Privacy Policy

1. OBJECTIVE OF THIS PRIVACY POLICY

The words below whose first letters are capitalized will have the meanings which are defined for them in the General Terms and Conditions of the Fowllow.com site.

The personal data that we collect is subject to the regulations set out in the French “Informatique et libertés” law of 6 January, 1978, amended in 2004, and to all other applicable legislation and regulations.

For personal data collected in France, the data controller is Tripnity, a simplified limited company (société par actions simplifiée) under French law, capitalized at €150,000, headquartered at 90, route du Palais 87000, Limoges, France, registry number 480 850 346 at the Paris Registre du Commerce et des Sociétés.

The present privacy policy describes the personal data that we collect, the reasons for and the means of collecting, the ways in which we use the data, and under which circumstances we will share it with third parties.

2. PERSONAL DATA

2.1 Collection of Personal Data

We collect personal data about you such as your family names, first names, billing address, email address, and phone numbers, limited to what you have agreed to tell the Site in order particularly to publish your Content, create your Account, organize a Photo Contest, participate in a Photo contest, or to post comments.

In cases where the entry of certain personal data is absolutely required for us to carry out a Service, we will indicate that.

2.2 Use of Your Personal Data

We use your personal data with the following goals in mind:

- to allow you to benefit from the Services offered by Fowllow.com;
- to improve the quality of the Site, of the Services, and of the functionality of the Services;
- to provide you personalized service;
- to manage the Site internally;
- to understand our visitors better in order to help satisfy them;
- to let us identify you in order to contact you;
- with your consent, if it is required by law, to contact you by email/SMS/post with information about our Services and/or contests.

If you no longer wish to receive commercial marketing information from us, you can at any time unsubscribe from our list by clicking on the link at the bottom of the emails.

2.3 Sharing of Personal Data

Fowllow.com may share your personal data: (i) with affiliated companies or subsidiaries of Fowllow.com in order for them to use it for the same reasons as indicated above, and/or with third parties, on condition that you have expressedly consented to these sharing arrangements; (ii) with service providers acting on its behalf; (iii) with a third party in order to comply with a legal obligation; or (iv) in the event of a transfer of ownership or merger if you have expressedly consented to the transfer or merger.

2.4 Duration of the Personal Data Retention Period

We undertake not to retain your personal data longer than the length of time necessary to manage the commercial relationship.

In the event that your account becomes inactive, the personal data associated with your account will be automatically deleted after three years, except for that data which we would need to preserve as proof, for legal or administrative needs, or in order to comply with applicable legislation.

3. Links

On the Site you will find various links that direct you to third party sites. Fowllow.com cannot be held responsible for links posted by the Users, nor for the privacy policies of these third parties. The General Terms and Conditions of the Fowllow.com Site, and in particular the privacy policy, do not govern third party sites or content of third parties accessed by Site Users.

4. Use of cookies

4.1 Placing of Cookies

We can deposit information about how your computer navigates our site onto your computer, by storing data files on it. These files are called “Cookies.”

4.2 Use of Cookies

When you access our Site for the first time, a scrolling banner automatically appears at the bottom of the page. The presence of this banner aims to inform you about the use of Cookies by our site and to ensure that you consent to the presence of some of them.

We only use three types:

- Functional Cookies to make sure our site functions;
- Statistical Cookies to measure the audience on our site;
- Marketing Cookies, targeted marketing support, coming from third parties.

The marketing Cookies require your explicit consent, which is why we request your consent for them to be deposited on your computer, and on your first visit to our site.

4.3 Duration of Cookie Preservation

In compliance with the recommendations of the Commission Nationale de l'Informatique et des Libertés, Cookies are not preserved longer than 13 months after their first deposit in the User's terminal equipment. At the end of this time period, they are deleted, and consent, if needed, will be sought anew.

4.4 Refusal of Cookies

Browser settings can be configured to inform the User of the presence of cookies, and even to refuse them. It therefore falls to Users themselves to set their browsers to refuse cookies.

To do that, Users may follow the following recommendations:

For Mozilla Firefox:

- Go to the “Tools” menu, and then to “Options”; - Click on the “Privacy” icon; - Locate the “Cookies” subsection and select the options that suit the User.

For Microsoft Internet Explorer:

- Go to the “Tools” menu, and then to “Internet Options”;
- Click on the “Privacy” tab;
- Select the preferred level using the slider.

However, users are informed that it is possible that after having blocked cookies, certain pages on the Site will no longer be available to them.

5. DATA SECURITY

Fowllow.com maintains the confidentiality of your personal data. Fowllow.com uses technology, which is secure to industry standard to protect the content and the privacy of Users. All Fowllow.com staff have a duty to respect User confidentiality. A confidentiality obligation is included in every employment contract of Fowllow.com, employees who have access to the personal data, as well as in those with its subcontractors.

6. CNIL DECLARATION

In accordance with the French “Informatique et libertés” law of 6 January, 1978, amended by the law of 6 August, 2004, the processing of your personal data collected via the Site has been declared to CNIL under number 1513594 v 0.

7. CHANGES TO THE PRIVACY POLICY

Fowllow.com may modify or amend this privacy policy. All changes or amendments will come into force from the date of posting on the Fowllow.com Site. Your continuing usage of the Site after the publication by Fowllow.com of an updated version of the Privacy Policy implies that you consent to the Privacy Policy, as modified. Consequently, it is important that you regularly read this Privacy Policy to make sure that you are fully aware of all the changes that may have been applied to it.

8. RIGHTS OF OPPOSITION, ACCESS, RECTIFICATION AND DELETION

Pursuant to French “Informatique et Libertés” law no. 78-17 of 6 January, 1978, each User possesses rights of access, modification, rectification and deletion of personal data which concerns him or her.

Users may also, at any time, access their data in order to modify, rectify, or totally or partially delete their personal data, by logging into their accounts and using the “delete account” function.

Users may also modify or delete their personal data by sending an email to [email protected].

Users must include with all communication their Login Credentials, a photocopy of their official identification document with photo, as well as details on the modifications and/or deletions that they wish to carry out.

9. APPLICABLE LAW

The current privacy policy is part of the General Terms and Conditions of the Fowllow.com Site, and as such, it will be governed by and construed in accordance with the laws of France, without regard to conflict of laws principles.

10. CONTACT

If you have any questions about this Privacy Policy, or questions about the use of the Site, please contact us by email at the following address: [email protected].