PRIVACY POLICY

1.0       BACKGROUND:

1.1       This Privacy Policy (“Privacy Policy”) describes how FanzFirst Limited (“the Company”, “the Website”, “the App”, “we” or “us”) gathers and uses personal information submitted on our websites and associated Apps (“the Website”).  We understand that your privacy is important to you and that you care about how your information is used and shared.

1.2       We respect and value the privacy of everyone who visits the Website and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.  This Privacy Policy is intended to inform you about how we gather, store and use your Data and under what circumstances we will disclose that information to any third parties.

1.3       Your acceptance of the Privacy Policy is deemed to occur upon your first use of the Website.  If you do not accept and agree with the Privacy Policy, you must stop using the Website immediately.

1.4       We may use information gathered about users to offer and improve our products and services or as otherwise described in this Privacy Policy.  We will wherever possible aggregate and anonymize information received.

1.5       We are the sole owner of information collected on the Website (if any).  We will never sell or rent Data to anyone else without your permission and will never use your Data for any purpose other than as described here.  We do not take credit card information and we do not take your money.  We search the globe to partner with the most reputable and recognisable global brands (“Partners”) and negotiate discounts from them on your behalf.  We refer you to our Partner’s website to avail of these offers by way of hyperlinks on the Website to their websites.  We may share some information with these carefully selected Partners and they in turn my share some of your information with us but we aim to avoid ever collecting or sharing Data where possible.

1.6       Payment information that you provide to our Partners, including credit card data is never exchanged with us.

IF YOU DO NOT AGREE TO BE SUBJECT TO THE PRIVACY POLICY PLEASE DO NOT USE THE WEBSITE.

Definitions and Interpretation

In this Privacy Policy the definitions in our Terms and Conditions of Use [LINK] shall apply.  The following terms shall have the following meanings:

“Account” means an account required to access and / or use certain areas and features of the Website or the App;
“Cookie” means a small text file placed on your computer or device by us when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies used by Our Site are set out  below;
“EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;

2.0       What Does this Privacy Policy Cover:

2.1       This Privacy Policy applies only to your use of the Website.  It does not extend to any websites or apps that are linked to from the Website (whether we provide those links or whether they are shared by other users).  We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

3.0       What Do We Collect:

3.1       Personal information is any information that identifies you or which would enable someone to identify you (“Data”).  This may include your name, email address, phone number and other non-public information.  It does not include aggregated information, anonymous information or any other non-personally identifiable information.  For the doubt we aim to avoid collecting Data wherever possible and where Data is collected we will try to aggregate or anonymise it and will comply with this Policy and the Terms in our handling of it.

3.2       Generally, information is collected when you download and register on our App, from your purchase of goods and / or services from our Partners, when you email or call us, and when you use the Website, App and any of our or Partner’s social media accounts.  This is not always Data as in many cases this information is anonymised and cannot be linked specifically back to you.  By providing personal data, you are telling us that this information is both true and accurate, and that you are authorized to provide it to us.

3.3       Some information will be collected automatically by the Website (for further details, please see below our use of Cookies and our Cookie Policy), other data and in particular personal data will only be collected if you voluntarily submit it.  We may collect information about the browser you’re using and your IP address (this is a number that identifies a specific network device on the internet and is required for your device to communicate with websites).  We might look at what website you came to us from, what you did and didn’t use the Website for, or what website you visit when you leave us.  Once again this information is likely to be aggregated and anonymised.

3.4       If you use the App, we may collect your GPS location or your device’s unique identifier.  We might also collect the type of device you are using, or the version of the operating system your computer or device is running.  We will hold contact information you provide to us or which has been provided to us by Facebook or Google when registering on the App (e.g. name, address, phone number, email, country of residence, preferred language).

3.5       In relation to emails we send you (if any), we may collect information on how you respond to such emails, for example, the number of times the email is opened or the links in them that are clicked.

3.6       We may also gather and store other information about your interactions with us.  For example, if you interact with us via email, telephone or social media (e.g. Facebook) we may record this.

3.7       We may hold information you post on the Website or on a third-party social media sites to which we have access.  When you post information online, you must not infringe the rights of others (including privacy rights) and you should be aware that others may use, tag and/or re-publish your information in ways that you might not expect (including in ways that are unlawful).  You understand that we and others (including our Suppliers and Partners) may use and re-publish any data you post online publicly, on the Website or when using apps or social media tools.

3.8       We may hold information about you provided to us by other companies for example by our Partners or Suppliers.  We may also add information to your details which we have obtained from other companies or sources (if any).  For example, we may add demographic information.  Much of this data is created using publicly available sources or is derived from market research such as consumer panel surveys.

4.0       How do we collect your information:

4.1       We collect your information in a number of ways;

4.1.1    Directly from you when you use the Website or download the App, email us directly or interact with our social media accounts or call us by phone.

4.1.2    You may view and use the Website and the App via a computer, phone, tablet or other device.  We use tracking tools like browser cookies on the Website (specifically Google Analytics and Statcounter) to collect information about your usage.  To learn more, please see our Cookies Policy .

4.1.3    If you choose to visit one of our Partners’ sites and purchase anything from them our Partners will give us certain information about you.  This information will be anonymised so we will not know that it relates to you but it will inform us of your transactions so that we can earn a commission on your activities on a Partners’ sites.  This also allows us secure discounts for you and our other Users.

5.0       How Do We Use Your Data:

5.1       Information that we gather is used to administer the Website and provide general statistics regarding your use of the Website.  Once you register with us on the App, you are no longer anonymous to us.  We may use this information to offer and improve our products and services, to provide you with requested information or technical support, to facilitate your movement through the Website and our Partners’ sites or your use of our products and services, to do a better job of marketing products and services which may be of interest to you, to diagnose problems with our servers or our products and services, in connection with our security and compliance programs, to administer the Website, to communicate with you, to target prospective customers with products or services, to assist us in offering you a personalized experience or otherwise tailor the Website, product and service offerings to you, or as otherwise described in this Privacy Policy.

5.2       We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

5.3       With your permission and / or where permitted by law, we may also use your information for marketing purposes which may include contacting you by email, telephone, text message and / or ordinary post with information, news and offers on products and services.  We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Irish Data Protection Act 1988 as amended and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015 as well as the GDPR.

6.0       Disclosure of Information we Collect.

6.1       We utilise third parties to supply services to us (“Suppliers”).  We aim to continually improve the standard and quality of service you receive from us and our Partners and the effectiveness of the Website.  Suppliers provide services which may include web services, business analysis, search engine facilities, advertising and marketing.  In some cases, our Suppliers may require access to some or all of our data.  Where any Data is required for such a purpose, we will take all reasonable steps to ensure that Data will be handled safely, securely, and in accordance with your rights, our obligations, and our Supplier’s obligations under the law.

6.2       We may compile statistics about Website traffic, usage patterns, user numbers, sales and other similar information.  All such data will be anonymised and will not include any personally identifying information about you.  We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers.  This data will only be shared and used within the bounds of the law and this Privacy Policy.

6.3       In certain circumstances, we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority.  We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.

6.4       Our offering by its very nature, requires data to flow between us and our Partners and Suppliers and back again.  In certain limited circumstances that will require Data to flow from the European Union (EU) to the United States (U.S.) (or other non-EU countries including India) and back.  To ensure that EU personal data is adequately protected when transferred outside the EU, the Data Protection Directive 95/46/EC and, as of May 25, 2018, the General Data Protection Regulation mandate that such transfers take place using certain legal mechanisms.  We will comply with all relevant legal requirements when transferring your data abroad.  We will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers outside of the EU.  These clauses are contractual commitments between companies transferring personal data (for example, between us and our suppliers and partners), binding them to protect the privacy and security of the data.  We will adopt Standard Contractual Clauses so that the data flows necessary to provide, maintain, and develop our services take place legally.

6.5       We are the sole owner of information collected on the Website.  We collect information only as necessary to fulfil the purposes set out and as described in this Privacy Policy.

6.6       We will wherever possible aggregate and anonymize information received to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, the Website, our Partners’ sites or evaluated or purchased products and services.

6.7       We may disclose your aggregated usage information to others, in a form that does not identify you individually.  We may disclose to third parties, including Partners and Suppliers but also potential business partners, aggregated statistics that we develop from usage habits, preferences, and transaction histories.  This statistical information will not identify you or any individual.

6.8       We may share some of your information with our Partners so that you can benefit from discounts and special offers we have negotiated with them on your behalf and so that they can, analyse customer behaviour, provide a better service and support, so that they can process and fulfil orders and for any other purpose described in our Partners’ privacy policies. You should read those policies on our Partner’s website to learn how they treat your information.  We have no control over the further use of your information or the sharing of such information by our Partners.  Once again, we strongly recommend that you carefully review the privacy policy of any of our Partners with whom you choose to do business, as well as any third-party payment agent who transacts your business.

6.9       We may share your information with our Suppliers so that they can provide services to us (e.g. maintenance, analysis, audit, payments, fraud detection, marketing and development hosting and webservices, mailing house, call-centre services, market research), but where we do we will put in place a written agreement protecting your information.  These Suppliers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.  Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.

7.0       Third Party Links

7.1       The main purpose of the Website is to provide links to our Partners’ websites.  Our Partners provide us with trackable links which are added to their logos, text and banners on the Website.  Clicking on these allows you to exit the Website and be redirected to the target pages on our Partner’s websites.  If a purchase is made by you on foot of clicking such a link, you are likely to be asked to submit personal information to any of these Partners.  Because we do not control the information policies or practices of our Partners, you should review their privacy policies to learn about how they collect and use personal information.  We try to only work with responsible Partners, Suppliers and other third parties.  Their business policies may include different privacy policies and practices than we have.  Please be aware that when you click through to third-party websites, our privacy policies no longer apply and that we are not responsible for the privacy practices of these other sites.  THIS PRIVACY POLICY DOES NOT APPLY TO THIRD PARTY WEBSITES

7.2       If you do transact with one of our Partners some of this information may be relayed back to us via one of our Suppliers.  In those circumstances the Supplier will securely sends us details of each transaction via an API but without specifically identifying you as the individual who made a purchase.

8.0       Payment and Paying Agents:

8.1       We not perform any role in the purchase transaction between you and any of our Partners save that we have tried to ensure that you get a discount from our Partners.  We do not ask for or receive your credit card details.

8.2       When you purchase something from one of our Partners, depending on the payment method you choose, you may be transferred to the website of a third party payment agent.  As noted above, this policy does not apply to any third party websites.  As such, you should read the privacy policy associated with any third party’s website to understand what information about you it collects and how such information is used by them and for what purposes.

9.0       Legal Requirements:

9.1       We may disclose any and all information collected if, in good faith, we believe we are required to do so to comply with any local, state, federal or foreign law, to respond to a court order, any court or governmental subpoena (or its equivalent), or any domestic or foreign governmental investigation.  We also reserve the right to disclose information collected that we believe, in reasonable good faith, is appropriate or necessary to protect against any liability; to protect Fans from fraudulent, abusive or unlawful uses; to investigate and defend ourselves against any third party claims or allegations of wrongdoing; to assist domestic or foreign government enforcement agencies; to protect against fraudulent uses the rights, property (including intellectual property) or safety of the Company, its Fans, Partners, Suppliers, Processors, users of the Website or other persons or entities.

10.0     Security and Storage:

10.1     The security of your personal information is important to us.  Data is stored securely in accordance with best practice and the principles of Irish and EU Privacy and Data Protection legislation.  Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through the Website.  Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to us via the internet.

10.2     We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it.  However, no method of transmission over the internet, or method of electronic storage is one hundred percent secure and we cannot guarantee its absolute security.  We employ reasonable technical, administrative and physical safeguards to protect the confidentiality and security of your personal information.  We use industry-recognized technical safeguards, such as firewalls, and have adopted and implemented security procedures to protect your information from loss, misuse or unauthorized alteration.

10.3     We encrypt the transmission of any your information that we hold using secure socket layer technology (SSL).  Given the instability of the Internet and the World Wide Web, we make no representations or warranties as to the effectiveness of our security and assume no liability for security breaches or any failure in the security of your computer equipment, your internet service provider or other networks and communications providers.

10.4     We are headquartered in the Republic of Ireland however we utilise servers in a number of different jurisdictions.  Personal information may be accessed by us or transferred by us within the European Union or to our Partners or Suppliers elsewhere in the world.  By providing us with personal information, you consent to this transfer.  We will protect the privacy and security of personal information according to this privacy statement, regardless of where it is processed or stored, however you explicitly acknowledge and consent to the fact that personal information stored or processed in Ireland will be subject to the laws of Ireland.

10.5     In particular we currently utilise the services of the Amazon Web Service and your information is hosted on an Amazon AWS database at a secure data centre in Ireland.  You will find more information on Amazon AWS’ security compliance here – https://aws.amazon.com/compliance/

10.6     Some of our Partners and Suppliers are based outside of the EU.  The transfer of your information for use in line with this Privacy Policy may involve the transfer of your information to other countries (including outside Europe).  The laws of other countries to which your information is transferred may not provide the same level of protection for your personal information as the law of your home country.  We do, however, put in place appropriate technical and contractual protections for your personal information in accordance with applicable laws.  Any transfer of your Data will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.  Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements.

11.0     Change of Ownership:

11.1     We may, from time to time, expand or reduce our business and this may involve the sale and / or the transfer of control of all or part of our business.  Data provided by you will, where it is relevant to any part of our business transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally collected by us.

11.2     In the event that the Company is acquired by, merged with or into, or substantially all of its assets are sold to, a third-party entity, the Company reserves the right to transfer or assign the information it has collected from you as part of such acquisition, merger or sale.  We do not sell your personally identifiable information to third-parties.

12.0     Opting-out:

12.1     We will only use your information for the purposes described in this Privacy Policy.  To use all features and functionality available on the Website you are required to submit or allow for the collection of certain data.  You may restrict your internet browser’s use of Cookies however this will affect your experience with us and your ability to use the Website.  For more information, see our Cookie Policy.

If you do not want your information used as set out in this Policy DO NOT USE the Website or register with us.

12.2     You will always have the opportunity to opt-out of our marketing communications or to change preferences by following a link in the footer of non-transactional email messages sent by us (if any) or by emailing us at privacy@fanzfirst.com.

12.3     If an account or profile was created without your knowledge or authorization, please contact us at privacy@fanzfirst.com to request removal of the account or profile.

12.4     When you opt-out of promotional communications from us, you may still receive service messages and legally mandated notices and third-party marketing messages.  Please note that, even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users.

13.0     Accessing Data:

13.1     You have a legal right to obtain a copy of any of your Data held by us (where such data is held) on payment of a small fee in compliance with the Data Protection Acts 1988 as amended and / or the General Data Protection Regulations (“GDPR”) when they become effective.

13.2     For the purposes of European Directive 95/46/EC and applicable national implementing laws in your jurisdiction, with respect to your data, we are a data controller and with respect to our Partners’ information, we are a data processor.

13.3     We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access it and make corrections to it.

13.4     We will retain and use your information for as long as your account is active or as needed to provide you with services, as necessary to comply with our obligations under this privacy statement and at law, resolve disputes, enforce our agreements and for backup purposes.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

14.0     Contacting Us:

14.1     For questions regarding this Privacy Policy, your personal information, our third-party disclosure practices or your consent choices, or if you believe that we have not complied with this Privacy Policy, or if you have any other complaint or concern with regard to your Data please contact us at privacy@fanzfirst.com or by post at:

FanzFirst Limited
The Jack Doyle Suite
Lawlors Hotel
Naas
Co. Kildare
Ireland

14.2     We will review your communication promptly and respond to you upon completion of this review.

15.0     Changes:

15.1     We may change this Privacy Policy as we deem necessary from time to time, or as may be required by law.  Any changes will be immediately posted on the Website and you will be deemed to have accepted the terms of the updated Privacy Policy on your first use of the Website following such alterations.  We recommend that you check this page regularly to keep up-to-date so you are always aware of what information we collect, how we use it and under what circumstances we disclose it.

15.2     If you object to any of the changes, please do not continue to use the Website.  You can also request that we delete your information from our database by contacting privacy@fanzfirst.com.

16.0     Children and Privacy:

16.1     The Website is not designed and intended for use by Minors (persons under the age of 18).  We do not knowingly collect personal information from children.  If you are a parent or legal guardian and think a Minor has given us information, you can contact us on privacy@fanzfirst.com.  If we become aware that a Minor has provided us with personal information, we will delete such information from our files.

16.2     It is possible that some Partners presented on the Website may offer products or services intended for Minors as well as adults, it is our expectation that adults will purchase from those Partners on behalf of Minors.

Last Updated:

17th August 2017

Cookies

1.0       Tracking Technologies – What Cookies Do We Use and What For?

1.1       When you access the Website, a small file called a “Cookie” is placed on your hard drive  (or other electronic device).  Your browser will store these cookies on your computer in a small text file, and if you return to the Website the cookie may be read. No personal information is stored within these Cookies and we have taken steps to ensure that your privacy is protected and respected at all times.

1.2       If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this Privacy Policy.  If you change your mind in the future about letting us use cookies, you can modify the settings of your browser to reject cookies or disable cookies completely.  You can control and limit your data used in this way by adjusting your web browser’s privacy settings.  There is also a notice on our home page which describes how we use cookies and which also provides a link to our Privacy Policy.  If you agree to this notice and use the Website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this Privacy Policy and our Terms and Conditions of Use of the Website.  If you do not agree to this notice, please do not continue to use the Website.  Certain features of the Website depend on Cookies to function.  EU Cookie Law deems these Cookies to be “strictly necessary”.

1.3       Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use the Website.  This, in turn, enables us to improve the Website and the products and services offered through it.  You do not have to allow us to use these Cookies however whilst our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable us to continually improve the Website, making it a better and more useful experience for you.  The analytics service in particular used by us uses Cookies to gather the required information.

1.4       We use cookies and other online tracking devices on the Website for:

  • analyzing trends;
  • administering and improving the Website;
  • tracking users’ movements around the Website and our Partners’ sites (including point of entry) and obtaining information about your preferences, online movements and use of the internet;
  • gathering demographic information about our users;
  • verifying login status or recognising you whenever you visit this website (this speeds up your access to the Website as you do not have to log in each time) and distinguishing unique users and providing essential security measures;
  • measuring the success of a particular marketing campaign;
  • providing more relevant content;
  • deterring or detecting fraud;
  • providing users with a customized experience, negotiating better discounts on your behalf;
  • target our marketing campaigns and those of our partners more effectively;
  • identifying and recording the number and time of previous visits, traffic source information and the value of visitor-level custom variables;
  • determining the start and end of a session; and
  • making your online experience more efficient and enjoyable by facilitating the quicker loading and distribution of Content.

1.5       First party Cookies are those placed directly by us and are used only by us.  By using the Website you may also receive certain third party Cookies on your computer or device.  Third party Cookies are those placed by websites, services, and/or parties other than us.  Some of these Cookies may be placed immediately when you first visit the Website and it may not be possible for us to obtain your prior consent in relation to these.  You may remove these Cookies and prevent future use of them by enabling or disabling Cookies in your internet browser.  Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies.  By default, most internet browsers accept Cookies but this can be changed.  For further details, please consult the help menu in your internet browser or the documentation that came with your device.

1.6       Please note, we do not control the activities of Suppliers or Partners, nor the information they collect and use.

1.7       All Cookies used by and on the Website are used in accordance with current Irish and EU Law.  It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.  For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.

1.8       The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer (or other electronic device) such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

1.9       We may also use electronic images known as “web beacons” (or “clear GIFs”) that allow us to track general user traffic patterns.  We also automatically receive and record information from our servers and from your browser, including your IP address, the time, and information about any page you requested and viewed.  We may also include web beacons in promotional or other e-mails or e-newsletters to determine whether Fans have acted upon particular messages.  The information obtained in this manner enables us to customize the services we offer our Fans, to deliver targeted promotions and to measure the effectiveness of our marketing activities.    Data collected through this mechanism is not linked to personal information.

1.10     Additionally, if you visit the website of one or more of our Partners, they may place their own cookies on your computer.  This third party cookie may transfer information to the third party in order for them to track your activity when you visit their websites and on other websites not controlled by us for the purposes of serving you advertising on topics in which you have a demonstrated interest.  Please note that we can only access cookies that we set on your computer, not the cookies sent to you by other companies including our Partners.  Also, when you leave the Website, whether by clicking on third party links, sponsored content or advertising or directly accessing a third party’s website, these third parties may place Cookies or web beacons on your computer.

2.0       Description of cookies

2.1       The table below provides more information about the cookies we use and why:

Name of cookie Owner Purpose for the cookie
Google Analytics Google This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (eg how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.  The information being tracked cannot be linked back to any individual.
StatCounter StatCounter This is a web analytics service which also uses cookies to show us how visitors found and explored our site.  It also provides us with information about the behaviour of our visitors.  StatCounter is used by over 2,500,000 million bloggers, web designers, marketing and SEO professionals and small business owners around the world. The information being tracked cannot be linked back to any individual.

3.0       Contact Details

3.1       If you have any queries about how we use Cookies on the Website please contact us either by email on privacy@fanzfirst.ie or to;

FanzFirst,
The Jack Doyle Suite;
Lawlor’s Hotel,
Naas,
Co. Kildare,
Ireland.

Last Update

14th August 2017