We as Favorites Group, Inc. (“Favorites Group”), give utmost importance to the privacy of our Visitors and Users during their use of our website with domain name www.favoritan.com (“Website”) and Favoritan Application (collectively “Favoritan Platform”) regardless of their country of access.
This Privacy Policy (“Policy”) is prepared with a privacy-prioritizing attitude in order to provide detailed information to Visitors and Users regarding the identity of Favorites Group as a data controller; data processing and its legal bases, reasons; rights of Visitors and Users (collectively “Data Subject”), which can be exercised against Favorites Group.
Since, Favorites Group is a USA based company but has numerous Visitors and Users from different countries; it is hard to determine which legislation should be applied to its activities and business. Therefore, Favorites Group intends to reflect its compliance with different legislations about privacy and data protection. For this reason, Favorites Group shows considerable effort to act in accordance with General Data Protection Regulation (“GDPR”), California Consumer Privacy Act (“CCPA”) and other applicable data protection regulations.
This Policy includes different Data Subjects with various motives such as somehow accessing, signing up, signing in to Favoritan Platform and having a premium account on it. Even though Data Subject may be referred as Visitor or User according to their intention for using Favoritan Platform, they will be covered in this Policy.
Information that makes it possible for related person to be identified directly or indirectly by any other person (“Personal Data”) is in the scope of this Policy. Accordingly, it can be safely said that confidential information, which cannot be considered as Personal Data, is excluded from this Policy.
For any and all data processing that occurs through accessing the Favoritan Platform, Favorites Group, Inc. residing at 16912 Coastal Highway, Lewes/Delaware is a data controller (“Controller”).
Favorites Group processes personal data during including without limitation below-mentioned situations: accessing to Favoritan Platform, creating an account on Favoritan Platform, using Favoritan Platform, providing feedback to Favorites Group, purchasing and using premium services, contacting with Favorites Group regarding different requests and questions.
Favorites Group considers below-mentioned principles while Processing Personal Data: Processing Personal Data lawfully, fairly and in a transparent manner in relation to the Data Subject, Processing Personal Data accurately and where necessary, kept up to date, Processing Personal Data for specific, explicit, and legitimate purposes, Processing Personal Data relevantly, limitedly and proportionately to the purposes for which they are processed, Processing Personal Data in a manner that ensures appropriate security of the Personal Data and kept in a form which allows identification of Data Subjects for no longer than it is necessary for the processing reasons.
Personal Data Collected By Us Personal Data Collected By Us Name-Surname Cookie E-mail Address User Feedback Phone Number IP Address Profile Picture Login Data Country Device & Browser Type City Usage Information Birth Date Gender Language Preference Feedback Answer
Personal Data given to or collected by us shall only be processed when necessary for a reasonable cause and when there is a legal basis for processing. Reasons and legal bases of processing are listed limitedly in this Policy and this Policy will be updated if a reason or a legal basis change. a. First Name and Last Name b. E-Mail Address c. Birth Date d. Phone Number Processing Reasons Legal Bases Creating an account Entering into a contract Making name-surname data searchable in Favoritan Platform The data being made manifestly public by the Data Subject Processing Reasons Legal Bases Creating an account Entering into a contract Notifying about your purchased premium account Performance of a contract Notifying about changes in the Favoritan Platform Performance of a contract Guiding for password renewal Performance of a contract Processing Reasons Legal Bases Creating a personalized account Legitimate interest Processing Reasons Legal Bases Allocating an account to the phone number Legitimate interest Providing log in to Favoritan Platform Performance of a contract Notifying about changes in the Favoritan Platform Performance of a contract e. Country Data f. City Data g. Profile Picture h. Gender i. Answers j. Feedback k. Language Preference Processing Reasons Legal Bases Adding a location mark for the questions & answers Legitimate interest Processing Reasons Legal Bases Adding an optional location mark for the questions & answers Legitimate interest Processing Reasons Legal Bases Enabling User to personalize their account on Favoritan Platform The data being made manifestly public by the Data Subject Processing Reasons Legal Bases Adding a gender mark for the questions & answers Legitimate interest Processing Reasons Legal Bases Enabling Users to see answers for a specific question The data being made manifestly public by the Data Subject Processing Reasons Legal Bases Improving Favoritan Platform Legitimate interest Processing Reasons Legal Bases Enabling User to use Favoritan Platform with preferred language Performance of a contract 5 l. User Feedback m. Usage Information n. Cookie o. IP Address p. Login Data q. Device & Browser Type 9. Rights of Data Subjects Data Subjects are endowed with some rights to ensure their Personal Data to be processed on a lawful basis. Favoritan Platform is designed in compliance with the Privacy by Design and Data Protection by Design principles. Therefore, along with the below-mentioned rights, Data Subjects have a right to opt-out from the Favoritan Platform which ends up with their accounts to be deleted. a. Right to be informed, by which the Data Subject may request information about their Personal Data being processed by Favorites Group. b. Right of access, by which the Data Subject may request to learn their Personal Data being processed by Favorites Group. Processing Reasons Legal Bases Improving Favoritan Platform Legitimate interest Processing Reasons Legal Bases Improving Favoritan Platform Legitimate interest Processing Reasons Legal Bases Improving Favoritan Platform Legitimate interest Processing Reasons Legal Bases Complying with legal obligation Legal obligation Processing Reasons Legal Bases Improving Favoritan Platform Legitimate interest Processing Reasons Legal Bases Improving Favoritan Platform Legitimate interest c. Right of rectification, by which the Data Subject may request Favorites Group to correct or complete their Personal Data. d. Right to restrict processing, by which the Data Subject may request to limit the way their Personal Data is used. e. Right to erasure, by which the Data Subject may request to have their Personal Data erased. f. Right to data portability, by which the Data Subject may request to receive their Personal Data in a machine-readable format and/or request Favorites Group to transfer their Personal Data to another controller. g. Right to object, by which the Data Subject may request Favorites Group to stop processing their Personal Data. h. Rights in relation to automated decision-making, by which the Data Subject may request Favorites Group to stop processing their personal data in cases where Personal Data is being processed via automated decision-making.
Favorites Group transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which have their own legal bases for the transfer:
a. Law Enforcement and Judiciary Authorities: Favorites Group may be obliged to disclose Personal Data when required to do so by law, including but not limited to legal claims, legal investigations, lawful requests or legal proceedings.
b. Mobile Application Server and Infrastructure Services Provider: Name-Surname, E-mail Address, Country, City, Profile Picture, Phone Number, answers to questions and Gender data may be transferred to the company providing server and infrastructure services in the U.S. for Favoritan Platform.
c. Third-Party Marketing Services: Usage Information, User Feedback and Cookie data may be transferred to Facebook and Google in order to conduct marketing and remarketing activities, helping us to keep Favoritan Platform’s basic functions free. [Facebook Pixels and SDKs - Firebase or Google Analytics SDKs | Google Adsense for Website and Google Admob for Mobile App advertising] Such transferring activity is limited to the usage of Facebook Pixel, Facebook Software Development Kits (SDK), Google Software Development Kits (SDK), Google AdSense and Google AdMob. To limit such activity, for the tracking purposes, Users should check their device settings to activate “Limit Ad Tracking” function. Users may also visit www.facebook.com/ads/settings and www.adssettings.google.com to opt-out such tracking activities.
Favorites Group stores Personal Data in view of Data Minimization Principle, which necessitates Personal Data to be kept only for the required period. Required period is assigned considering the nature of the Personal Data, the potential risks of a Personal Data breach, processing reasons, and whether or not such reasons can be achieved in a different manner.
Appropriate technical and organizational measures are enacted to ensure the safety, protection and the encryption of the Personal Data in order to prevent any Personal Data breach such that may be caused by accidental or unauthorized destruction, loss, theft or; unauthorized use, alteration and disclosure. In this context, Favorites Group; a. Sign non-disclosure agreements with parties who have limited or unlimited access to Personal Data. b. Organize awareness trainings about data protection inside its organization. c. Entitles its employees with limited authorization according to their work line. d. Transfer Personal Data on a ‘need-to-know’ basis. e. Process and store personal data on safely secured and encrypted cloud servers.
Data Subjects may contact Favorites Group in case of having questions, comments, or feedback via info@favoritan.com and Favoritan Website