Privacy Policy

Summary

This Privacy Policy explains how we collect, use and share your information. It also describes how long we keep your information and how we keep it safe when we transfer it.
This Privacy Policy also lets you know your rights.
This Policy applies to what we call Fiona Products, or Products and Services. Our Products include Fiona Interactive and all related affiliates’ products.

We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

When we offer Products and Services in the European Economic Area (EEA), we are subject to the EU general Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purpose of the GDPA. We are responsible for your personal information as a “Business” under the CCPA/ CPRA.

1. Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Fiona Interactive LLC and our affiliated companies.
Privacy Policy Contact	Privacy@fionainteractive.com
Personal information	Any information relating to an identified or identifiable individual.
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information	Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status.

2. What Information do we collect?

In this policy, we list the kinds of information we collect. Here are some important ones. We collect:

The information you give us when you sign up for our Products and create a profile, like your email address or phone number.
What you do on our Products. This includes what you click on or like, your posts and photos and messages you send.
Where you post our Products and if those posts bring people back to our Products.
Who your friends and followers are and what they do on our Products.
Information from the phone, computer, or tablet you use our Products on, like what kind it is and what version of the app you are using.
Information needed to determine bots from humans on your device.
Signals from your device.
Information you’ve shared with us through device settings like GPS location, camera access, photos and metadata.
Information about the network you connect your device to and your connection, including your IP address.
Information from cookies and other similar technology.
Information from partners about things you do both on and off our Products. This could include other websites you visit, apps you use or online games you play.
Information you choose to upload from your contacts.

What information we collect depends on how you use the Products. We collect some information about you even if you don’t have an account.

Here’s the activity we collect

We call all the things you do on our Products “activity.” We collect your activity across our Products and information you provide, such as:

Content you create, like posts, comments, audio or video.
Content you provide through our camera feature or your camera roll settings, or through our voice enabled features.
Messages you send and receive, including their content, subject to applicable law. We can’t see the content of end to end encrypted messages unless users report them to us for review.
Metadata about content and messages, subject to applicable law.
Types of content, including ads, you view or interact with, and how you interact with it.
Apps and features you use, and what actions you take in them.
Purchases or other transactions you make, such as through Fiona checkout experiences, including credit card information.
Transfer of funds or credits.
Credit or debit card number and other card information.
Billing and shipping contact.
Purchase history.
Hashtags you use.
The time, frequency and duration of your activities on our Products.

Partners also share information like your email address, cookies, and advertising device ID with us. This helps us match your activities with your account if you have one.

We receive this information whether or not you’re logged in or have an account on our Products.

3. How Your Personal Information is Collected

We collect personal information from the following categories of sources:

You, directly in person, by telephone, text, or email and/or via our website and apps
Third party with your consent (e.g., your bank)
Advertising networks
Internet service providers
Data analytics providers
Government entities
Operating systems and platforms
Social networks
Data brokers
Publicly accessible sources (e.g., property records)
Cookies on our website
Our IT and security systems, including:

Door entry systems and reception logs
Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems

4. How and Why We Use Your Personal Information

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

Personalize your experience
Improve Products by applying information about what you use them to do an what else is happening when your device or apps crash
To prevent harmful behavior on our Products
If you allow us, to send you messages about the Products you use or ones you might like to use
Research to advance technology or to help in a crisis
To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party –or–
Where you have given consent

We use this information across devices. The information we use for these purposes is automatically processed by our systems. In some cases, we may also use manual review to access and review your information.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide Products and/ or services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Fiona Interactive	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: - Existing and former customers - Third parties who have previously expressed an interest in our services - Third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

[For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.]

5. EEA Data Subjects: Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone, or post) about our Products and services, including exclusive offers, promotions or new Products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside the Fiona Interactive and affiliates for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at support@fionainteractive.com
Using the “unsubscribe” link in emails or “STOP” number in texts or
Updating your marketing preferences within your account settings

We may ask you to confirm or update your marketing preferences if you instruct us to provide further Products and Services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With

We routinely share personal information with:

Our affiliates, including companies within the Fiona Interactive group
Service providers we use to help deliver our Products and Services to you, such as payment service providers, warehouses, and delivery companies
Other third parties we use to help run our business, such as marketing agencies or website hosts
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
Credit reporting agencies
Our insurers and brokers
Our bank[s]
Or as required by law

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing Products and Services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf
To show that we treated you fairly –or–
To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

8. California Consumers: Your Rights Under the CCPA/CPRA

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosures of Personal Information We Collect About You

You have the right to know, and request disclosure of:

The categories of personal information we have collected about you, including sensitive personal information
The categories of sources from which the personal information is collected
The categories of third parties to whom we disclose personal information, if any –and–
The specific pieces of personal information we have collected about you

Please note that we are not required to:

Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
Provide the personal information to you more than twice in a 12-month period

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal Information link here: https://www.fionainteractive.com

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–
As authorized by further regulations

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

To limit the use of your sensitive personal information, visit our homepage and click on the "Limit the Use of My Sensitive Personal Information" link here: https://www.fionainteractive.com

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