We collect personal information to provide you with our Services. When we require certain personal information from users it is because such information is relevant for specified purposes. Any information you provide to us that is not required is voluntary.
For example, we collect personal information when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for a FULOOS event or webinar. We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you.
In addition, we may collect personal information disclosed by you on our message boards, chat features, blogs and our other services to which you are able to post information and materials. Any information that is disclosed in those forums becomes public information and may therefore appear in public ways, such as through search engines or other publicly available platforms, and may be "crawled" or searched by third parties. It could also be read, collected or used by other users to send you unsolicited messages. Please do not post any information that you do not want to reveal to the public at large.
You are free to choose whether to provide us with the types of personal information described below, but we may not be able to serve you as effectively or offer you some or all of our Services when you choose not to share certain information with us.
Here are some examples of the types of personal information FULOOS collects and how we may use it:
When you create an account or use FULOOS Services, we, or our affiliates' vendors acting on our behalf may collect the following types of information: your name, date of birth, email that you link to your Fuloos Account or input when you use FULOOS Services. FULOOS will use this information to fulfill your requests and provide the relevant Services.
Whenever you contact us or respond to our communications (e.g., email, telephone, written), we receive your contact information and any other personal information you choose to provide us. FULOOS will use such information to fulfill your requests or to provide Services.
You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorisation.
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how we may use this information include:
To provide you with FULOOS Services and customer support that you request.
To process transactions and send notices about your transactions.
To verify your identity by comparing your personal information against third-party databases.
To send administrative or account-related information to you.
To better understand our customers and end-users and the way they use and interact with FULOOS-owned or -operated websites, mobile apps, and Services.
To provide a personalised experience, and implement the preferences you request.
To customise, measure, and improve FULOOS Services and the content and layout of our website and applications.
To enhance security, prevent fraud, monitor and verify identity or service access, combat spam or other malware or security risks.
To deliver targeted marketing, service update notices, and promotional offers based on your communication preferences (where this in accordance with the law).
To communicate with you about our events or our partner events.
To prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms.
To resolve disputes, collect fees, and troubleshoot problems.
To comply with legal obligations.
To enforce our agreements with third parties.
For quality control and staff training.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may choose not to have your personal information shared with third parties where we rely on consent as the lawful basis for processing your personal information. You may also choose not to allow us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features or FULOOS Services may not be available to you.
We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.
For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognise you when you arrive at the Site via an external link, such as a link appearing on a third party site.
We understand how important your privacy is, which is why FULOOS maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.
We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the United States and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to FULOOS or Fuloos staff.
However, we cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account.
We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. FULOOS will never sell or rent your personal information. We will only share your data in the following circumstances:
We share your information with third party identity verification services in order to prevent fraud. This allows FULOOS to confirm your identity by comparing the information you provide us to public records and other third party databases.
We may share your information with service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
We share your information with financial institutions with which we partner to process payments you have authorised.
We may share your information with companies or other entities that purchase FULOOS assets pursuant to a court-approved sale under U.S. bankruptcy law and / or where we are required to share your information pursuant to insolvency law in the U.K. or in any other jurisdiction;
We may share your information with any third parties where required to do so by applicable law or any court or other authority to which we are subject in any jurisdiction; or we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of the FULOOS User Agreement and any other applicable policies.a
We may share your information with other third parties with your consent or direction to do so.
If you establish a FULOOS Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a FULOOS website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies.
If you use your FULOOS Account to transfer Digital Currency in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to transfer Digital Currency to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
In connection with a Digital Currency transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a FULOOS customer, that Digital Currency transfers are enabled, and/or to notify you that you have received Digital Currency. If you request that we validate your status as a FULOOS customer with a third party, we will do so. You may also choose to send Digital Currency to or request Digital Currency from an email address. In such cases, your user name will be displayed in an email message notifying the user of the designated email address of your action.
Please note that merchants you interact with may have their own privacy policies, and FULOOS is not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, which may include such things as contact details or location data, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
If you authorise one or more third-party applications to access your FULOOS Account, then information you have provided to FULOOS may be shared with those third parties. Unless you provide further authorisation, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using FULOOS Services.
You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab. This right shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.
Rights of access, correction and deletion
You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
Right to object
You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us as set out below.
FULOOS will retain your personal data for as long as is necessary for the purposes of our business relationship with you, to perform our contractual obligations to you, or if longer, as required for legal and regulatory purposes.
We have established internal policies for the deletion of data from customer accounts following termination of a customer's subscription to the Service.