable on Feedc.
- Feedc stores the User’s Personal Data until it is no longer necessary to provide the Services. For the avoidance of doubt, Feedc is entitled to store the Personal Data of the User for three (3) months following the removal/termination of the User’s account.
- When the User deletes the account, Feedc delete things they have posted, such as the User’s photos and status updates and the User will not be able to recover this information later.
8. GENERAL OBLIGATIONS OF FEEDC
- implement appropriate technical and organizational measures to protect the Personal Data;
- assist the User by appropriate technical and organizational measures insofar as this is possible to enable the User to fulfill any obligations to respond to requests for the exercise of data subject rights by a data subject under GDPR;
- assist the User in ensuring compliance with their obligations pursuant to the GDPR, taking into account the nature of the processing and the information available to Feedc;
- make available to the User all information that is reasonably necessary to demonstrate Feedc’s compliance with its legal obligations as a Data Processor under Article 28 of the GDPR;
- notify User without undue delay of the discovery by Feedc of any actual or suspected Personal Data Breach involving the Personal Data. Such notice shall include, at the time of notification or as soon as possible after notification, details of the nature of the breach and number of records affected, the category and approximate number of affected data subjects, anticipated consequences of the breach and any actual or proposed remedies for mitigating the possible adverse effects of the breach.
- comply with any other obligations stipulated under the GDPR and applicable Georgian laws.
9. AMENDMENTS TO THE POLICY
- If Feedc decides to make changes/amendments to this Policy, the User will be notified in advance to review the revised Policy before they choose to continue using Feedc Services.
10. FINAL PROVISIONS
- Notwithstanding anything to the contrary in this Policy, Feedc may disclose the Personal Information of the User if it is so required by applicable law or by any competent authority under Georgian law.
Effective Date: [March 23, 2020]