PRIVACY POLICY

 

Who are we?

We are Global E Shop Solutions Limited (“GESS”) incorporated in Ireland under registration number 604530 and having our registered office at The Jack Doyle Suite, Lawlors Hotel, Naas, Co. Kildare.

We create bespoke website platforms and online Apps tailored to the requirements of our Influencers.

This notice 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 practices regarding your personal data and how we will treat it.

We use certain expressions throughout this document such as Personal data. This means any information relating relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession. It includes any information that can identify you e.g. your name, address, phone number etc;

When dealing with Influencers data, FanzFirst will be a data controller. When dealing with Customer data, FanzFirst will be a data processor.

Our data protection representative may be contacted at privacy@fanzfirst.com

 

What PERSONAL information do we collect from you?

You may give us personal data by:

Corresponding with us

  • When you contact us by phone, e-mail, social media or otherwise, we ask you to disclose only as much information as is necessary to provide you with our product or to submit a question/suggestion/comment in relation to fanzfirst.com, www.moshoppa.com (our Websites), our mobile apps or our products/services. 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. 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.

Downloading one of our Mobile Apps.

  • 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 Mobile App (e.g. name, address, phone number, email, country of residence, preferred language).

Using our Website

  • Customers may provide personal data to us through the websites and apps that we manage. This information includes your name; your email address; your address; your telephone number and your billing payment details.
  • The data we collect will include performance, viewing and other technical information about your use of our network, services, products or websites. Some information will be collected automatically by our website (for further details, please see our Cookie Policy). 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. This information is likely to be aggregated and anonymised.
  • 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.
  • We collect information about your activity using the website and our services for a number of purposes using technologies such as cookies, user behaviour, and server log files. We use that information to help tailor the content you see on our site.

Applying to work with us

The type of information you may provide in your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive personal information (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.

 

What PERSONAL information do we collect from THIRD PARTIES?

We may collect personal data relating to you from third parties as follows:

  • Influencers may supply us with information which may include information relating to you such as your contact information, billing information, likes, dislikes, purchase history, interactions on the Influencers’ social media platforms.
  • Personal data collected from third parties (for example – from social media networks).

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.

 

Why do we collect this information?

In general, we collect this information to provide you with our services/products, to market our services, to improve our site and to recruit staff.

We will use this information:

  • To set you up on our systems;
  • To provide you with our services, to fulfill orders with suppliers, to facilitate payment for products purchased and respond to any questions you may ask us;
  • To create a candidate profile for you if you are a prospective employee;
  • To administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes so that we can provide you with the best user experience possible;
  • As part of our efforts to keep our website safe and secure and to address network integrity and security issues;
  • To deliver information about our products and services, offers and updates, where you have subscribed to receive same;
  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • To make suggestions and recommendations to you and other users of our website and Apps about services that may interest you or them;
  • To investigate, prevent or take action regarding illegal activities, violations of our Terms and Conditions of Use;
  • To analyze customer demographics identify shopping trends, popular products and to compile other relevant statistics on customer behavior and preferences.

The legal basis on which we process your personal data are:

  • Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract; or
  • Processing necessary for the purposes of the legitimate interests which we pursue where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information; or
  • Compliance with legal obligations; or

Where you have given clear consent to the processing for a specific purpose.

 

Who might we share this information with?

We may share your information with our selected business associates/ suppliers and contractors to provide you with our services/products. For example, these business associates/suppliers may include our web hosting provider and our IT service providers. 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 websites/apps and be redirected to the target pages on our Partner’s websites.  If a purchase is made by you after clicking such a link, you are likely to be asked to submit personal data 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. Please be aware that when you click through to third-party websites, we are not responsible for the privacy practices of these other sites. We are not responsible for the practices employed by websites linked to or from our websites and apps, nor the information or content on those sites. 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.

 

PAYMENT AND PAYING AGENTS

  • In addition to us ensuring that you get a discount from our Partners we also process your payment for the products purchased from our Partners.
  • 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.

 

DISCLOSURE OF YOUR INFORMATION

We may also share your information with selected third parties set out in the table below:

Payment Service providers
Web Service providers eg Amazon web service
Universal Shopping Cart API [use generic description of service provided rather than name]
[Sub-contractors]
[Cloud Service Providers]
[IT Back-up Providers]
[Archive/shredding companies]
[IT Service Providers]
[Email Service Providers]
[Internal customer database]
[CCTV]
[An Gardaí Siochána]

We may also disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • If we or substantially all of our assets are acquired by a third party, in which case information held by us about our customers will be one of the transferred assets;
  • If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

How long do we keep hold of your information?

The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.

 

Do We transfer your information Outside The European Union or European Economic Area?

Yes

The data that we collect from you may be transferred to, and stored in locations outside the European Economic Area (“EEA”) (including India) for which there is not an adequacy decision relating to the safeguards for personal data from the European Commission.

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/

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.

 

[AUTOMATED DECISION-MAKING AND PROFILING [FanzFirst TO CONFIRM THIS POINT]

We use automated decision-making/profiling. We use the following logic in making those decisions:

[insert description of logic of automated decision-making/profiling][insert the significance of the automated decision-making/profiling for the data subject][insert the envisaged consequences of such automated decision-making/profiling for the data subject]]

 

WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?

You have the following rights:

  • The right to access the personal data we hold about you.
  • The right to require us to rectify any inaccurate personal data about you without undue delay.
  • The right to have us erase any personal data we hold about you in circumstances such as where it is no longer necessary for us to hold the personal data or, in some circumstances, if you have withdrawn your consent to the processing.
  • The right to object to us processing personal data about you such as processing for profiling or direct marketing.
  • The right to ask us to provide your personal data to you in a portable format or, where technically feasible, for us to port that personal data to another provider provided it does not result in a disclosure of personal data relating to other people.
  • The right to request a restriction of the processing of your personal data.

Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.

You may exercise any of the above rights by contacting our data protection representative at privacy@fanzfirst.com

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commissioner. The website is www.dataprotection.ie.

 

What will happen if we change our privacy notice?

This notice may change from time to time, and any changes will be posted on our site and will be effective when posted. Please review this notice each time you use our site or our services. This notice was last updated on 07.06.2018.

 

How can you contact us?

You can contact us:

On our website contact form: www.fanzfirst.com

Or by email: privacy@fanzfirst.com

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 cookieOwnerPurpose for the cookie
Google AnalyticsGoogleThis 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.
StatCounterStatCounterThis 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