Privacy Policy

Updated 13 June 2020

Your privacy

This Privacy Policy describes how we collect, use and share your Personal Data and tells You about your privacy rights and how the law protects You.

You can navigate to different parts of this Privacy Policy using the links below.

 

Definitions

Definitions

For the purposes of this Privacy Policy:

  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
  • Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to us as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • Facebook Fan Page is a public profile named fual.io specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/fualio-103585181369012/
  • GDPR means the General Data Protection Regulation (EU 2016/679) and any replacement legislation that comes into force in the UK following Brexit.
  • Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

  • Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes your personal information on our behalf. It refers to third-party companies or contractors employed by us to facilitate the Service, to provide the Service on our behalf, to perform services related to the Service or to assist Us in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • We (also referred to as Us) means Fual Communications Ltd, 35 Ballards Lane, London. N3 1XW

For the purpose of the GDPR, We are the Controller of your Personal Data.

  • Website refers to fual.io, accessible from https://fual.io
  • You means the individual whose personal data we are collecting and processing. This includes individuals who are accessing or using one of our Services, individuals who contact us with a query and contacts at organisations that we work with.

 

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data is information that we receive from your device and includes information such as your Device's Internet Protocol address (IP address), browser type, browser version, the pages of our Service that You visit, the time and date of your visit, the time spent on those pages and unique device identifiers

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other information about your device and how you navigated to our Service.

We may also collect information that your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. This includes information such as screen resolution and extensions that you have installed.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

Use of your Personal Data and lawful basis for processing

We may use Personal Data for the purposes set out below. In each case, we indicate the Personal Data that is used and the legal basis that permits us to use your Personal Data for this purpose under GDPR.  

If it is necessary to process Personal Data for the purposes of an agreement we have with You or if we have a legal obligation to process your Personal Data this is indicated below.

Purpose

Data

Legal basis

To provide and maintain our Service

Email address and IP address

Contractual necessity.

 

If you do not provide this Personal Data we cannot provide the Service to you.

To register your interest in our Services, including to send You updates about when new products and features are available.

Email address

We have a legitimate interest in collecting information about people who are interested in our Service and informing them of developments

To develop and improve our Service, including to monitor the usage of our Service, to analyse how our Service is being used, how Users are interacting with the Service and to carry out surveys.

Usage Data and email address

We have a legitimate interest in improving our Service and developing new products and features

To contact You: To contact You by email or via social media (if you have contacted us via social media).

Email address, social media avatar and Personal Data contained in queries you submit to us

We have a legitimate interest in responding to enquiries about our Services and our business and to contact people in relation to business matters

To send You marketing communications by email with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already enquired about unless You have opted not to receive such information.

Email address and information about your preferences

We have a legitimate interest in sending out marketing materials related to our business

To deliver targeted advertising to you on third party platforms such as Facebook

Email address, Usage Data

We have a legitimate interest to display advertisements to promote our Services

To manage marketing preferences

Details of marketing preferences, including consents to marketing and opt-out requests.

Legal obligation

Sharing of your Personal Data

We may share your Personal Data in the following situations:

  • With Service Providers: We may share your Personal Data with Service Providers who provide us with services to enable us to run our business, such as data hosting services, mailing services and analytics services.
  • With advertising partners: We may share your Personal Data with advertising partners to advertise on third party websites to You after You visited our Service.
  • For Business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
  • With affiliates: We may share your information with our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

Retention of your Personal Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. This includes retaining and using your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, defend legal claims and enforce our legal rights.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or We are legally required to retain this data for longer time periods.

Transfer of your Personal Data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place to ensure the security of your Personal Data.

If it is not possible to put in place one of these mechanisms, we will only transfer your Personal Data outside the UK or the EEA if we are permitted to do so under the General Data Protection Regulation.

Disclosure of your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, We may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend our rights or property
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of your Personal Data

The security of your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to your Personal Data only to perform their tasks on our behalf and we require that they do not disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service. We use Google Analytics and Mixpanel Inc for these purposes and they use cookies to track your use of our Service. You can find out more about Google Analytics and Mixpanel and manage your preferences in relation to analytics cookies by visiting our Cookies Policy

Email Marketing

We may use your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Mailchimp to manage and send emails to You.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Behavioral Remarketing

We use remarketing services to advertise on third party websites to You after You visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service. You can find out more about the cookies that we use to enable remarketing and how you can manage your preferences in our Cookie Policy.

 

GDPR Privacy

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee You can exercise your rights.

You have the right to:

  • Request access to your Personal Data. This enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes You want to object to our processing of your Personal Data on this ground. You also have the right to object where We are processing your Personal Data for direct marketing purposes.
  • Request erasure of your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw your consent. Where we rely on your consent to process your Personal Data, You have the right to withdraw your consent at any time. If You withdraw your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting Us at hello@fual.io. Please note that we may ask You to verify your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

Right to complain

If you are not happy about how We are processing and using your Personal Data, please get in touch via email hello@fual.io so that we can try to resolve the issue.

If you are still not happy, You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. In the UK, you can contact the Information Commissioner’s Office (ico.org.uk). If you are in another country in the European Economic Area (EEA), You can also contact your local data protection authority.

Facebook Fan Page

Data Controller for the Facebook Fan Page

We are the Controller of your Personal Data collected while using the Service. As operator of the Facebook Fan Page (https://www.facebook.com/fualio-103585181369012/), the Company and the operator of the social network Facebook are Joint Controllers.

We have entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php.

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal Data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page, in order to obtain anonymized statistical data about our Users.

For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
  • The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell your Personal Data to third parties.
  • The right to know about your Personal Data. You have the right to request and obtain from Us information regarding the disclosure of the following:
  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the Personal Data
  • Categories of third parties with whom We share Personal Data
  • The specific pieces of Personal Data we collected about You
  • The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer's rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, You can email or call us using the details below.  

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by changing your preferences in our Cookie Policy. The opt out will place a cookie on your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If You are visiting such websites, You can set your preferences in your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from our servers.

Your California Privacy Rights (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to any material changes becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By email: hello@fual.io
  • By phone: +44 141 628 7234 or +1 313 483 7533