Last Modified: May 21st, 2018
MG Freesite II Ltd (hereinafter “we”, “us” or “our”)
operates the website https://www.foxyave.org/
(hereinafter “Foxyave” or the
“Website”) and is the controller of the information collected or provided via
and use of our Website signifies that you have read, understand and agree to
Website or otherwise submit your personal data. We respect your privacy and are
committed to protecting your personal data
If you have any questions about our privacy practices,
please see “Contact Information” below for information on how to contact us.
We collect, process and retain personal data to the extent
to information we collect:
on this Website,
in e-mail, text and other communications between you and
through mobile applications you download from this Website,
which provide dedicated non-browser-based interaction between you and this
when you interact with our advertising and applications on
third-party websites and services, if those applications or advertising include
It does not apply to information collected by:
us offline or through any other means, including on any
other website operated by us or any third party (including our affiliates and
any third party (including our affiliates and subsidiaries),
including through any application or content (including advertising) that may
link to or be accessible from or on the Website. Clicking on those links or
enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible
for their privacy statements.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any
information about an individual from which that person can be identified by
(“Personal Information”). It does not include data that has been anonymized or
We may collect, use, store and transfer different kinds of
personal data about you, which we have grouped together as follows:
Persons who visit the Website without logging in or
registering “unregistered users”
Technical Data includes internet protocol (IP) address,
which we pseudonymize (a technique that replaces or removes information in the
dataset that identifies an individual), browser type and version, time zone
setting and location, operating system and platform and other technology on the
devices you use to access this Website.
User Submitted Data includes data collected at your
direction for a specific function, for example a contest or survey.
Usage Data includes aggregated information about how you use
our Website, products and services.
Persons who choose to create an account “registered users”
Identity Data includes, username or similar identifier, date
of birth and gender.
Contact Data includes email address.
Financial Data in case of purchases includes payment card
Transaction Data in case of purchases, it may include
details about payments to and from you and other details of products and
services you have purchased or received from us.
Technical Data includes pseudonymized internet protocol (IP)
address, your login data, browser type and version, time zone setting and
location, operating system and platform and other technology on the devices you
use to access this Website.
User Submitted Data includes data collected at your
direction for a specific function, for example your username and password,
purchases or orders made by you, your interests, preferences, feedback and
Usage Data includes information about how you use our
Website, products and services.
Marketing and Communications Data includes your preferences
in receiving marketing from us and our third parties and your communication
We may also collect, use and share your data to produce and
share aggregated insights that do not identify you. Aggregated data may be
derived from your personal data but is not considered personal data as this
data does not directly or indirectly reveal your identity. For example, we may
aggregate your usage data to calculate the percentage of users accessing a
specific Website feature, to generate statistics about our users, to calculate
the percentage of users accessing a specific Website feature, to calculate ad
impressions served or clicked on, or to publish visitor demographics.
We do not collect special categories of Personal Information
about you (this includes details about your race or ethnicity, religious or
philosophical beliefs, political opinions, trade union membership, information
about your health and genetic and biometric data). However, particular
preferences and sexual orientation depend on how you use our Website and
services. The processing of such Sensitive Personal Information may be
necessary to provide some of our service to you.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We use different methods to collect data from and about you
Direct interactions. Information that you provide when
carrying out search queries on our Website or by filling in forms on our
Website, in particular at the time of registering to use our Website,
subscribing to our service, posting material, taking part in surveys, entering
a contest or promotion sponsored by us, when reporting a problem with our
Website, or requesting further services.
Automated technologies or interactions. See “Third-party Use
of Cookies and Other Tracking Technologies” for details of how we may
automatically collect your personal data.
We may provide areas on our Website where you can post
information about yourself and others and communicate with others, upload
content (e.g., pictures, videos, audio files, etc.), and post comments or
reviews of content found on the Website. Such postings are governed by our
. You should be
aware that any Personal Information you submit, display, or publish in public
areas of our website is considered publicly available and can be read,
collected, used, and disclosed by others. We cannot control who reads your
posting or what other users may do with the information you voluntarily post,
so we encourage you to exercise discretion and caution with respect to your
Personal Information. To request removal of your personal information from our
website, please refer to the section “your rights related to your personal
information” in this policy.
INFORMATION COLLECTED THROUGH AUTOMATIC DATA COLLECTION
As you navigate through and interact with our Website, we
use automatic data collection technologies to collect certain information about
your equipment, browsing actions and patterns, including information such as
your IP address, browser type, operating system, the referring web page, pages
visited, location, your mobile carrier, device information, search terms, and
The technologies we use for this automatic data collection
Cookies (or browser cookies). Cookies are small text files
that are stored in your web browser or downloaded to your device when you visit
a website. Cookies are then sent back to the originating website on each
subsequent visit, or to another website that recognizes that cookie, and allow
a website to recognize a user’s device.
We currently use the following types of cookies:
Cookies that are strictly necessary: These are cookies that
are required for the operation of our Website. These include, for example,
cookies that enable a user to log in to our Website and to check if a user is
allowed access to a particular service or content.
Analytical cookies: These cookies allow us to recognize and
count the number of users and to see how users use and explore our Website.
These cookies help us to improve our Website, for example by ensuring that all
users are able to find what they are looking for easily.
Functionality cookies: These cookies are not essential, but
help us to personalize and enhance your online experience on our Website. This
type of cookies allows us to recognize you when you return to our Website and
to remember, for example, your choice of language.
Targeting cookies: These cookies record the visit of a user
on our Website, the pages a user has visited and the links a user has followed
in order to enable us to make our Website more relevant to the users'
We do not require that you accept cookies and you may
browser’s privacy settings. However, if you decline to accept cookies, some
functionality on our Website may be disabled and you may be unable to access
certain parts of our Website. Unless you have adjusted your browser setting so
browser to our Website. Cookies can be either session cookies or persistent
cookies. A session cookie expires automatically when you close your browser. A
persistent cookie will remain until it expires or you delete your cookies.
Expiration dates are set in the cookies themselves; some may expire after a few
minutes while others may expire after multiple year
Web Beacons. Pages of our Website and our e-mails may
contain small electronic files known as web beacons (also known as clear gifs,
pixel tags, single-pixel gifs and web bugs) that are tiny graphics with a
unique identifier, similar in function to cookies, and are used to track the
online movements of web users or to access cookies.
Analytics. We use third party analytics and advertising
tools and technologies, in particular Google Analytics and DoubleClick provided
by Google, Inc., USA (“Google”). These tools and technologies collect and
analyze certain types of information, including IP addresses, device and
software identifiers, referring and exit URLs, onsite behavior and usage
information, feature use metrics and statistics, usage and purchase history,
media access control address (MAC Address), mobile unique device identifiers,
by Google Analytics and DoubleClick about your use of the Website (including
your IP address) may be transmitted to and stored by Google on servers in the
United States. Because we activated IP anonymization for Google Analytics and
Double Click, Google will anonymize the last octet of a particular IP address.
Only in exceptional cases, the full IP address is sent to and shortened by
Google servers in the USA. Google will use this information for the purpose of
evaluating your use of the Website, compiling reports on Website activity and
managing advertising content. To learn how you can opt out from this
information collection by Google see “Choices About How We Collect, Use and
Disclose Your Personal Information” below.
Some content or applications, including advertisements, on
the Website are served by third parties, including advertisers, ad networks and
servers, content providers and application providers. These third parties may
to collect information about you when you use our Website. Unless expressly
stated otherwise, our website does not provide any Personal Information to
these third parties, however they may collect information, including Personal
Information, such as internet protocol (IP) address, browser type and version,
time zone setting and location, operating system and platform and other
technology on the devices you use to access this Website. They may use this
information to provide you with interest-based advertising or other targeted
We do not control these third parties’ tracking technologies
or how they may be used. If you have any questions about an advertisement or
other targeted content, you should contact the responsible provider directly.
For information about how you can opt out of receiving targeted advertising
from many providers, see “Choices About How We Collect, Use and Disclose Your
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the applicable
local law allows us to. Most commonly, we will use your personal data in the
For purposes of providing the services, customer management
and functionality and security as is necessary to perform the services provided
to you under our term and conditions and any other contract that you have with
Where it is necessary for our legitimate interests (or those
of a third party) and your interests and fundamental rights do not override
Where we need to comply with a legal or regulatory
Where you declare your valid consent to use it.
Note that we may process your personal data for more than
one lawful ground depending on the specific purpose for which we are using your
PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
In general, we use information that we collect about you or
that you provide to us, including Personal Information and Sensitive Personal
Information, for following purposes:
Provision of services (Registered Members Only): to present
our Website and its contents to you, including any interactive features on our
Website, and to provide you with information, products or services that you
request from us; we also collect and use Personal Information to verify your
eligibility and deliver prizes in connection with contests and sweepstakes;
Customer management (Registered Members Only): to manage a
registered users’ account, to provide customer support and notices to the
registered user about his account or subscription, including expiration and
renewal notices, and notices about changes to our Website or any products or
services we offer or provide through it;
Customization of content (Registered Members Only): to
perform research and analysis about your use of, or interest in, our Website
content, products, or services, in order to develop and display content and
advertising tailored to your interests on our Website and other sites;
Analytics: to determine whether users of the Website are
unique, or whether the same user is using the Website on multiple occasions,
and to monitor aggregate metrics such as total number of visitors, pages
viewed, demographic patterns;
Functionality and security: to diagnose or fix technology
problems, and to detect, prevent, and respond to actual or potential fraud,
illegal activities, or intellectual property infringement;
Compliance: to enforce our terms and conditions and to
comply with our legal obligations;
in any other way we may describe when you provide the
information; or for any other purpose with your consent provided separately
DISCLOSURE OF YOUR PERSONAL INFORMATION
We do not disclose your Personal Information except in the
limited circumstances described here.
We may disclose your Personal Information to members of our
corporate group (that is, entities that control, are controlled by, or are
under common control with us) to the extent this is necessary for the purposes
of provision of services, customer management, customization of content,
advertising, analytics, verifications, functionality and security, and
Service providers. To our authorized service providers that
perform certain services on our behalf. These services may include fulfilling
orders, processing credit card payments, risk and fraud detection and
mitigation, providing customer service, performing business and sales analysis,
customization of content, analytics, security, supporting our Website
functionality, surveys and other features offered through our Website. These
service providers may have access to Personal Information needed to perform
their functions but are not permitted to share or use such information for any
Legal successors. To a buyer or other successor in the event
of a merger, divestiture, restructuring, reorganization, dissolution or other
sale or transfer of some or all of our assets, whether as a going concern or as
part of bankruptcy, liquidation or similar proceeding, in which personal
information held by us about our Website users is among the assets transferred.
Should such a sale or transfer occur, we will use reasonable efforts to try to
ensure that the entity to which we transfer your personal information uses it
We access, preserve and share your Personal Information with
regulators, law enforcement or others where we reasonably believe such
disclosure is needed to (a) satisfy any applicable law, regulation, legal
including investigation of potential violations thereof, (c) detect, prevent,
or otherwise address illegal or suspected illegal activities, security or
technical issues, (d) protect against harm to the rights, property or safety of
our company, our users, our employees, or others; or (e) to maintain and
protect the security and integrity of our Website or infrastructure. In such
cases, we may raise or waive any legal objection or right available to us, in
our sole discretion.
We may disclose aggregated information about our users, and
information that does not identify any individual, without restriction. We also
may share aggregated information with third parties for conducting general
business analysis. This information does not contain any Personal Information
and may be used to develop content and services that we hope you and other
users will find of interest.
Financial information (including Personal Information) that
you have provided to us will only be shared with our third party processors in
order to initiate and complete any orders placed on your account. All credit
card transactions and such are processed with industry standard encryption
through third party processors who only use your financial information and
Personal Information for that purpose. All financial data and related Personal
Information will not be shared by us with third parties except with your authorization
or when necessary to carry out all and any transactions requested by you with
the understanding that such transactions may be subject to rules, terms,
conditions and policies of a third party. All such information provided to a
third party is subject to their terms and conditions.
TRANSFERS OF YOUR PERSONAL INFORMATION TO OTHER COUNTRIES
Whenever in the course of sharing information we transfer
Personal Information to countries outside of the European Economic Area and
other regions with comprehensive data protection laws, we will ensure that the
permitted by the applicable laws on data protection.
By using the Website you consent to the transfer of
information that we collect about you, including personal information, to any
country in which we, members of our corporate group (that is, entities that
control, are controlled by, or are under common control with us) or our service
providers are located.
RETENTION OF PERSONAL INFORMATION
We will only retain your Personal Data for as long as
necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal
data, we consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorized use or disclosure of your personal
data, the purposes for which we process your personal data and whether we can
achieve those purposes through other means, and the applicable legal
Where we no longer need to process your Personal Data for
from our systems.
Where permissible, we will also delete your Personal Data
upon your request. Information on how to make a deletion request can be found
under “Your Rights Related to Your Personal Information”.
If you have questions about our data retention practices,
please send us an e-mail at firstname.lastname@example.org.
The period for which we keep your Personal Information that
is necessary for compliance and legal enforcement purposes varies and depend on
the nature of our legal obligations and claims in the individual case.
HOW WE PROTECT THE SECURITY OF YOUR PERSONAL INFORMATION
We take appropriate security measures (including physical,
electronic and procedural measures) to safeguard your Personal Information from
unauthorized access and disclosure. For example, only authorized employees are
permitted to access Personal Information, and they may do so only for permitted
business functions. In addition, we use encryption in the transmission of your
Personal Information between your system and ours, and we use firewalls to help
prevent unauthorized persons from gaining access to your Personal Information.
Please be advised, however, that we cannot fully eliminate security risks
associated with the storage and transmission of Personal Data.
You are responsible for maintaining the secrecy of your
unique password and account information at all times. We are not responsible
for circumventions of any privacy settings or security measures contained on
CHOICES ABOUT HOW WE COLLECT, USE AND DISCLOSE YOUR PERSONAL
We strive to provide you with choices regarding the Personal
Information you provide to us.
You can choose not to provide us with certain Personal
Information, but that may result in you being unable to use certain features of
our Website because such information may be required in order for you to
register as a member; purchase products or services; participate in a contest,
promotion, survey, or sweepstakes; ask a question; or initiate other
transactions on our Website.
You can set your browser to refuse all or some browser
cookies, or to alert you when cookies are being sent. If you disable or refuse
cookies, please note that some parts of the Website may then be inaccessible or
not function properly.
You may opt out of the DoubleClick cookie or of Google
Analytics by visiting the Google advertising opt-out page or by downloading and
installing the browser plug-in available at Google Analytics opt-out page.
When you register on our Website. If you no longer want to
receive commercial or promotional emails or newsletters from us, you will need
to avail yourself of the unsubscribe mechanism set out in the applicable
communication. It may take up to seven days for us to process an opt-out request.
We may send you other types of transactional and relationship e-mail
communications, such as service announcements, administrative notices, and
surveys, without offering you the opportunity to opt out of receiving them.
Please note that opting out of receipt of promotional email communications will
only affect future activities or communications from us. If we have already
provided your information to a third party before you have changed your
preferences or updated your information, you may have to change you preferences
directly with that third party.
If you submit Personal Information, you may delete and
deactivate your account with us at any time. If you deactivate and delete the
information of your account, your Personal Information and any and all other
account related information including, but not limited to, user profile data,
sharing data and any other data, or content specifically associated with your
account will no longer be accessible by you. After deleting and deactivating
your account, if you choose to have an account with us in the future, you will
have to sign up for a new account as none of the information you previously
provided or saved within your account will have been saved.
YOUR RIGHTS RELATED TO YOUR PERSONAL INFORMATION
Subject to local law, you have certain rights regarding the
Personal Information we collect, use or disclose and that is related to you,
including the right
to receive information on the Personal Information
concerning we hold about you and how such Personal Information is used (right
to rectify inaccurate Personal Information concerning you
(right to data rectification);
to delete/erase your Personal Information (right to
erasure/deletion, “right to be forgotten”);
to receive the Personal Information provided by you in a
structured, commonly used and machine-readable format and to transmit those
Personal Information to another data controller (right to data portability)
to object to the use of your Personal Information where such
use is based on our legitimate interests or on public interests (right to
in some cases, to restrict our use of your Personal
Information (right to restriction of processing).
If we ask for your consent to use your Personal Information,
you can withdraw your consent at any time. Note that in case of a withdrawal of
your consent you may no longer able to use several functionalities of our
Website and our services.
You may, at any time, send us an e-mail at email@example.com
to exercise your above rights in accordance with the applicable legal
requirements and limitations. If you are located in the European Economic Area,
you have a right to lodge a complaint with your local data protection
Note that some requests to delete certain Personal
Information will require the deletion of your user account as the provision of
user accounts are inextricable linked to the use of certain Personal
Information (e.g., your e-mail address). Also note that it is possible that we
require additional information from you in order to verify your authorization
to make the request and to honor your request.
time. Although we may attempt to notify you when major changes are made to this
version found at http://www.foxyave.org/information#privacy
so you are aware of
any changes, as they are binding on you.
change will be reflected in the “last modified date”. You agree that you will
then it is unchanged. On the other hand, if the date has changed, then there
to the new ones. By continuing to use the Website subsequent to us making
take notice of it, you thereby consent to such amendment.
Please feel free to direct any questions or concerns regarding this privacy
policy or our treatment of Personal Information by contacting us through this Website
at firstname.lastname@example.org. When we receive a formal written complaint, it is our
policy to contact the complaining party regarding his or her concerns. We will
cooperate with the appropriate regulatory authorities, including local data
protection authorities, to resolve any complaints regarding the collection, use
and disclosure of Personal Information that cannot be resolved by an individual
NO RIGHTS OF THIRD PARTIES
third parties or require disclosure of any Personal Information relating to
users of the Website.
OUR POLICY TOWARDS MINORS
Our Website is not directed to persons under the age of 18
or the applicable age of majority in the jurisdiction from which the Website is
accessed and we do not knowingly collect Personal Information from minors. If
you become aware that your child has provided us with Personal Information,
please contact us at email@example.com. If we become aware that a minor has
provided us with Personal Information, we take steps to remove such information
and terminate that person’s account.
NO ERROR FREE PERFORMANCE
We do not guarantee error-free performance under this
policy and will take prompt corrective action when we learn of any failure to
information-handling practices, please contact us at firstname.lastname@example.org.
GDPR (GENERAL DATA PROTECTON REGULATION)
In accordance with the General Data Protecton Regulation law
in the European Union effective May 25, 2018, Foxyave users can request a copy
of their personal data as well as get Foxyave to delete their personal data.