Privacy Policy
When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
We have prepared this privacy policy (‘Privacy Policy’ or ‘Policy’) to explain to you how we collect, use, and share information and Personal Data (as defined under applicable law) we obtain through your use of the Internet sites, applications and online services (‘Services’) that are operated by, controlled by or affiliated with Fairphonic Pte Ltd (herein referred to as ‘Fairphonic’). This Privacy Policy only covers information collected through the Services and via direct communications between you and Fairphonic, and does not cover any information collected at any other website, application or otherwise by us (unless specifically stated), including when you call us, write to us, or communicate with us in any manner other than through the Services. By using the Services, you consent to such collection, use and sharing of your information and Personal Data and agree to the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you must leave this website and discontinue all use of any of our Services.
We will only process your Personal Data in accordance with applicable data protection and privacy laws. For the purposes of UK and EU data protection legislation, the data controller is Fairphonic Pte Ltd, 6 Raffles Quay, #11-07, Singapore 048580.
CONTENTS:
1. INFORMATION AUTOMATICALLY COLLECT BY US
2. INFORMATION AUTOMATICALLY COLLECTED BY TECHNOLOGIES
3. INFORMATION YOU VOLUNTARILY SUBMIT
4. INFORMATION USE
5. SOCIAL NETWORK INTEGRATION
6. OUR INFORMATION SHARING PRACTICES
7. ANONYMOUS DATA
8. USERS OUTSIDE SINGAPORE AND CONSENT TO TRANSFER
9. ADVERTISING
10. CHOICE/OPT-OUT OF COMMUNICATIONS
11. RETAINING, MODIFYING AND DELETING YOUR PERSONAL DATA
12. FINANCIAL DATA
13. EU DATA RIGHTS UNDER GDPR
14. SECURITY
15. LINKS
16. CHILDREN’S POLICY
17. SENSITIVE PERSONAL DATA
18. CHANGES
19. CONTACT US
1 INFORMATION AUTOMATICALLY COLLECTED BY US
We and our third party service providers (including any third party content, advertising, and analytics providers) automatically collect certain information from your device or web browser when you interact with the Services to help us understand how our users use the Services and to target advertising to you (which we will refer to in this Privacy Policy collectively as ‘Usage Data’). For example, each time you visit the Services we and our third party service providers automatically collect your IP address, mobile device identifier or other unique identifier, browser and computer type, access time, the Web page you came from, the URL you go to next, the Web page(s) that you access during your visit and your interaction with content or advertising on the Services.
We and our third party service providers use such Usage Data for a variety of purposes including to diagnose problems with our servers and software, to administer the Services, to gather demographic information and to target advertising to you on the Services and elsewhere online. Accordingly, our third party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Services in a manner that does not identify personally any specific individual. The Usage Data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Data.
2 INFORMATION AUTOMATICALLY COLLECTED BY TECHNOLOGIES
As you navigate through and interact with our website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information, search terms, and cookie information.
A cookie is a piece of information that the computer that hosts our website gives to your browser when you access the website. Our cookies help provide additional functionality to the website and help us analyze Site usage more accurately. On most web browsers, you will find a “help” section on the toolbar which you can refer to for how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the website’s features. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you will not be able to sign in to the Services or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser, you will have to again reset your browser to refuse all cookies or indicate when a cookie is being sent.
Our Services use the following types of cookies for the purposes set out below.
a) Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages that they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
b) Essential Cookies: These cookies are essential to provide you with services available through our Services and to enable you to use its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
c) Functionality Cookies: These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, remembering which polls you have voted in and in some cases, to show you poll results, and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
d) Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
e) Targeted and Advertising Cookies: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. These cookies also store your location, including your latitude, longitude, and GeoIP region ID, which helps us show you locale-specific news and allows our Services to operate more efficiently. You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive cookies and tailored adverts from companies that are not listed.
3 INFORMATION YOU CHOOSE TO SUBMIT
When you sign up for newsletters or notifications, purchase items through our Services, or register for events, you voluntarily provide us with personal information by which someone could identify you as a specific, identifiable individual (which we will refer to in this Privacy Policy collectively as “Personal Data”). This includes your name, email address, gender and even age group. You can also choose to add a phone number. When you purchase anything from our website, you provide us with additional data which includes payment information like your credit card and your home address. By voluntarily providing us with this sort of Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to this website, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Fairphonic and the authorized third parties referred to herein.
If you are purchasing anything from the website, then we collect Personal Data for and on and behalf of our merchandisers and e-commerce platforms which include you:
1. Name, surname, company name;
2. Shipping and billing address;
3. Email address and phone number;
4. IP address and device data; and
5. Other information that you share with us using our Services or during checkout.
We use your Personal Data to fulfill your requests for products and services, to improve our Services, to contact you from time to time, with your consent, about us and our products and services, and as otherwise described in this Privacy Policy.
You can also choose to submit or we may collect additional information about yourself, such as demographic information (for example your gender, birth date, or zip code) and information about your preferences and interests. Failure to provide any required Personal Data will prevent us from being able to provide the Services you request or otherwise inhibit our ability to provide the Services.
We refer collectively to all information we collect that is not Personal Data, including Usage Data, demographic data and de-identified Personal Data, as “Non-Personal Data”. If we combine Non-Personal Data with Personal Data, we will treat the combined information as Personal Data under this Privacy Policy. Personal Data, Non-Personal Data, and User Submissions are referred to in this Privacy Policy collectively as “User Information.”
4 INFORMATION USE
We use the information we collect, including Personal Data and Usage Data:
1. To enable you to use our Services;
2. In the case of purchasing anything from the website to process your transactions;
3. To share with authorized third parties as set out in this Privacy Policy (including investors and sponsors)
4. To provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys (with your consent) and processing survey responses;
5. To provide you with information, products, or services that you have requested;
6. with your consent, to provide you with information, products, or services that we otherwise believe will interest you, including special opportunities from us and our third party partners;
7. To tailor content, recommendations, and advertisements we and third parties display to you, both on the Services and elsewhere online;
8. For internal business purposes, such as to improve our Services;
9. To administer and process contests, sweepstakes, and promotions;
10. To contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms of Use, or any of our other policies;
11. To comply with regulatory and legal obligations; and
12. For purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.
5 SOCIAL NETWORK INTEGRATION
If you visit our Services on a device through which you also interact with social networks or if you interact with us through a social media function such as a plug-in (for example, a Facebook “like” button) then you permit us to have on-going access to, to use and to store information from your social network profile (such as your name, email address, your friend list, photo, age, gender, location, birthday, social networking ID, current city, and the people/sites you follow) in accordance with this Privacy Policy. If you don’t want a social network to collect the information about you as described above, or you don’t want a social network to share it with us, please review the privacy policy, privacy settings and instructions of the applicable social network before you visit and use our Services.
6 OUR INFORMATION SHARING PRACTICES
As a general rule, we share Non-Personal Data, including Usage Data, de-identified Personal Data and aggregated user statistics, with third parties in our discretion. We share User Information, including Personal Data, as otherwise described in this Policy, and under the following circumstances:
a) Service Providers: From time to time, we enter into relationships with third parties who provide services to us (for example, analytics companies such as Google Analytics, advertisers and ad agencies, data management and storage services or credit card processing services, sweepstakes or contest prize fulfillment). In those circumstances, we disclose User Information so that such service providers perform those services. These service providers are only permitted to use your Personal Data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Data. In particular, our sites use certain Google analytics and other services, and certain pages use the Google AMP Client ID API, each of which enable collection and sharing of your information (including Personal Data) with Google for further use. For specific information on Google usage and how to control it, please see Google’s Privacy Policy at https://policies.google.com/privacy. Some service providers, such as Mailchimp, engage sub-processors to process User Information on our behalf. In those circumstances, such service providers mandate data protection obligations for User Information at the same level of protection they provide us, and are responsible for the sub-processors’ compliance with those obligations.
b) Third party Marketing: You will have a choice before we share your information with third parties for marketing purposes. Provided that you have opted-in to receive marketing messages from third parties, we share your information (including Personal Data) with third parties for those third parties’ own direct marketing purposes. Please note, messages delivered from a third party will subject you to the third party’s privacy policy. We also match your email address with third parties with whom you have also consented to share your email address and use such match to deliver custom offers or emails to you on the Services and off the Services provided you have consented to receiving such offers or emails.
c) Investors and Sponsors: We enter into relationships with investors and sponsor who allow us to deliver, maintain and improve our services. In those circumstances we disclose user information so that such investors and sponsors understand the demographic of users of our Services. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Data.
d) Change of Control: In the event we go through a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of our assets, including, without limitation, during the course of any due diligence process), your Personal Data will likely be among the assets transferred. By providing your Personal Data, you agree that we can transfer such information in those circumstances without your further consent. Should such a business transition occur, we will make reasonable efforts to request that the new owner or combined entity (as applicable) follow this Privacy Policy with respect to your Personal Data. If your Personal Data would be used contrary to this Privacy Policy, we will request that you receive prior notice.
e) Other Disclosure Scenarios: We reserve the right, and you hereby expressly authorize us, to share User Information:
- In response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims;
- If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property;
- If we believe it is necessary to investigate, prevent, or take action regarding significant abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information);
- To protect and defend our legal rights or property, our services or their users, or any other party, and to protect the health and safety of our users or the general public; and
- To our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy).
f) Facebook and Instagram Advertising: We adhere strictly to the Facebook and Instagram advertising policies:
- All advertisement data collected, received or derived from Facebook or Instagram advertisements is only shared only with people acting on our behalf (e.g. our service providers);
- All advertisement data collected, received or derived from Facebook or Instagram advertisements will be used only on an aggregate and anonymous basis to assess the performance and effectiveness of the advertisement campaigns (unless authorized by Facebook); and
- All advertisement data collected, received or derived from Facebook or Instagram advertisements, even on an aggregate and anonymous basis, will never be transferred to any advertising networks, advert exchange, data broker or other advertising or monetization-related service.
You understand that we retain the right to present macro processed advertisement data on an aggregate and anonymous basis, in respect of assessing the performance and effectiveness of the advertisement campaign, to permitted and authorised third-parties in confidence, such as our investors.
7 ANONYMOUS DATA
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data will include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.
8 USERS OUTSIDE OF THE SINGAPORE AND CONSENT TO TRANSFER
The Services are operated in Singapore. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in Singapore. By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in Singapore. You understand that the Singapore government can obtain access to the Personal Data you submit if necessary for investigative purposes (e.g., terrorism investigation). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We use appropriate and suitable safeguards for transferring your Personal Data to Singapore (e.g., standard contractual clauses issued by the European Commission, which can be accessed here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
9 ADVERTISING
We use other companies under agreements with us to serve third party advertisements when you visit and use the Services. These companies collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies, not this one.
In order to serve offers and advertisements that may be of interest to our users, we also display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide Personal Data to our advertisers when you interact with an advertisement.
10 CHOICE/OPT-OUT OF COMMUNICATIONS
We offer you the opportunity to manage your communications from us. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us or our third party partners, users may elect to modify their preferences by following the “Communications Preferences” and/or “Unsubscribe” link provided in an email or communication received. Please be aware that if you wish to remove yourself from a newsletter and/or other marketing emails from third parties that you consented to through the Services, you must do so by contacting the relevant third party. Even if you do opt-out of marketing emails, we reserve the right to send you transactional and administrative emails including those related to the Services, service announcements, notices of changes to this Privacy Policy or other Services policies, and to contact you regarding any goods or services you have ordered.
11 RETAINING, MODIFYING AND DELETING YOUR PERSONAL DATA
You may access the information we hold about you. If you wish to exercise this right, please contact us using the details in the Contact Us section, or email data@fairphonic.com If you would like to update, correct, modify or delete from our database any Personal Data you previously submitted to us, please let us know by email at data@fairphonic.com. If you delete certain information you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (for example, when you enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such promotion). We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
Please also note that purchases made through the Service results in collection of financial data which we will pass along to the requisite third party platforms or processors which we have engaged. This information will only be retained for the period necessary to fulfill such purposes and will be removed within a reasonable number of days.
Some third party party platforms or processors may retain your personal data for as long as our relationship with us is active by having an account with said third party, or as otherwise needed for them to provide their Services. After terminating our relationship with these third parties, the third parties we may continue to store copies of your personal data as reasonably necessary to comply with our legal obligations, to resolve disputes between you and us or you and your Customers, to prevent fraud and abuse, to enforce our agreements, and/or to protect our legitimate interests.
12 FINANCIAL DATA
Financial information (including Personal Information) that you have provided to us will only be shared with our third party processors in order to initiate and complete any orders placed on your account. All credit card transactions and such are processed with industry standard encryption through third party processors who only use your financial information and Personal Information for that purpose. All financial data and related Personal Information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions and policies of a third party. All such information provided to a third party is subject to their terms and conditions.
13 EU DATA RIGHTS UNDER GDPR
If you are a resident of the European Economic Area (EEA), you have the right to:
1. request access to your Personal Data and rectification of inaccurate Personal Data;
2. request erasure of your Personal Data;
3. request restrictions on the processing of your Personal Data;
4. object to processing your Personal Data; and/or
5. the right to data portability (“collectively, “Requests”).
We can only process Requests from a user whose identity has been verified. To verify your identity, please provide your email address when you make a request. For more information about how to get access to Personal Data and for exercising your rights, you can submit a request via email to data@fairphonic.com. You also have the right to lodge a complaint with a supervisory authority.
14 SECURITY
We have implemented commercially reasonable and appropriate technical and organizational security measures to help protect your Personal Data from accidental or unlawful destruction, loss, alteration, misuse, or unauthorized access or disclosure; unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your User Information, we cannot guarantee its security. You use the Services and provide us with information at your own initiative and risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Us section below or at data@fairphonic.com.
15 LINKS
The Services contain links to other websites that we do not control, and the Services contain videos, advertising and other content hosted and served by third parties. We are not responsible for the privacy practices of any third party.
16 CHILDREN’S POLICY
The Services are intended for a general audience and should only be used by children under the age of 13 with parental consent. If we collect information from children under the age of 13, we will require the consent of their parent of guardian to do so; we do not knowingly collect information from children under the age of 13 without the consent of their parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Us section below or at data@fairphonic.com. We will delete such information from our files as soon as reasonably practicable.
17 SENSITIVE PERSONAL DATA
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data as this term is defined under applicable data protection and privacy laws (for example, Passport/NRIC/social security numbers, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to our Services.
18 CHANGES
We update this Privacy Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Data, by posting a notice on relevant areas of the Services. We will also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected.
19 CONTACT US
If you have any questions about this Privacy Policy, please feel free to contact us by as follows:
Attn:
Fairphonic Pte Ltd
6 Raffles Quay
#11-07
Singapore 048580
data@fairphonic.com