Legal notices

Privacy policy

Last updated: 21 July 2024
This is a translation for convenience. In the event of any discrepancy, the Spanish version prevails.
Contents
  1. 1. Privacy policy
  2. 2. What data do we collect?
  3. 3. How we use your data
  4. 4. What is our legal basis for processing your information
  5. 5. How do we share data?
  6. 6. Automation and profiling
  7. 7. Advertisers and analytics providers
  8. 8. Cookies and similar technologies
  9. 9. Your choices
  10. 10. Data security
  11. 11. Protecting the privacy of minors
  12. 12. How long we keep your information
  13. 13. Your rights
  14. 14. Contact
  15. 15. Additional information for certain jurisdictions

Privacy policy

At FEEBERSE we take your privacy very seriously. We want you to know how we collect, use and share your personal data in order to give you a safe and personalized experience.

The Data Controller is REACHAT MARKETPLACE INC, with registered address at no. 1600, 63rd St., Brooklyn, New York (11204-2713), USA, EIN 85-1700130, contact dpo@feeberse.com.

What data do we collect?

We collect information that you provide to us, such as your name, email address, telephone number, date of birth, country of residence, profile picture or language.

We also collect information about your activity on the Platform, such as your status, your service usage history, connections and interactions with other users, the content you share, the date and time of your use or visit, information about the links you access, the pages you view, and the advertising you interact with within our services, inferences used to build a profile of your preferences and characteristics, registration information, time of use, transactions and friends on the platform; chats and interactions may be monitored and stored; specific information about your device and across your devices, for example: model, serial number, operating system, device settings, device performance, advertising and device identifiers, Internet service provider, IP address and other unique network or personal identifiers.

In the case of paid subscriptions or any other service or purchase you make on the Platform, the data will be stored in Google Pay and/or Apple Pay's own systems.

In the case of monetization payments on the platform, the IBAN of the destination account, account authentication information and billing and contact information such as your tax identification number, billing address and shipping address.

With your consent, we may collect and process information about your precise location. When we obtain information about your location, we use it to tailor our services for you and for others.

Please note that we need certain types of information in order to be able to offer you the Platform Services. If you do not provide us with such information or you ask us to delete it, you may no longer be able to access or use our Services.

Information provided directly by the User: When you register to use the Platform Services; upload videos or content, purchase, view or download certain content or products from the Platform Services; take part in challenges; register for or otherwise use the features and functionalities of the Platform Services, you may provide us with a variety of information about yourself, such as your name, voice or image (in any content you upload, transmit or take part in), Platform username, email address, postal address, telephone number, credit card number and billing information.

Information generated when you use our services: When you use our services, technical data is produced relating to the features used, the way you use them and the devices from which you access them. This information is detailed below:

Information from Other Sources: In addition to the information you can provide to us directly, we receive information about you from third parties, including:

Users

Users may provide information about you as they use our services, for example when they interact with you or if they submit a report involving you.

Social networks

You may decide to share information with us through your social media account, for example if you decide to create an account and log in to it through your social networks or another account (for example, Facebook, Google or Apple) or to upload information (for example, photos) to our services from one of your social media accounts (for example, Facebook, Instagram, etc.). When you access the Platform Services through social networks or when you connect the Platform Services to social networks, you are authorizing the Platform to collect, store and use such additional information and content in accordance with this Privacy Notice. We use this information to supplement the information we collect about you in order to provide you with more relevant and safer experiences on the Platform Services and to improve the Platform Services, analytics and advertising. If we combine or associate information from other sources with the information we collect through the Platform Services, we will treat the combined information in accordance with this Privacy Notice.

How we use your data

We use your information to operate, maintain, improve, provide, create and develop all the features, functionalities and services (whether new or existing) found in the Platform Services; provide security for our website, products, software and applications; manage relationships with Platform account holders, including making or receiving payments; improve users' experience of the Platform by delivering content recommendations and presenting content that we hope users will find relevant and interesting, including advertising and marketing messages; allow you to comment on content and take part in online games, contests or reward programmes; prevent fraud and abuse; and understand our users' usage trends.

We use your email address and/or telephone number to communicate with you, including notifying you about important updates to the Platform Services, for customer support purposes or to contact you in relation to any content you have posted or downloaded from the Platform Services.

The Platform may periodically send promotional materials or notifications relating to the Platform Services. If you wish to stop receiving promotional materials, you can go to your account settings once you have logged in to the Platform Services or follow the unsubscribe instructions at the bottom of any email from us. If you have installed a mobile application and wish to stop receiving notifications, you can change the settings on your mobile device or through the application.

In order to comply with legal obligations, we may collect and process user information if we believe in good faith that such collection and processing are necessary to comply with US state and federal laws or other applicable laws worldwide (for example, in your country of residence), or to respond to a court order, judicial request or other government request, subpoena or order as legally required.

The Platform has the appropriate legal bases to process your personal information to the extent permitted by applicable law, which may include, without limitation: fulfilling contractual commitments, taking steps prior to entering into a contract, complying with legal obligations, documenting your consent and supporting the Platform's legitimate interests. Some examples of these legitimate interests include: monitoring and analysing the use of the Platform's services, communicating with registered users through notifications or emails about the Platform's products and services, advertising, responding to enquiries or complaints from prospective or current Platform users, taking appropriate or necessary measures to protect the Platform from potential liabilities or from fraudulent, abusive or illegal uses; investigating and defending ourselves against third-party claims or allegations; protecting the security or integrity of the Platform Services; or protecting the rights, property or safety of the Platform, our users or others.

Below we set out what we use your information for, together with specific examples.

What is our legal basis for processing your information

The legal basis for processing your data rests on several legal grounds established in the GDPR and the LOPDGDD (the Spanish Data Protection Act). These grounds may include:

User Consent: Most of the processing of your data on the Platform is based on users' consent. Users give express consent to the processing of their personal data when they register on the platform and accept the terms and conditions, including the privacy policy.

Performance of a Contract: In the case of payments for additional services, the processing of data may be based on the need to perform a contract entered into with the user. This includes the processing of data relating to payment transactions.

Compliance with a legal obligation: Processing is necessary to comply with a legal obligation applicable to the data controller.

Protection of vital interests: Processing is necessary to protect the vital interests of the data subject or of another natural person.

Legitimate Interest: The Platform may base the processing of data on its legitimate interests, such as providing and improving its services, ensuring the security of the platform and carrying out analysis for business purposes, provided that the user's fundamental rights and freedoms are not overridden. The Platform balances the company's legitimate interests against users' fundamental rights and freedoms and considers various factors, such as the nature of the personal data, the impact on the user's privacy, the context in which the data is collected and the existence of appropriate safeguards.

Exercise of public functions or public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

Here is a summary of our Platform's main legal bases:

Data processing activityLegal basis for the processing
Providing Platform services (for example, creating an account, sharing content and connecting with other users) Performance of a contract: the processing is necessary to perform the terms of service contract
Improving, personalizing and developing the Platform (for example, analysing user activity to improve the user experience and develop new features) Legitimate interest: the processing is necessary for the Platform's legitimate interests, provided that the user's fundamental rights and freedoms are not overridden
Complying with legal obligations (for example, responding to requests from government authorities) Compliance with a legal obligation: the processing is necessary to comply with legal obligations
Protecting the vital interests of users or of other people (for example, in the event of a medical emergency) Vital interest: the processing is necessary to protect the vital interests of users or of other people
Carrying out investigations and preventing illegal or harmful activities (for example, fraud, abuse or harassment) Legitimate interest: the processing is necessary for Instagram's legitimate interests, provided that the user's fundamental rights and freedoms are not overridden
Sending personalized advertising and carrying out direct marketing activities (for example, sending emails or push notifications) Consent: the processing is based on the user's consent, which may be withdrawn at any time. Other legal bases, such as legitimate interest or compliance with a legal obligation, may also be used in certain circumstances.
Sharing information with third parties (for example, affiliated companies, service providers and advertising partners) Legitimate interest: the processing is necessary for the Platform's legitimate interests, provided that the user's fundamental rights and freedoms are not overridden. Other legal bases, such as consent or compliance with a legal obligation, may also be used in certain circumstances

With your consent or at your request

We may ask for your consent to share your information with third parties. In that case, we will explain the reason for sharing that information.

We may use and share non-personal information (that is, data that on its own does not identify you, such as device information, general demographic data, general behavior, anonymized geolocation) and personal information in encrypted and unreadable form in the circumstances mentioned above.

We may also share this information with third parties (especially advertisers) in order to develop and deliver targeted advertising on our services and to analyze and report on the advertising you see. We may combine this information with additional non-personal data or with encrypted and unreadable personal information collected from other sources. You can find more details about our use of cookies and similar technologies in our Cookie Policy.

How do we share data?

Information about Platform users is an important part of our business and of our effort to deliver the best experience on the Platform services.

We firmly assure you that your information is not sold, and we undertake to keep that position unchanged.

We share your data with third parties only in the circumstances described in our privacy policy. For example, we may share your data with our service providers, such as analytics and payment processing companies, in order to provide you with the Platform and process your payments.

With service providers

We disclose such information to service providers working on our behalf, for example to: provide website hosting, maintenance and security services; carry out data analysis and create reports; offer certain functionalities; or help the Platform improve the Platform Services and create new services and features. We require these parties to treat such information in accordance with this Privacy Policy, we authorize them to use the information only for the purposes for which it is provided to them and we require them to use reasonable confidentiality and security measures.

We select these providers carefully following a rigorous assessment process. They must undertake to maintain the confidentiality of the information shared.

Other users

When you voluntarily share information on the Platform you are disclosing data to other users. It is important to be aware of the information you share and to make sure you are comfortable with its visibility.

If you decide to restrict who can see your full profile or certain content or information about you, these restrictions will apply in accordance with your privacy settings.

If we receive a report in which you are involved, for example for an alleged breach of our Terms of Use or Community Guidelines, we may inform the reporting party about the actions taken, if any, as a result of their report.

In corporate transactions

Your information may be disclosed if we are involved in a merger, sale, acquisition, divestment, restructuring, reorganization, dissolution, bankruptcy or change of control or ownership.

With the legal authorities / where required by law

We may disclose your information if it is reasonably necessary: (i) to comply with legal processes, such as court orders, subpoenas, government or police investigations or other legal requirements; (ii) to assist in the prevention or detection of crime (as permitted by law); or (iii) to protect the safety of any person.

The Platform may disclose user information if we believe in good faith that such disclosure is necessary to comply with US state and federal laws or other applicable laws worldwide (for example, in your country of residence), or to respond to a court order, judicial request or other government request, subpoena or order as legally required.

The Platform also reserves the right to disclose information that we believe, in good faith, is appropriate or necessary to protect the Platform from potential liabilities or from fraudulent, abusive or illegal uses; to investigate and defend ourselves against third-party claims or allegations; to protect the security or integrity of the Platform Services; or to protect the rights, property or safety of the Platform, our users or others.

To protect legal rights

We may also share information: (i) if doing so could reduce our liability in actual or potential litigation; (ii) to protect our legal rights and those of our users, business partners and other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent or take action regarding illegal activities, suspected fraud or other wrongdoing.

Automation and profiling

These tools are essential to the services you enjoy and help us optimize them. Without them, we could not offer you profiles of interest.

We use them for several reasons:

To make it easier for users to connect and to suggest other users to you.

To feed our algorithm and suggest profiles of interest to you.

To present you with relevant advertising and offers.

To promote safety.

Automation and profiling are part of our moderation tools (such as bot detection) to ensure user safety and to act more quickly and effectively against illegal or inappropriate behavior.

Users who behave inappropriately may face penalties, including the suspension or closure of their account, among other legal measures.

Advertisers and analytics providers

In order to improve the user experience and advertising effectiveness on the Platform Services, we may make use of tracking and analytics technologies provided by third parties.

We also work with advertising networks and advertisers, as well as with advertising analytics providers, with the aim of offering you more personalized advertising both within and outside the Platform Services. To that end, we share certain data, such as cookies and mobile advertising identifiers, with these third parties, who may collect it directly in order to facilitate advertising activities. This helps us understand your interaction with ads and ensure the relevance of the advertising you receive.

When Advertisers or their representatives or service providers send ads directly to your devices through our platform, they automatically collect certain data, such as your IP address, and may use cookies or similar technologies. These practices help measure the effectiveness of ads and personalize advertising content. It is important to note that this Privacy Notice does not cover the tracking practices and technologies used by the Platform's advertisers, which operate outside our control. We encourage you to review their respective privacy policies for more information.

If you do not want to receive this type of advertising, we invite you to visit Privacy Settings.

Cookies and similar technologies

Resettable device identifiers (also known as advertising identifiers) are similar to cookies and are found in many mobile devices and tablets (for example: the "Identifier for Advertisers" [IDFA] on Apple iOS devices or the "Google Advertising ID" on Android devices), and in some streaming devices. Like cookies, resettable device identifiers serve to present online advertising that is more relevant to the user and for analytics and optimization purposes.

The Platform uses various technologies for numerous reasons that are essential to the provision and improvement of our services.

These technologies include cookies and device identifiers, used in order to:

Below we explain how we use cookies and resettable device identifiers:

The Site has enabled the Google Analytics services provided by Google LLC, an entity located in the USA and adhering to the Commission's Adequacy Decision of 10 July 2023, the EU-USA Data Privacy Framework, which makes it possible for the personal data of European citizens to flow to the USA. Interaction with users through the use of that tool involves the use of analytical and technical data in relation to the Site, provided that you have accepted the enabling of such cookies through the settings panel.

The Platform adheres to self-regulation programmes such as Home - European Interactive Digital Advertising Alliance (edaa.eu) in Europe, offering options to manage privacy and consent for cookies and similar technologies.

Users have various ways of exercising control over these technologies, including specific settings in browsers and devices to limit or prevent interest-based advertising tracking.

To exercise choices about these technologies, users can change the privacy and advertising settings on their devices or consult our resources for more information about managing cookies and similar technologies, thereby ensuring an experience that is personalized and aligned with their preferences.

For more information about the cookies set on our website, see our Cookie policy.

Your choices

You have several choices about how we use your data on the Platform. You can control what information you share with us and with other Platform users, and you can opt out of receiving marketing emails.

If you do not wish to receive personalized advertising, you can adjust your advertising preferences in your account settings. However, you should bear in mind that this does not mean you will stop receiving ads altogether, but rather that those ads will be less relevant to you.

In addition, you can exercise your privacy rights under applicable laws, such as the right to access, rectify and delete your personal data.

Data security

We strive to protect your personal data through appropriate technical and organisational measures. This level of security is determined taking into account technological progress, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as the varying risks to the rights and freedoms of individuals. In addition, appropriate mechanisms are put in place to safeguard personal information against unauthorized access, improper removal, unlawful alteration and loss of data. Nevertheless, no precaution and no system can be completely secure. We cannot guarantee or certify the security of the data you transmit to the Platform, so when you transmit your data, you do so at your own risk. We cannot guarantee that such data may not be accessed or that such data may not be disclosed, altered or destroyed in breach of any of our physical, technical or organisational safeguards

Protecting the privacy of minors

Our services are restricted to people over 16 years of age. We do not allow people under 16 to access our platform. If you suspect that a user is under 16, please use the reporting mechanism available in the service.

How long we keep your information

The Platform keeps information linked to your interaction with us for as long as is necessary to fulfill the purposes mentioned in this Privacy Notice, as well as to meet the requirements (or permissions) of the regulations in force, such as accounting and tax obligations, or any other purpose of which we have previously informed you. When you request the closure of your account and the deletion of your profile data, we will delete all data that the law does not require us to retain. If your account remains inactive for two years, we will close it automatically.

After that, we will delete your personal information as explained below:

To ensure the safety of our users, we apply a three-month security retention period after the account is closed. This time allows us to keep your information in case we need to investigate illegal or harmful actions. Retaining data during this period is based on our legitimate interest and that of potential victims.

At the end of the security retention period, we delete your data. However, we retain certain limited information for specific purposes, as detailed below:

Because of legal obligations, we keep transaction data for 10 years in order to comply with tax and accounting requirements. We may also need to retain traffic data or logs for 1 year in order to comply with legal data retention obligations. In addition, we keep records of the consents granted for 5 years in order to demonstrate compliance with applicable legislation.

On the basis of our legitimate interest, we retain customer service records and backup data, as well as the approximate location of the download/subscription, for five years in order to support customer service decisions, exercise our rights and defend ourselves in the event of claims, and profile data for one year in anticipation of possible litigation. We also keep data that is necessary to prevent expelled users or users under 16 from creating new accounts, ensuring the safety and wellbeing of our users.

Finally, we keep information on the basis of our legitimate interest when there is a pending problem, claim or dispute that requires the data to be retained, especially if we receive a legal subpoena or a request that obliges us to retain the data in order to comply with our legal obligations or if the data is necessary as part of legal proceedings.

Your rights

We want you to be in control of your information, so we would like to remind you of the following options and tools available to you:

Access / Update tools in the service. The account tools and settings can help you access, rectify or delete the information you provided to us that is associated with your account directly within the service. If you have any questions about those tools and settings, you can contact our customer support team for help here.

Device permissions. Mobile platforms may have permission systems for specific types of device data and notifications, such as phone contacts, images, location services, push notifications and advertising identifiers. You can change the settings on your device to give your consent to or object to the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do so, certain services may lose functionality.

Uninstall. You can stop all collection of information by an application by uninstalling it, using the standard uninstall process for your device. Remember that uninstalling an application does NOT close your account. To close your account, use the corresponding functionality in the service

Account closure. You can close your account using the corresponding functionality directly in the service.

We also want you to know your privacy rights. We will deal with any valid request to exercise data rights in accordance with the legislation applicable in your region. However, please note that in certain circumstances we will have to continue processing your data for legitimate purposes or to comply with our legal obligations. If these rights apply to you, you can ask us for the following:

To obtain access to the personal information we hold about you or obtain a copy of it

To stop processing your personal data for direct marketing purposes (including any direct marketing processing based on profiling)

To update your outdated or incorrect personal data

To delete certain personal data we hold about you

To restrict the way we process and communicate specific personal information we hold about you

To transmit your personal data to an external service provider

To withdraw the consent you have given to process your personal data

To protect you and all our users, we may ask you to provide proof of identity before we can respond to the above requests.

Please note that we may refuse requests, including in cases where we cannot authenticate you, if the request is unlawful or invalid, or if it could infringe trade secrets or the intellectual property, privacy or other rights of another person.

In certain countries, including those in the European Economic Area and the United Kingdom, you have the right to lodge a complaint with the relevant data protection authority if you have concerns about how we handle your personal information. You can find information about your data protection regulator in the European Economic Area here and in the United Kingdom here. The data protection authority with which you can lodge a complaint may be the one for your habitual residence, the one for the place where you work or where an alleged infringement took place. Alternatively, you may go to the local courts if you consider that your rights have been infringed.

Contact

If you have questions or concerns about our privacy policy or about how we handle your personal data on the Platform, contact us through the channels provided on the Platform.

Changes to the privacy policy: The Platform may update its privacy policy from time to time and will notify users about material changes.

Additional information for certain jurisdictions

The Platform operates internationally, and some of the processes involved in our use of your information require your information to be stored or processed in countries outside the country where you are located, including countries where the level of legal protection for your information may be different.

Additional State-specific privacy disclosures.

This State-specific privacy disclosure page supplements the Platform's Privacy Policy. That Policy sets out the personal information we collect, the sources it comes from, the purposes for its use, the circumstances under which we share personal information on a limited basis and the recipients of that information.

This additional information, required by the privacy rules of various states in the USA, including California, Colorado, Connecticut, Utah and Virginia, serves as Information about data processing under The California Privacy Rights Act of 2020 (CPRA).

Additional Rights Under the CPRA: There are other specific rights granted by the CPRA to California residents, such as the right to correct inaccurate personal information, the right to limit the use and disclosure of sensitive personal information, and the right to opt out of automated decision-making, including profiling.

Right of Appeal: users have the right to appeal if the Platform refuses their request to exercise any of the rights under the CPRA.

Contact Information for Privacy Rights: Providing specific contact information (for example, a link to a web form, an email address or a telephone number) so that California residents can exercise their rights under the CPRA.

Transfers based on an adequacy decision

Where the entities receiving the data are located in a country, a territory or one or more specific sectors of that country or international organization that have been declared to have an adequate level of protection by the European Commission. To date, the following countries and territories have been declared adequate:

Your privacy

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