Purpose

This Privacy Policy applies to Fainin [Commercial Register Number: HRB 190710 B in Amtsgericht Berlin-Charlottenburg] (as the context requires “We”, “Our” or “Us”) in relation to Our operations in Germany. This policy explains how We handle personal information and comply with the requirements of the EU General Data Protection Regulation 2018 (the Act). This covers all of Our “Apps” “Websites,” “Products” and “Services” you “Customers” may receive pursuant these and our other “Terms”. If you have any further questions in relation to this policy, please contact Us: contact@fainin.com.
This policy relates to our collection and handling of personal information that is covered by the Act. It is not intended to cover categories of personal information that are not covered by the Act. The information is gather via number of sources including but not limited to:

  • our App;
  • our Websites (including but not limited to fainin.com, fainin.de, fainin.co.uk);
  • any social media;
  • banners, banner ads;
  • cookies from our Websites;
  • mobile or Tablet UDIDs
  • any software; and
  • any other way information is collected manually or electronically.
    By using these Products, Services, App and Website you are accepting the practices described in this Privacy Policy. These practices may be changed from time to time and any changes will be posted and changes will only apply to activities and information on a going forward basis. You are encouraged to review the Privacy Policy whenever you visit the Website or App to make sure that you understand how any personal information you provide will be used.

Why we may collect information

We may collect information including personal information and data. We are committed to safeguarding this information. Unless expressively requested we will only collect, store and process information in the following Privacy Policy. The following Privacy Policy has also been developed to adhere to best practice and standards and complies with the requirements of the EU General Data Protection Regulation 2018. Further and more detailed Terms may be expressed by us from time to time including matters of privacy. These will be communicated to you and need to be considered in light of this Privacy Policy.

Active Information Collection

Personal information may be collected through these Products, Services, App, Website actively. Active information collection includes but is not limited to:

  • posting product reviews in line with our Feedback Policy;
  • through purchase of a Product or Service;
  • complete any forms or surveys;
  • registration information through these Services or a third party login feature
    including but not limited to Facebook, Instagram, Twitter, Gmail and Linkedin;
  • Phone number verification;
  • subscribing to emails, alerts or Services;
  • previously supplied or provided information;
  • through contacting us directly; and
  • participating in any deals, offers of specials.

Passive Information Collection, IP addresses & Cookies

Per standard industry practice we may collect information about your computer, tablet or mobile device, including, where available, your IP address, operating system, geographic location, demographic data and browser type for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Our App and Website uses cookies (and your device id in case of mobile for App) to distinguish you from other Users of our App and Website. This helps us to provide you with a good experience when you browse our App and Website and also allows us to improve our Services.

The access points may be by visiting the App and Website directly; via another App or Website; or from an email sent to you from us. By accessing from any of these points you consent to the collection of such data and personal information.

Where we store your personal information

The data that we collect from you may be transferred to and stored in our Google Cloud Platform. In cases where data is stored overseas, it may also be processed by staff operating outside Germany who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of your Service, the processing of your payment details and the provision of support services.

The data and personal information collected is used and disclosed for the following primary purposes:

  • to provide the Services;
  • to respond to enquires;
  • to maintain a customer relationship;
  • to register and receive new Customers or Users;
  • to fulfil obligations in other Terms such as the Returns Policy;
  • to maintain the Website and App;
  • improve the User experience of the Website and App;
  • provide third parties with statistical (non-individual) information about our Users
    only in line with this Privacy Policy and provided that no individual users are identified;
  • for the purposes of why it was collected pursuant to this Privacy Policy;
  • to handle enquires and complaints from Customers and Users;
  • to keep the Website and App secure and assist in preventing fraud;
  • to provide updates, deals and newsletters; and
  • to improve our Products, Services, App and Website.

Uses made of the information

We use information held about you in the following ways:

  • to provide you with information, Products or Services that you request from Us or
    which We feel may interest you, where you have consented to be contacted for such purposes;
  • to ensure that content from our App and Website is presented in the most effective
    manner for you and for your computer/Tablet and mobile device;
  • to carry out Our obligations arising from any contracts entered into between you
    and Us;
  • to allow you to participate in interactive features of Our Products and Services, when
    you choose to do so; and
  • to notify you about changes to Our Products and Services.
    We may also use your data, or permit selected third parties to use your data, to provide you with information about Services and Products which may be of interest to you and we or they may contact you about these.

Information we may collect from you

We may collect and process the following data about you:

  • contact information;
  • registration information;
  • payment processing details;
  • Credit related identification information such as name, date of birth, current or
    previous address, name of current employer, drivers licence number, internet Protocol (IP) addresses and unique device identifiers (UDIDs);
  • contact preferences;
  • if registering via social media photographs of you; from all of the third-party services mentioned above and other services which integrate with our App and Website.
  • your gender and marital status;
  • sensitive information per the Sensitive Information section in this Privacy Policy;
  • personal interests;
  • details of your visits to our Website and App including, but not limited to, traffic
    data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
  • location data;
  • information about your experience with our Services;
  • product review data in line with our Feedback Policy;
  • if you contact Us, We may keep a record of that correspondence;
  • we may also ask you to complete surveys that We use for research purposes,
    although you do not have to respond to them; and
  • any other personal information requested by our Services.

ID Verification and Reviews

As part of these Services we provide to you, we may ask you to complete an ID Verification process. Users will also receive reviews and the opportunity to leave reviews for other Users and Businesses. Third party services may be integrated to verify user identities, gain user ratings, identity information and historical ratings data.

Sensitive information

Where you provide us sensitive information through these Services, App and Website we will only use the information for the purposes stated in this Privacy Policy. These may include political believes, religious believes and current personal views. We will only collect sensitive information with your consent. If we do share this information with third parties it will only be shared in line with this Privacy Policy.

Disclosure of your information

We may disclose your registration information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We do not routinely disclose personal information to other organisations unless:

  • required by law;
  • We believe it necessary to provide you with a product or Service which you have
    requested;
  • use or disclosure is permitted by this Privacy Policy;
  • to protect the rights, property or personal safety of any member of the public or one
    of our customers or in Our interests;
  • required by a third party to deliver you this Service including but not limited to
    Shipping Companies;
  • some or all of Our assets or Our operations are or may be transferred to another
    party as part of the sale of some or all of Our business; or
  • you give your consent.

We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell or trade personal information to third parties or allow such third parties to use that personal information. Third Parties such as insurance providers may also be included in our information sharing for the purposes of providing these Services and analysing insurance risks.

Protection of data

All information you provide to us is stored on our Google Cloud Platform. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of Our App and Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our App and Website. Any transmission is at your own  risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Links to Other Websites

Our App and Website, banners or ads may, from time to time, direct you to other websites, apps or social media platforms. If this occurs, we cannot and do not endorse or approve their practices and content. Other apps or websites are responsible for their own content and information collection and subject to guidance of their own Privacy Policy. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these apps or websites. This Privacy Policy does not cover other apps or websites.

Cookies related to these Services are covered with our Terms. However other apps or websites may use cookies or tracking. It is recommended you review the other websites’ or apps’ Privacy Policy in line with cookies, tracking and information storage.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise the right at any time by contacting us at contact@fainin.com.
You have the right to ask us to provide you with any personal data we hold. We will provide you with such information provided that you:

  • instruct us in writing;
  • pay a fixed fee of EUR 100.00 (including VAT); and
  • supply appropriate evidence of your identity.

We have the right to withhold such personal data to the extent permitable by applicable law.

How we collect and hold your personal information

We may collect your personal information through these Services and in accordance with this Privacy Policy or if it is otherwise lawful to do so. We may receive personal information from third parties in which case this information is also collected for the purpose of providing these Services pursuant to this Privacy Policy.

Commitment to data security

Your personal identifiable information is kept secure. Only authorised employees, agents and contractors (who have agreed to keep information secure and confidential) have access to this information. All emails and newsletters from this App and Website allow you to opt out of further mailings.

Others to view information

We may through these Services provide you the ability to post, comment or leave product reviews in line with our Feedback Policy. This information may be viewed and acted upon by others. It may be shared to other apps, websites or social media platforms. This information  may become public information on an open forum. We are no responsible for any replication or distribution of this information.

Data Retention

To meet legislation guidelines, we retain your information for as long as needed to provide you the Services. If you no longer wish to use the Services, you can cancel your Service pursuant to our Terms on our App or Website. Following a cancellation however we may need to retain some information to meet legislation guidelines that survive the agreement of these Terms.

Children information

The purposes of this Privacy Policy and all of our Services are not directed to those under the age of eighteen (18). We will not collect information on those under this age when it is known to us unless consent has been given by a parent or legal guardian.

Changing and updating information

Information collected and stored by us may be updated or changed if required. You can do this in writing by contacting us at contact@fainin.com . Furthermore, if deletion of information is required, it needs to be completed in line with our Terms and this Privacy Policy. Legislative requirements may exist that require a longer retention period of this information.

Privacy Policy Survival

This Privacy Policy survives any cancellation of these Services or sale of this business by us. Your information may be disclosed to potential buyers and may form part of the assets being sold. If this occurs the Privacy Policy remains in place.

Contact

If at any time you want to know what personal information we hold about you, you may contact us by writing to contact@fainin.com.