(Last Updated April 23, 2021)
This policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By continuing to visit our website www.frientoru.com and other Frientoru services, you accept and consent to the practices described in this policy.
2. Information Collection
When you interact with the Site or its Services, Frientoru may collect Personal Data and other information from you, as further described below-
3. Personal Data you provide to us
4. Background checks
When you register as a user, we may use a third-party service to perform a background check on you with your consent. We do not receive information from the background check other than an indicator of whether you meet our requirements or not.
5. Non-Identifiable or Aggregated Data
When you interact with Frientoru and users through our website App or Services, we receive and store certain personal non-identifiable information. This information is collected passively and cannot presently be used to specifically identify you as a person. We may store such information or such information may be included in information databases that are owned and maintained by Frientoru, its affiliates, agents or service providers. We also use "cookies" to collect personal non-identifiable information, such as your IP address, browser type, domain name, and the Frientoru website pages that you visit. More information concerning cookies is provided below-
7. Mentors & mentees
In order to use Frientoru, Mentees must create a user-name and fill out a registration page that includes their first name, last name and email address in order to be able to use the service. Frientoru may ask Mentees to complete a profile page as well as a range of activities where limited personally identifiable and non-identifiable information may be requested. Personally identifiable information collected in these areas is used only for internal monitoring and reporting purposes. Frientoru does allow, share and display Mentee and Mentor usernames and first names within the Frientoru program.
Mentees and Mentors may also have the ability to email, chat or write posts in other spaces that are within the password protected, monitored and secure Frientoru site and can be viewed by other Frientoru users. The users’ user name, first name and profile information are visible with the information they post.
8. GDPR Data Protection Procedure
By using Frientoru, you agree to the collection, transfer, storage and use of your personal information by Frientoru on servers located in Hong Kong, China as further described in our Privacy Notice. You and Frientoru shall process personal data received under and/or in connection with this User Agreement each as a separate and independent controller. In no event will Frientoru and you process personal data under and/or in connection with this User Agreement as joint controllers or in a controller-to-processor relationship. As such separate and independent controllers, you shall be individually and separately responsible for complying with the obligations that apply to you as a controller under applicable data protection law.
You shall comply with your obligations under applicable data protection law (including but not limited to the Regulation (EU) 2016/679 (EU General Data Protection Regulation “GDPR”)) and supplementing EU and local data protection law. This includes, but is not limited to the obligation to provide appropriate safeguards for the transfer of personal data to a third country or an international organization. You shall process personal data received from Frientoru exclusively for the purpose(s) you received the personal data under and/or in connection with this User Agreement. You shall erase the personal data received under this User Agreement immediately after the respective purpose(s) has/have been fulfilled. Any further processing of the personal data is not permitted except when legally required (e.g., if a retention obligation applies).
Failure to abide with the aforementioned obligations may result in disciplinary action up to and including account suspension.
9. Advertising Networks
From time to time, we may use one or more third-party online advertising networks to serve ads on our behalf, onto the Internet. Said third-party network may collect anonymous information about your visits to our website and record your interaction with our ads. This accomplished with features such as cookies, action tags, web beacons, and/or GIF tags located within Frientoru. Occasionally, we may share anonymous information with third-party networks, in an aggregate form, to help us analyse and improve our website for future use. These third-party networks may also use information about your visit to our website and other websites in order to provide ads about goods and services that may strike your interest.
10. Marketing information:
If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an email from us or ceased using our materials. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
11. Children Under Age
Frientoru is directed to adults and does not knowingly collect personal from children under the age of 13. If you are a child under the age of 13, you must have your parent's or guardian's consent, and provide said consent to Frientoru. If you are the parent or guardian of child under the age of 18 and you believe your child has provided personal information Frientoru, please email us at firstname.lastname@example.org
12. Children’s online privacy protection act
We comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). COPPA requires that web site operators never knowingly request personally identifiable information from anyone under the age of 13 without requesting verifiable parental consent.
In accordance with COPPA, we do not knowingly collect any personally identifiable information from children under the age of 13. We recommend that no one under the age of 15 submit personally identifiable information to our Site. In the event that we determine that a user of this Site is under the age of 13, we will not maintain or use his or her personally identifiable information.
13. Information Use
The information we collect on Frientoru may be used to fulfil your requests or communicate special offers and other Frientoru promotions to you. When you contact us, we give you the opportunity to receive notifications about special offers and other Frientoru promotions.
14. Information Disclosure
15. Information Sharing
We may share the information collected on Frientoru website with agents or contractors who provide support for Frientoru's internal operations. Said parties may receive personally identifiable information- as such is needed to perform their duties. Please be assured that said parties may not use the information for any other purpose. If you do not want us to share such information, please email us at email@example.com
16. Where we store your information
Frientoru has a data privacy officer who is responsible for ensuring that your personal information is collected, used, disclosed (shared) and retained in compliance with applicable privacy regulations.
However, the data that we collect from you may be transferred to, and stored at, a destination outside the European economic area ("EEA") that may not be subject to equivalent data protection law.
17. Securing Personal Data
Frientoru takes reasonable steps to protect Personal Data via the Site from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. But unfortunately, no electronic transmission of information via the internet is ever fully secure- carefully decide whether you want to send us information electronically before actually doing so.
18. Your Rights as A Data Subject
In some jurisdictions (for example, the member states of the European Union) you may be entitled to certain rights in and to your personal data, subject to certain conditions and exceptions contained in applicable law. These rights may include the following:
· Request us to confirm whether your personal data is processed by us, and if we do, to obtain access to your personal data and certain information about it.
· Require the correction of your personal data if it is inaccurate or incomplete.
· Direct us to stop processing your personal data under certain circumstances.
· Erase or delete your personal data, for example, where the data is no longer needed to achieve the purpose for which it was collected.
· Restrict the further processing of personal data
· Request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (we currently do not engage in such processing and will notify you prior to doing so).
· Request to receive your personal data for transmission to, or to directly transmit to, another data controller in a structured, commonly-used and machine-readable format.
To protect your privacy and the security of your personal data, we will take reasonable steps to verify your identity before complying with such rights requests.
19. Privacy shield
20. Legal bases for processing EEA users Data
If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services;
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or
We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g., your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services
21. Your right to withdraw consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can exercise the rights listed above at any time by contacting us. If your request or concern is not satisfactorily resolved by us, you may contact our data protection officer, via email firstname.lastname@example.org.
He can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
22. Opting out of messages from us
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at email@example.com. We will process your request within a reasonable time after receipt.
23. Opting out of interest-based advertising
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. We comply with the Self-Regulatory Principles for Online Behavioural Advertising set forth by the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance ("EDAA"). You can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities.
24. Data portability
Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces you under your sole control, like your personal bitbucket repository.
25. Additional EU Disclosures
If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to address your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you are situated in the EU and have a complaint, please contact our privacy team
26. Provision of Personal Data and failure to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you
27. How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
28. Complaint to a Data Protection Authority
You have the right to submit a complaint concerning our data processing activities to our data protection officer
29. Complaints or Queries
If you have any queries regarding our data collection and protection practices or your rights, please do not hesitate to contact us, at firstname.lastname@example.org