Privacy Policy

1.1 Information You Provide

We collect personal information that we received from you when you use our platform, this includes personal information such as: watch a video, enquire or make an application for ours services, register to use and/or use any of our services and when you communicate with us through e-mail, or portals on our site. Such information may include user’s name including first name and family name, gender, date of birth, e-mail address, billing address, username, password, country of residence, etc.;

1.2 Information We Automatically Collect from Your Use of the Website.

We collect information about the services that you use and the way in which you use them, such as when you “like” or watch a video on the Website. This information also includes:

• Device information. We collect device specific information such as IP address, access dates and times, hardware and software information, device information, cookie data.
• Geo-location Information. When you use certain features of the Website, we may collect information about your approximate location as determined through data such as your IP address.
• Usage Information. We collect information about your interactions with the Website such as the content you view, your searches queries and other actions on the Website.
• Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers.  
• Payment Transaction Information. We collect information related to your payment transactions through the payment platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address and other related transaction details.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Website, to protect us and our users and to comply with our legal obligations. We also use this information to offer you tailored content – like giving you more relevant search results and ads.

2.1 Provide, Improve, and Develop the Website.  

• Enable you to access and use the Website.
• Operate, protect, improve, and optimize the Website, such as by performing analytics and conducting research.
• Provide customer service.
• Send you service or support messages, updates, security alerts, and account notifications.
• To operate, protect, improve, and optimize the Website, and personalize and customize your experience (such as making suggestions or ranking search results), we conduct profiling based on your interactions with the Website, your search and viewing history, your profile information and preferences, and other content you submit to the Website.

We process this information as it is necessary for the adequate performance of the contract with you and given our legitimate interest in improving the Website and our users’ experience with it and with your consent where required.

2.2 Protect us and our Users and Comply with Legal Obligations.

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Comply with our legal obligations.
• Resolve any disputes with any of our users and enforce our agreements with third parties.
• Enforce our Terms of Service and other policies.

We process this information given our legitimate interest in protecting the Website and to comply with applicable laws.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Website).
• Personalize, measure, and improve our advertising based on your characteristics and preferences (based on the information you provide to us, your interactions with the Website, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest and with your consent where required. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your account.

3. COOKIES POLICY AND GOOGLE ANALYTICS

3.1 We use cookies to collect information about how the Website is used.

Cookies are text files that are placed by the browser in the memory of a user’s device when our website is visited. Our website uses session cookies and persistent cookies:

Session cookies expire at the end of a browser session. They only enable us to collect and connect the user’s actions during the particular browser session and are deleted when the browser is closed or the user logs off.

Persistent cookies survive a browser session and are stored for a predefined period of time. We are using persistent cookies with the following information and for the following purposes:

• Identifying a registered user; and
• Keeping some search preferences; and
• Keeping the likes of the unregistered users; and
• Saving the video player’s preferences; and
• Displaying the advertisements; and
• Keeping statistics regarding the speed loading of the pages.

The user can disable the cookie function in his browser options. Please see the specific information of the browser used for visiting this website. For details how to control and/or delete cookies, see aboutcookies.org. If cookies are disabled the user might not be able to use all the functions and services of the Website.

3.2 In addition, we use Google Analytics, a web analytics service provided by Google, Inc. (hereinafter referred to as “Google“), using third-party cookies that enable Google to analyze the use of the Website.  

Google will use this information on our behalf to evaluate the use of the Website, to compile reports for activities on the Website, and to provide other services to us relating to the Website.

Google Analytics operates under the following terms:

• Terms of Service: http://www.google.com/analytics/terms/gb.html
• Privacy Statement: http://www.google.com/intl/en/analytics/learn/privacy.html
• Privacy Policy: http://www.google.com/intl/en/policies/privacy

The user can prevent Google from collecting and processing the data concerning the use of the Website (including the IP address) by installing a browser-plug-in which is available under https://tools.google.com/dlpage/gaoptout.

4. SECURITY

Note that all data is kept in a secure environment. We protect personal data by using appropriate safeguard procedures and measures, in particular:

• We encrypt our services using SSL (you can reach our SSL protected website under https://freshnewfaces.club).
• We use firewalls to protect your information.
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations.

If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us.

5. YOUR RIGHTS

You may exercise any of the rights described in this section by adjusting settings in your user account and, if it is not possible, you can contact us at our abovementioned address. Please note that we will ask you to verify your identity before taking further action on your request, if we cannot identify you we cannot act according to your request.

5.1 Managing Your Information.

You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.

5.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your account).

5.3 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us, to protect our legitimate interest or legitimate interest of a third party and to comply with our legal obligations. If you no longer want us to use your information to provide you the service, you can request that we close your account and erase your personal data in your user account by clicking “DELETE MY ACCOUNT” Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations.
• Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.