Privacy & Cookies Policy

LAST UPDATED: January 1, 2021


Welcome to our Privacy & Cookie Policy. This Privacy Policy explains how we collect, use, and disclose personal data (as defined herein) related to your use of our Services.


1) Who we are


2) About this privacy notice


3) Changes to this privacy notice


4) How to contact us


5) Personal data we collect and how


6) Aggregated data


7) How we collect personal data


8) Marketing Choices


9) Sharing your personal data


10) UK and EU users: international transfer of your personal data


11) Retaining your personal data


12) Third-Party Sites


13) Cookie policy


14) Privacy information for EEA and UK users

1. Who we are

When we mention “FlavourAds”, “we”, “us” or “our” in this Privacy Policy, we mean FlavourAds Limited registered in England & Wales with company registration number 05632423 and registered address 21 Clare Road, Halifax, West Yorkshire, HX1 2HX.


2. About this privacy notice

This Privacy Notice explains how FlavourAds collects, uses, and discloses data about you and processes information that identifies or can be used to identify you (sometimes referred to as “personal data” or “personal information” under applicable privacy and data security laws, and hereinafter “personal data”) when you use our website(s), mobile apps, and other online products or services that link to this Privacy Policy (collectively, the “Services”) or when you otherwise interact with us. From time to time we partner with third parties to provide you with products, promotions or other experiences. We will show you the privacy policies belonging to those third parties when they will receive information in connection with those experiences. Their privacy policy will govern the collection of your personal data, in addition to this Privacy Policy.


3. Changes to this Privacy Policy

We’re likely to update this Privacy Policy in the future and when we make changes, we will revise the date at the top of the policy and, in some cases, will notify you through the Services, such as on our homepage, or via email or other communication. Please come back and check from time to time for the latest information on our privacy practices.


4. How to contact us

If you have questions or concerns about the information in this Privacy Policy, our handling of your personal data more generally, your choices and rights regarding such use, or wish to exercise your rights under law, please do not hesitate to contact us at:


Flavour Ads Ltd

21 Clare Road, Halifax, West Yorkshire, HX1 2HX

Attn: Data Protection Officer

data-privacy@flavourads.com


5. What personal data we collect and how


5.1 Personal data you provide to us.

We collect data you provide directly to us.


-Account data. If you sign up for a FlavourAds account (“Account”), we will collect data you give us related to your Account, including your name, email address, username and password. We describe this more fully in Section 5.4 below.


-Payment data. To order products or services through our Services, you may need to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments. We will collect the data we need in order to process that purchase (for example, payment details). However, your financial information is collected and stored by our third party payment processing company, and use and storage of that data is governed by the third party payment processor’s applicable privacy policy.

Purchase data. If you make a purchase from a third party after clicking on an affiliate link through the Services, we will receive data about the purchase for the purpose of managing our business relationship.


-Additional Account data. You may provide additional data as part of your Account (such as your personal description). This data will be publicly visible to others. If you do not wish to share this information with us or others, do not provide the information as part of your Account.


-Other data you share through the Services. You may provide us with data when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, post to community forums, provide us with feedback, participate in promotions, or use other features of the Services.


5.2 Data that indirectly identifies you and automatically collected data.


When you access or use the Services, we collect data that indirectly identifies you and we automatically collect other data about you, including:


-Log Data. We automatically receive and record information from your device or web browser when you interact with the Services. For example, we collect your internet protocol (IP) address, mobile device ID, time zone setting, language preference, operating system, platform, internet service provider (ISP), and links you have clicked on or shared with others, including through email and social media. If you sign up for an Account, we also create a user ID that indirectly identifies you. We use this information to collect data about your activities through the Services. We associate information that indirectly identifies you with your Account (if you have one) and other information we have collected about you.


-Cookies. When you visit the Services, we will set certain “cookies” and similar tracking technologies on your device, including cookies and web beacons. For more information about cookies and how to disable them, please see our “Cookie Policy” section below.

We also may use these technologies to collect data about your online activities over time and across third-party websites or other online services (behavioral tracking).


The information we collect automatically may include personal data, or we may maintain it or associate it with personal data we collect in other ways or receive from third parties.


5.3 Location data.

We use your IP address to infer your approximate location. We may also collect the language option or country you choose. When we provide certain services, such as providing you with a version of our Services that is localized to your country, we link location data to other information we have collected about you in order to do so.


5.4 Profile data.

If you sign up for an Account, we will collect certain data you give us as part of your Account sign-up as described above, information you give us in connection with purchases or orders made by you, and your interests, preferences, feedback and survey responses. Your interests and preferences are inferred from data we collect regarding what types of content you have interacted with, how long you interacted with them, how often you interacted with them, and the nature of your interaction with the content. We do not disclose email addresses to other users except where it is necessary to comply with the law, to protect our rights, or to protect the rights of our users.


5.5 Special category data.

When we conduct research or carry out surveys and you participate in our research or surveys, we may collect sensitive personal data about you, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation. We will get your explicit consent for our collection, use, or sharing of this data as required by law.


6. Aggregated data


6.1 We analyze and aggregate personal data we collect, such as the number and frequency of your visits to the Services, to produce anonymized metrics and statistical information that does not identify you as an individual.


6.2 We combine information about you with information about other users to create audience segments of aggregated data, for example, statistical, demographic and usage data. If we combine or connect aggregated data with your personal data, we treat the combined data as personal data and deal with it in accordance with this Privacy Policy.


7. How we collect personal data


7.1 You may give us your personal data directly, for example when you create an Account, fund us by donation, support us by paying for a subscription, buy products or services, subscribe to our newsletters, opt-in to marketing communications, publish posts or comments, enter a competition, participate in a promotion or survey, ask for user support, or contact us for any reason.


7.2 We automatically collect personal data when you interact with our Services. We collect information about your devices and browsing actions and interests by using cookies and similar technologies. Our “Cookie Policy” section provides more details on how this works.


7.3 Third parties who provide advertising and related services (such as analytics providers and ad networks) may give us your personal data so that we can compare it to personal data we hold in order to determine if you are the same individual (this is sometimes called “cookie-matching”). We may collect data from unaffiliated third parties so we can better understand you and provide you with information and offers that may be of interest to you. For example, we may receive information about your interests or preferences as well as contact information, such as email address.


7.4 We may receive your personal data from third parties when you buy things through our Services or when you buy things from a third party after clicking on an affiliate link in our content. This information may include your contact details and financial and transaction data (such as items purchased and purchase price) from providers of technical, payment and delivery services.


7.5 If you access our Services using your Facebook or Google credentials, we will automatically collect certain information, such as your Facebook or Google user ID. We will use any information collected from Facebook or Google, including the user ID Facebook or Google attribute to you, only in accordance with Facebook’s or Google’s policies and your preferences selected through Facebook or Google.


7.6 What we use your data for:

We use the data we collect to provide, maintain, and improve our Services. We also use the data we collect to:


-Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;

-Communicate with you about products, services, offers, and events offered by FlavourAds and others, and provide news and information we think will be of interest to you;

-Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests. Your interests and preferences are inferred from data we collect regarding what types of content you have interacted with, how long you interacted with them, how often you interacted with them, and the nature of your interaction with the content;

-Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;

-Monitor and analyze trends, usage and activities in connection with our Services and personalize and improve the Services;

-Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of FlavourAds and others; and

-Carry out any other purpose described to you at the time the data was collected.


8. Marketing choices

When you sign up for a promotion like a sweepstakes, or subscribe to or create an Account to use our Services, we use your personal data to help us decide which products, services and offers may be of interest to you. We will send marketing messages to you if you have asked us to send you information, bought goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion. If you opt out of receiving marketing messages, we may still send you non-promotional emails, such as those about your Account or our ongoing business relations. We will ask for your consent before we share your personal data with any third party for direct marketing purposes.


You may unsubscribe from marketing messages through a link we include on messages we send you. You can also ask us to stop sending you marketing messages at any time by contacting us at: data-privacy@flavourads.com


9. Sharing your personal data

In general, your personal data will remain with FlavourAds but we may share personal data about you as follows or as otherwise described in this Privacy Policy:


-We share your personal data within FlavourAds’ legal entities where necessary to fulfill a contract or precontractual measures, or where we have a legitimate interest in doing so or a legal obligation to do so;

-With vendors, consultants, and other service providers who process your data on our behalf when they provide services to us, for example data analytics, ad networks, research, marketing and financial services;

-With third parties who use it for their own purposes if you have provided consent;

-In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

-We may be legally required to disclose or share your personal data without your consent in some circumstances, for example to comply with a court order or law enforcement. In such circumstances, we will only disclose your personal data if we have a good-faith belief that such sharing is required under applicable legal obligations;


We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may share aggregated or de-identified information with our ad partners and service providers so that we, and they, can understand how people use our Services; this helps us grow our business and improve and develop our products and services. We may also share a hashed version of your email address to facilitate customized ad campaigns on other platforms.


10. UK and EU users: international transfer of your personal data


10.1 When we process your personal data within FlavourAds, we will do so in countries in which we have offices (United States, India, Australia, Japan, Brazil, Mexico, Canada). We have put into place intra-group controls (including the standard contractual clauses approved by the European Commission) to ensure that your rights continue to be protected.


10.2 Third parties with whom we share your data may be based outside the EEA and their processing of your personal data may involve a transfer of data outside the EEA. For more information, please refer to the privacy policy links for such third parties in our consent management platform.


10.3 Our agreements with those third parties include Commission-approved standard contractual clauses and otherwise make clear the standards we expect of them in order to safeguard your information and your legal rights.


11. Retaining your personal data


11.1 We keep your personal data for as long as we need it for the purposes for which it was collected.


11.2 When we decide how long we will keep your information we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, why we need it, and any relevant legal requirements (such as legal retention and destruction periods).


11.3 We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes.


12. Third-Party Sites


12.1 Our sites and apps may include links to third-party sites, apps and social media platforms (“Third-Party Sites”). Clicking on those links may allow third parties to collect or share data about you. We do not endorse or control Third-Party Sites, each of which may be governed by its own terms of service and privacy policy and we encourage you to read their privacy policies and terms so that you understand how they process information about you. You are solely responsible for all liability for any damages or other harm, whether to you or third-parties, resulting from your use of Third-Party Sites. Please take all protections necessary to protect yourself when accessing Third-Party Sites, particularly when downloading or purchasing anything therefrom.


12.2 The Services may offer social sharing features and other integrated tools, which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. We also use the analytics tools provided by the social media platforms to help us to understand how people interact with our social media presence, to identify trends and to carry out joint promotional activities with those platforms. For example, sometimes we agree with a social media platform that we will jointly promote certain content.


We also use the analytics tools provided by the social media platforms to help us to understand how people interact with our social media presence, to identify trends and to carry out joint promotional activities with those platforms. For example, sometimes we agree with a social media platform that we will jointly promote certain content.


We receive aggregated statistical information from social media platforms about the performance of our posts and promoted content, such as numbers of views and kinds of viewers. This data is aggregated and anonymized by the social media platform prior to being made available to us.


We also use the paid advertising and paid content tools provided by the social media platforms to help us carry out advertising campaigns for our ad partners and to promote our content on the social media platforms. For example, we use the “Promoted Pins” tool on Pinterest to promote editorial or paid content to visitors to Pinterest. Again, we receive from the social media platforms only aggregated statistical information about interactions with our ads and paid content, such as number of views, number of times shared and so on.


We process information provided to us by the social media platforms on the basis of our legitimate interest in interacting with our audience on social media and using social media to promote our content.


For more information about the purpose and scope of data collection and processing in connection with social sharing features or your use of the social media platforms, please visit the privacy policies of the respective entities at the following links:


Facebook and Instagram – https://en-gb.facebook.com/policy.php

Twitter – https://twitter.com/en/privacy

YouTube – https://policies.google.com/privacy?hl=en

Snapchat – https://www.snap.com/en-US/privacy/privacy-center/

Twitch – https://www.twitch.tv/p/legal/privacy-policy/

TikTok – https://www.tiktok.com/en/privacy-policy

Pinterest- https://policy.pinterest.com/en/privacy-policy

Tumblr – https://www.tumblr.com/privacy

LinkedIn – https://www.linkedin.com/legal/privacy-policy

LINE – https://terms.line.me/line_rules


13. Cookie policy


13.1 Cookies are small data text files that are sent from a server during a browsing session. Cookies are typically stored on your computer’s hard drive and are used by web sites to simulate a continuous connection to that site. The use of cookies automatically identifies your browser whenever you interact with a site. A “web beacon,” also known as a tag, pixel tag, or clear GIF, is used to transmit information back to a web server. When we talk about “cookies” in this Privacy Policy, we mean not just cookies, but web beacons and similar technologies.

Cookies and similar technologies allow us to collect the following types of personal data: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken through our Services; time and date of those actions; country and language selected.


Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies you may not be able to access all the features of our services. We suggest that you keep our essential cookies (described below) active for a better user experience and to help us keep improving and developing our products and services.


13.2 Our Services use our own cookies to recognize you and remember you as a unique user.


Session cookies remember you during your session on our Services. They are deleted when you log out of the Services and when you close your web browser. Session cookies are used to ensure you are served content correctly, to balance and monitor load on our servers, and for other technical matters essential to the operation of our Services. You can configure your device to reject these cookies, but our Services will probably not work correctly, or at all, if you do.


Consent cookies are used by our consent management platform we employ to record your preferences about third party cookies described below, and to store and share your preference with those third parties. These cookies are essential for compliance with the legal obligations imposed on us and on third parties with whom we have a business relationship to ensure we request your consent, record your consent preferences, and act on such consent preferences.


13.3 Analytics cookies

Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (for example Google Analytics) so that we can manage and improve the performance and design of our Services and for monitoring, auditing, research and reporting.


We have activated Google’s IP anonymisation function on our Sites. This will cause your IP address to be cut by Google within Member States of the European Union or in other countries party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Sites, to compile reports on Site activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.


With respect to Google Analytics, you can read about how Google uses data gathered for that purpose here.


13.4 Third party cookies: advertising and affiliate links

Our ad partners and our affiliate links partners collect personal data from you for the purposes they disclose through our cookie consent management platform.


Ad partners include ad networks such as third party ad servers, ad agencies, ad technology vendors and research firms.

Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.

Our ad partners use third party cookies to serve ads to you and to target you with tailored (or personalized) ads when you are using the Services and when you visit Third-Party Sites. They also use cookies to measure traffic on the Services (for example to track ad views).


Ad partners and affiliate links partners may view, edit or set their own cookies on your mobile device or web browser when you interact with our Services. They use cookies to track your use of our Services and your activities elsewhere online. We are not responsible for the privacy practices of these third parties and we encourage you to read their privacy policies so that you understand how they process information about you. We provide links to their privacy policies in our consent management platform, which you can access by here.


You can decide who you will allow to set these third party cookies on your browser or device by going to our consent preferences center. You can change your mind and revisit your consent choices at any time by returning there.


14. Privacy information for EEA and UK users


14.1 Information for UK/EU Users (including legal bases)

We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose, we will explain the legal basis we rely on.


The table below shows what we use your personal data for and the lawful basis for processing it in each case.

Purpose

Type of Data

Lawful Basis

Recognize you and analyse how you, and other users, navigate the Services and apps and what type of content you’re interested in, and to manage and improve the Services by testing new features of our sites and apps. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.

Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.

Legitimate interest

Recognize you and analyse how you, and other users, interact with ads on our Services and what type of ads you’re interested in. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.

Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.

Consent

Communicate legal information to you.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information you include in your user profile).

Legitimate interest

Analyse comments and feedback you have given us including comments, feedback and reviews you have posted on our Services in order to use the information to carry out journalistic activities, to improve our services and content offerings, and to enforce our Terms of Service.

Data that directly identifies you (such as your name, username, and email address) and data that indirectly identifies you (such as your IP address or mobile device ID and location data).

Legitimate interest

Provide you with communications and services you’ve signed up, for such as our newsletters.

Data that directly identifies you such as your name, username, email address and location data.

Consent

Register you as a user of our Services and other products and services and administer your Account.

Data that directly identifies you (such as your name, username, and email address and other information included in your user profile).

Creation or performance of a contract

Publish content on our Services including articles, feedback, reviews and user comments about our posts.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information included in your user profile).

Creation or performance of a contract

Fulfill orders for subscriptions, products or services placed through our Services.

Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.

Creation or performance of a contract

Collect money you owe us.

Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.

Legitimate interest

Verify or obtain payments due to us when you buy something from a third party after clicking on an “affiliate” link in our content, measure the performance of affiliate links, analyze and develop this part of our business.

Data that indirectly identifies you (such as your IP address or mobile device ID) or data that directly identifies you (such as your name, username, email address and location data).

Legitimate interest

Communicate our terms, notify you about changes to them and communicate with you about non-compliance.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username and email address).

Creation or performance of a contract

Communicate our Privacy Policy and notify you of changes to them.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username and email address).

Compliance with a legal obligation

Conduct surveys or undertake similar types of research so that we can improve and develop our business, our Services.

Data that directly identifies you (such as your name, username, name, email address and location data)

Consent

Allow you to take part in a prize draw, sweepstake, or other competition or other promotional activity.

Data that directly identifies you such as your name, username, and email address.

Creation or performance of a contract

Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganization, including exchanging information with third parties for fraud protection and spam/malware prevention.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address).

Legitimate interest

Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganization, including exchanging information with third parties for fraud protection and spam/malware prevention.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address).

Consent

Communicate with you about our services that you sign up to receive when you create an Account and transactions that you conduct using our services, including published content you visit, content you submit for publication on Flavour Ads, and content posted by you on Flavour Ads (including your comments on content, feedback and reviews).

Data that directly identifies you such as your name and email address.

Creation or performance of a contract

Comply with applicable laws, regulations and legal and regulatory processes.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and/or data that directly identifies you (such as your name, username, and email address).

Creation or performance of a contract

14.2 Legal rights for EEA and UK users


If you are an EU or UK resident, you have certain rights in respect of the information that we hold about you. Below is a short overview of those rights:


Access


With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.


Correction


You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as views expressed in editorial content.


Deletion


In some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).


Objection


You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.


Withdrawing Consent


If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.


14.3 How to exercise your rights


To exercise your rights, email data-privacy@flavourads.com. In order to protect your privacy and that of others, we will ask you to prove your identity before we take any steps in response to a request you have made. If a third party is making a request on your behalf, we will ask them to prove that they have your permission to act for you.


We may contact you to ask you for further information to help you exercise your legal rights or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request, we will explain why.


14.4 Complaints


You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. You can contact the ICO on 0303 123 1113. We invite you to raise your concerns with us first, so that we can try to resolve them.

@ Copyright 2021 - FlavourAds Limited | All rights reserved

21 Clare Road, Halifax, West Yorkshire, HX1 2HX