TrendVision Labs Ltd. is the publisher and operator (referred to as the “Company”, “we”, “our” or “us”) of the www.famesters.com website (referred to as the “Website”).

The Company is committed to protecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process will vary depending on how you use the Website.

This privacy policy:

• provides an overview of how the Company collects and processes your personal data and tells you about your rights under the EU General Data Protection Regulation (“GDPR”);
• is directed to individuals who are visitors of the Website (referred to as “Browsers”).

For the purposes of this privacy policy:

• when we refer to “personal data” or “personal information” we mean data which identifies or may identify you and which may include, for instance, your email or IP address;
• when we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data; and
• when we refer to “sensitive data” we mean personal data which may reveal information about racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, genetic or biometric data.

1. Who we are

TrendVision Labs Ltd. is a legal entity, registered in the Republic of Cyprus under registration number HE 370121, having its registered office at Agiou Gerasimou 7A, 4183, Limassol, Cyprus.

If you have any questions, comments and/or requests regarding this privacy policy or wish to obtain more details in relation to the personal data we process about you, please contact us by sending an email to  [email protected].

2. How we collect your personal data

We obtain your personal data mainly through any information you provide directly to us through our Website. Sometimes your personal data can also be shared with us. Below is a list of ways we collect your personal data:

• when you visit and/or use our Website;
• when you complete our feedback form;
• when you take part in surveys or report a problem with our Website; and/or
• when you contact with us via email, post or other ways of communication.
• when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this privacy policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

3. Personal data that we collect and process

We will collect different categories of personal data from you depending on your level of interaction with our Website. We will limit the collection and processing of information to information necessary to achieve one or more of our legitimate purposes as identified in this privacy policy.

Personal Data we collect and process from Browsers

• Technical Data, including your Internet Protocol (IP) address and associated country, your browser type and version, time zone setting and location, smart device information, mobile phone network information, operating system and platform and other technology on the devices you use to access this Website;
• Usage Data, including your communication preferences and information about how you use our Website including the services you viewed or searched for, page response times, download errors, length and number of visits and page interaction information (such as scrolling, clicks and mouse-overs) as well as the links you clicked on or used; 
• User Submitted Data, including work email, job title, first name, last name, company name, number of employees etc.;
• Communications and correspondence, including any correspondence between you and us, including customer service requests, emails and live chats.
• Consents, including any permissions, consents or preferences that you give to the Website.

We may also collect, use and share aggregated data such as statistical or demographic data for the purpose of customizing our marketing efforts or the use of our Website. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For instance, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature, to generate statistics about our users, to calculate the percentage of users accessing a specific Website feature, to calculate ad impressions served or clicked on, or to publish visitor demographics. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which shall be used in accordance with this privacy policy.

4. Why we need your personal data and how we use it

We will only use and share your information where it is necessary for us to provide you with our lawful services in accordance with this privacy policy. We would like to ensure that you fully understand why your information may be used. We will only use your personal data when the applicable local law allows us to.

We will most commonly use your personal data in the following circumstances:

• a) where we need to perform our services to you;
• b) 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;
• c) where we need to comply with a legal or regulatory obligation; and/or
• d) where you have given us your consent.

Below, we describe these circumstances in further detail.

• (a) Performance of our services to you
  • (1) Provision of services
    
    We may collect and process your personal data where it is necessary in order to present our Website and its contents to you, including any interactive features on our Website and to provide you with information, products or services that you request from us.
• (b) Legitimate interests
  • (1) Analytics
    
    We may collect and process your personal data where it is necessary in order to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed and demographic patterns.
  • (2) Functionality and security
    
    We may collect and process your personal data where it is necessary to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
  • (3) Other legitimate interests
    
    In addition to the above, we may process your data, to the extent required for our business needs in order to:
    • 1) develop new services on our Website as well as analyze and target new markets;
    • 2) protect our legal rights and interests (including legal claims and preparing our defense in litigation);
    • 3) monitor, maintain and improve internal business processes, information and data, technology and communication solutions and services;
    • 4) ensure network information security, including monitoring Browsers’ access to our information technology for the purpose of preventing cyber-attacks, unauthorized use of Website and prevention or detection of crime;
    • 5) monitor the performance and effectiveness of our services and the Website; and
    • 6) assess the quality of our customer services.

• (c) For compliance with legal obligations

When you visit and/or use our Website (and throughout your relationship with us), we are required to comply with certain legal and regulatory obligations which may involve the processing of your personal data. This may include processing to:

• 1) perform checks and comply with laws relating to fraud;
• 2) identify other infringements of our Terms of Use; and
• 3) manage contentious regulatory matters, investigations and litigation.

• (d) You have provided your consent

We will ask for your consent when we wish to provide marketing information to you in relation to our services which we believe may be of interest and of benefit to you.

You have the right to revoke your consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.

5. Who we share your personal data with

It is our policy not to use or share personal data about you in ways unrelated to those described in this privacy policy without also providing you with an opportunity to opt out or otherwise object to such unrelated uses. However, we may disclose personal data about you, or information regarding your use of the services or the Website to third parties for any of the reasons set out hereinabove, or if we are legally required to do so, or if we are authorized under our contractual and statutory obligations. When we disclose your personal data to service providers, we will ensure that they are bound by a contract requiring them to comply with their GDPR obligations. Under the circumstances referred to above, recipients of personal data may be, for example:

• (a) governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings or investigations by such parties or in order to enable the Company to comply with its legal and regulatory requirements. We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed or suspected or if we are compelled to do so by lawful criminal, civil or administrative process, discovery requests, subpoenas, court orders or writs, to enforce applicable terms of use, including investigation of potential violations thereof, to detect, prevent or otherwise address security or technical issues, protect against harm to the rights, property or safety of our company, our users, our employees, or others; or to maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
• (b) buyers or other legal successors in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website Browsers, is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to ensure that the entity to which we transfer your personal data uses it in a manner that is consistent with this privacy policy; and/or
• (c) legal or other professional consultants.

We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third-parties for conducting general business analysis. This information does not contain any personal data and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.

Please note that we have never sold and will never sell your personal data to third parties.

6. Security of your personal data

We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your personal data from unauthorized access and disclosure. For instance, only authorized employees are permitted to access personal data, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your personal data between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal data.

7. Information we transfer

Some of our external third parties are based outside the European Economic Area (“EEA”) so the processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• b) Where we use service providers outside the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the European Union.
• c) Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the European Union and the US.

We may additionally, in rare occasions, transfer your personal data to a party outside the EEA where we have your prior explicit consent to do so or where such transfer is necessary for the provision of our services to you.

8. Marketing information

We may process your personal data so as to inform you about existing and/or future services that may be of interest to you by sending you periodic announcements with details on existing and/or new services and/or programs.

You have the right to object at any time to the processing of your personal data for marketing purposes, by sending us an email at  [email protected] or by clicking at the opt-out link at the bottom of any marketing emails we send you.

We can only use your personal data to promote our services to you if we have your explicit consent to do so.

9. How long we keep your personal data for

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Where we no longer need to process your personal data for purposes set out in this privacy policy, we will delete your personal data from our systems. However, we may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and that your data are only used for those purposes. The period for which we keep your personal information that is necessary for compliance and legal enforcement purposes varies and depend on the nature of our legal obligations and claims in the individual case.

Where permissible, we will also delete your personal data upon your request. Information on how to make a deletion request can be found under the paragraph “Your data protection rights” below.

If you have questions about our data retention practices, please contact us electronically by sending as an email at [email protected].

10. Your data protection rights

Subject to local law, you have certain rights regarding the personal data we collect, use or disclose and that is related to you. We want to make sure you are aware of your rights in relation to the personal data we process about you. We have described those rights and the circumstances in which they apply further below.

• Right to Access: This enables you to get access or receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
• Right to Data Rectification and Correction: If you believe that any of the information that we hold about you is inaccurate or incomplete, you have a right to request that we correct the inaccurate personal information.
• Right to be Forgotten / Erasure: You may request that we delete your personal information if you believe that:
  • a) we no longer need to process your information for the purposes for which it was provided;
  • b) we have requested your permission to process your personal information and you wish to withdraw your consent; or
  • c) we are not using your information in a lawful manner.
• Right to object: You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you exercise your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedom or for the establishment, exercise and defense of legal claims.

You also have the right to object where we are processing your personal data for direct marketing purposes. This also includes profiling in as much as it is related to direct marketing.

If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.

Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your personal data. Please note that if you object us processing your personal data, you may no longer be able to use several functionalities of our Website.

• Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data. This enables you to ask us to restrict the processing of your personal data if:
  • a) it is not accurate; or
  • b) it has been used unlawfully but you do not want us to delete it; or
  • c) it is not relevant any more, but you want us to keep it for use in possible legal claims; or
  • d) you have already asked us to stop using your personal data but you are waiting for us to confirm if we have legitimate grounds to use your personal data.

Please note that if you request us to restrict processing of your personal data, you may no longer be able to use several functionalities of our Website.

• Right to data portability: Where we have requested your permission to process your personal data or you have provided us with information for the purposes of entering into a contract with us, you have the right to receive the personal data you provided to us in a portable format. 

If we ask for your consent to use your personal data, you can withdraw your consent at any time. Please note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our Website.

Please note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us electronically by sending us an email at [email protected] .

We endeavor to address all your requests promptly.

11. How to access or modify your personal data

We remain dedicated to the protection of your data and we want to be clear about the type of information collected. You have a right to ask for and obtain from us confirmation as to whether or not we hold any personal data which concerns you.

12. Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us. You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Website.

13. Our communication with you

If you have any questions about this privacy policy or our information-handling practices, please contact us electronically at [email protected] .

14. Right to complain

If you wish to lodge a complaint about how your personal data is used by the Company, you may contact us electronically at the email address [email protected] .

Upon receipt of your complaint, we will investigate it and respond to you within a reasonable time.

We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the collection, use and disclosure of personal data that cannot be resolved by an individual and us.

You also have the right to complain to the data protection supervisory authority of the country in which you reside, provided that such country is a Member State of the European Union or is located within the EEA.

15. Third-party links

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements or representations about their accuracy, content or thoroughness. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

16. California Consumer Privacy Act Notice

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:

• Opt-out of the sale of their personal information, should we sell their personal information;
• Be informed of certain information concerning our collection and use of their personal information;
• Request that we delete certain personal information we collected from them;
• Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
• Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA;
• Correct inaccurate personal information that we have about them;
• Limit the use and disclosure of sensitive personal information collected about them.

This Website does not sell nor has it sold in the past 12 months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to record such preference, please send us an email at  [email protected].

17. Changes to this privacy policy

We reserve the right to update, revise, amend and/or modify this privacy policy at any time in order to reflect any changes to the way in which we process your personal data or changing legal requirements.

Although we will notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at Famesters Privacy Policy  so you are aware of any changes. The date of the latest version of the privacy policy will appear at the top of the webpage hosting the policy.

18. No Error Free Performance

We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy.