Privacy policy 

This Privacy Policy is part of the Terms and Conditions and applies to sites in the Open Fanclub network In order to use this Site, but also the Android Application, it is necessary to read and accept these rules in full. Your continued use of the Site and Application implies that you agree to these rules. The Open Fanclub team ensures, in accordance with the law, the preservation of the confidentiality of the User's personal data and the observance of his right to the protection of privacy. 
  1. DATA COLLECTED
    • In order to provide the Services, we will process certain personal data such as: name and surname, date of birth, sex, e-mail, telephone, location, place of residence, data related to the interaction with Open Fanclub, standard internet authentication information, data traffic, type, version and language of the browser, access times and IP addresses, information related to the quality and use of the Site and / or the Application, statistics related to the installed applications. 
    • If you give us your consent, we will process the geolocation to autocomplete the city you are in (dynamic information that changes with the change of your location if you use a mobile device) and to be able to suggest people from nearby. We also request this information for the accuracy of the information (eg if there are localities with the same name). If you do not give us permission to collect this information, we will not do so and you may continue to use our services.
    • Certain information, comments or content (eg photos, profile, lifestyle) that the User provides optionally, under the responsibility and initiative of the User in question, discloses the family situation, economic and financial situation, ethnic origin, racial origin the political belief, the religious beliefs of the User and / or the sexual orientation. By providing such optional information, the User expressly consents to the processing of these special categories of personal data. 
    • In order to manage the Site and to facilitate improved navigation, both the Site Administrator and our service providers have a legitimate interest in using cookies or web beacons (electronic images that allow this Website to count visitors who have accessed a certain page and access to certain cookies) to collect aggregate data. The use of cookies is made to allow the correct display of content, the creation and retention of authentication data, the personalization of the interface, for example the language of use of the service, the improvement of the service, by implementing and testing technical solutions. You can obtain additional information about how we use cookies and other tracking technologies and how you can control them in the Cookie Policy. 
    • These Services can offer you the facility to connect (create new account and / or login) using your account on social networks: Facebook, Google. We are not responsible for the use, misuse or improper retrieval of any personal data or other information with which you contribute to any Social Media Application. 
    • We may monitor any disputes between Users, in the event that there is an obligation provided by law in this regard or if a User reports an abuse. If the abuse is reported through the messaging service, the User assumes and understands that part of the reported conversation will be verified by the Open Fanclub team. 
    • We offer you control over the data we collect, both from the Application and on the Site. Each User has the possibility to deactivate the collection of certain personal data related to the quality and use of other applications or of the Open Fanclub Application, in case you use the Application, but also to deactivate the notifications. 
    • NOTE: If you choose to disable the push notifications received through the Application, the Site Administrator will still have the opportunity to send webpush notifications or e-mails, if the User does not expressly waive these options.
    • We inform you that stopping these preferences will have an impact on the level of customization that Open Fanclub can offer you. 
  2. WHAT KIND OF INFORMATION ABOUT USERS IS PUBLIC?
    • Certain personal data uploaded by Users through Open Fanclub and may be accessible to members / visitors, by accessing the profile page of each User or through listings. Users have the opportunity to edit, at any time, the content of the profile page and thus choose which categories of personal data they want to be displayed on the profile page. 
    • Some of the information that Users provide when completing the profile is public, and can also be seen by people who do not use the Open Fanclub services. Your public profile includes username, gender, profile picture, age, etc. 
    • Regarding the visibility of the public profile in search engines, the Site Administrator has no control over the content already indexed and stored in the cache of search engines. To request the immediate removal of this search list, you will need to contact the specific search engine support team. Unfortunately, the Site Administrator cannot send on behalf of the Users, requests to remove the content already indexed in the memory of these search engines. We apologize for any inconvenience this may cause. To support users, we provide you with the contact details of the appropriate support teams: Google, Bing, Yahoo
  3. THE PURPOSE OF PROCESSING PERSONAL DATA
    • We inform you that the personal data you provide to the Site Administrator are processed for the purpose of offering, providing and functioning in optimal conditions of the Site and the Application, but also for the purpose of their development. Thus, the Site Administrator will process your data for: 
    • providing a social network; 
    • improving the content offered, based on an understanding of the patterns that describe the use of the Site and the Application; 
    • compliance with the legal obligations of the Site Administrator (such as reporting obligations to state authorities); 
    • in order to comply with court decisions and in order to exercise and / or defend our rights and interests; 
    • securing the service, to protect users against fraud or identity theft; 
    • correct use of the service provided; 
    • to allow the distribution of the content of the offered service; 
    • complete services requested by Users, for example to manage participation in contests, games, surveys, including to allow and consider the transmission of feedback by Users;
    • creating personalized offers through the analysis of users' preferences, behaviors and interests in order to obtain the targeted content or offer from Open Fanclub; 
    • managing performance issues for low-performance phones; 
    • improving the performance of the Site and / or the Android Application and its design ;
    • offering personalized recommendations; 
    • informing the Users regarding the situation of their account; 
    • commercial activities, promotion of products and services, marketing, advertising, media, administrative, development, market research, statistics, tracking and monitoring of sales and consumer behavior.
  4. 4.    Legal bases for the processing of personal data 
    • Any operation of processing the personal data provided by the Site Administrator will be performed on the basis, in compliance with the applicable legal provisions, according to one of the following grounds: 
      • for concluding or executing a contract to which the User is a party; 
      • to comply with a legal obligation of the Site Administrator; 
      • based on the consent of the Users; 
      • Processing is necessary to protect the vital interests of you or another individual; 
      • for the purpose of the legitimate interests of the Site Administrator or of a third party;
      • for finding, exercising or defending a right in court; 
  5. DISCLOSURES OF PERSONAL DATA
    • Because our goal is to help you make meaningful connections, the primary distribution of user information is, of course, with other users. We also share information with users, with service providers and partners who assist us in operating the services and with legal authorities. 
    • With other users. Share information with other users when you voluntarily disclose information on your public profile. Please pay attention to your information and make sure that the content you share is a matter that you are comfortable viewing in public, as neither you nor we can control what others do with your information once it is shared. 
    • With our service providers and partners. We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including hosting and data maintenance, audience analysis (Google Analytics), customer support (Zendesk), marketing and advertising services (Google AdWords and Facebook Ads), payment processing and security operations. We follow a strict verification process before hiring any service provider or collaborating with any partner. All our service providers and partners must accept strict confidentiality obligations. They will have access to your data only to the extent that it is reasonably necessary to perform certain tasks on our behalf.
    • For corporate transactions. We may transfer your information if we are involved, in whole or in part, in a merger, sale, acquisition, assignment, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. 
    • When required by law. We may disclose your information if necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, governmental / law enforcement investigation or other legal requirements; (ii) to contribute to the prevention or detection of crime (subject to the application in each case of the applicable legislation); or (iii) to protect the safety of any person. 
    • To enforce legal rights. We may also share information: (i) whether disclosure would diminish our liability in a lawsuit or potential lawsuit; (ii) as necessary to protect our legal rights and the rights of users, business partners or other interested parties; (iii) implement our agreements with you; and (iv) investigate, prevent or take other measures with respect to illegal activity, suspected fraud or other misconduct. 
    • With your consent or at your request. We may ask for your consent to share your information with third parties. In any case, we will clarify the reason why we want to share the information. We may use and share non-personal information (ie information that, by itself, does not identify who you are, such as device information, general demographics, general behavioral data, geographic location, in a form that cannot be read by human, in any of the above circumstances. More information about the use of cookies and similar technologies can be found in: Cookie Policy. 
    • The personal data of the Users may also be provided to the Prosecutor's Offices, the Police, the courts and other competent areas of the state, based on and within the limits of the legal provisions and as a result of expressly formulated requests.
  6. USERS' RIGHTS REGARDING PERSONAL DATA
    • According to the applicable legislation on personal data protection, each User has the right to information, access, intervention on data, the right to restrict processing, the right of opposition, the right not to be subjected to an automated individual process, the right to go to court and claim damages for violating his rights. 
    • Right to be informed - as a User of the services offered by the Site Administrator we want to ensure that you always receive clear and transparent information, easy to understand and accessible regarding how we use your data and about the rights that you have them. This is the purpose of this Privacy Policy. For additional information related to the personal data of the Users, the Open Fanclub team is at your disposal. 
    • Right of access - pursuant to this right, each User has the opportunity to obtain, free of charge for one request per year, through a written request, dated and signed, sent to the address indicated in this Privacy Policy, confirmation whether or not the data concerning it is processed by the operator. The first provision of information will be made without charging any fee. If you still need copies of the information already provided, we may charge you a reasonable fee considering the administrative costs of providing the information. We reserve the right not to respond to manifestly unfounded, excessive or repeated requests. 
    • The right to intervene on the data - any User has the right to request, free of charge, the rectification, updating, blocking or total or partial deletion of data whose processing cannot be done according to the law. NOTE: requests for data deletion will be made to the extent that they will not generate manifestly disproportionate costs for the Site Administrator and only if there are no contrary legal provisions, by which we are obliged to keep your data. Users understand and accept that the deletion of their personal data will be followed by the deletion of their account from the system and the impossibility of accessing the service offered by the Site Administrator. The right to rectify data that is incorrect, inaccurate or incomplete can be exercised directly by accessing the User's account. If you encounter difficulties in exercising the right of intervention on your data, please contact us.
    • If the data processing is based on consent (eg in the case of geolocation), you can withdraw your consent at any time without affecting the processing carried out before its withdrawal. If some data is collected via mobile or phone applications (eg geolocation, push notifications), you can change the settings of your mobile device at any time to oppose / consent to the collection of such data or the display of notifications. 
    • The right to restrict the processing - Users have the right to request the restriction of the processing of personal data. This right applies in the specific circumstances provided in the General Regulation on data protection, namely: The user disputes the accuracy of the data for a period that allows Open Fanclub, as operator, to verify the correctness of the data; the processing is illegal, and the User opposes the deletion of personal data and requests the restriction of their use; The Site Administrator, as operator, no longer needs personal data for processing, but they are requested by the User to establish, exercise or defend legal claims; The User objected to the processing based on legitimate reasons from Open Fanclub, the restriction of the processing being applied for the time interval in which it is verified if the legitimate rights of Open Fanclub prevail over those of the User. 
    • Right of opposition - Users have the right to object at any time, by a written request, dated and signed, if there are good and legitimate reasons, that the data concerning it be processed or disclosed to third parties. 
    • The right not to be subjected to an automated individual process.
    • The right to go to court - Without prejudice to the possibility of complaining to the supervisory authority, Users have the right to go to court to defend any rights guaranteed by law, which have been violated. A damage following a processing of personal data, carried out illegally, can be addressed to the competent court for its repair. You can contact us at any time, using the contact details below, before submitting a complaint to the relevant data protection authority. 
    • In order to exercise these rights, each User may make a written request to this effect, which he shall then send to support@openfanclub.com. 
    • You can also write to the data protection officer at the e-mail address: dpo@openfanclub.com. 
    • By reading this Privacy Policy, the User declares that he has taken note of the fact that his rights are guaranteed by law. 
    • The Site Administrator may notify Users of information related to the use and operation of the Service offered, by e-mail communications. Users can opt out of receiving this information at any time, following the unsubscribe options in the footer of each email. 
    • The information you provide to us will be used for the purposes expressly stated in this Privacy Policy to administer, support and evaluate our services and to prevent breaches of security, law and our contractual terms.
    • Users can edit the content of the account in the "Edit Profile" section at any time. "Nickname" and "Email Address" are not editable, while the "last name" and "first name" fields are not visible on the site, thus ensuring full privacy of this information. Users can cancel their account at any time in the Account Settings - Account Cancel section. 
  7. SPECIAL INFORMATION FOR PARENTS
    • Our services are prohibited for users who are 18 years of age or younger. We do not allow users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, use the available reporting mechanism. 
    • Although the services do not target children under the age of 18, our policy is to comply with the law, when parental or guardian permission is required, before collecting, using or disclosing information about children. 
    • The Site Administrator strongly recommends that parents take an active role in overseeing their children's online activities. If you consider that we have collected personal data from persons under the age of 18, contact us at: dpo@openfanclub.com. 
  8. HOW WE PROTECT INFORMATION
    • The Site Administrator is subject to the technical and security measures imposed by the legislation in force in order to ensure the confidentiality and protection of the personal data of the Users against unauthorized access. The Site Administrator ensures at all times, by implementing and applying the optimal technical measures, that the personal data of the Users are used exactly as described in the Privacy Policy and that each User's choices regarding the processing of his data are respected. 
    • These measures include, but are not limited to: 
      • (i)    storing your personal information in secure operating environments, which are not available to the public and which are accessible only to authorized persons; 
      • (ii)    the use of encryption techniques to protect the security of certain sensitive personal information, 
      • (iii)    verifying the identity of registered Users before being able to access their personal information.
    • The Site Administrator will be able to provide personal data provided by Users to other companies with which it is in partnership, only under contracts and on the basis of confidentiality commitments by which the latter guarantee that personal data are kept safe and that their processing and supply is done according to the legislation in force. Thus, Open Fanclub may provide personal data in order to contract marketing services, in order to facilitate payment services. 
    • This privacy restriction does not apply if the information regarding the personal data of the Users is requested by the judicial authority during a judicial procedure, in accordance with the law and the disclosure is authorized by the management of the Site Administrator, if the User requests in writing To the Site Administrator to disclose the information regarding his person or in any other cases provided by law. 
  9. THE PERIOD OF PROCESSING AND STORING THE USERS' DATA
    • The Site Administrator may retain the personal information that Users provide to us through the Site and / or the Application, in a database, such as the customer database. Your personal data will be kept by the Site Administrator only for as long as they are used in order to provide you with access to all the facilities of the Site / Application, to be able to answer your questions, in order to solve certain situations or to bring new improvements and services, subject to the legal requirements and legislation in force. 
    • Considering that through the Open Fanclub site you are offered social relations services as the purpose of the service is precisely to offer Users a way to know each other, to initiate and maintain social relations, it is necessary to store and process data with personal character offered by each User, for the entire duration of the provision of the service.
    • Personal data may be retained for a certain period of time even after you stop using the services offered by this Site and / or Application by revoking the initial agreement. In this case, certain personal data will be kept for a maximum period of 3 years from the moment of account cancellation, except in situations where the law requires us to store this data for a longer period. After the expiration of these periods, personal data will be destroyed by automated deletion or, if the law provides a longer storage period than that provided by this Privacy Policy, personal data are secured by automated methods of encryption and anonymization .
    • During this period, the account information will be kept, although the account, of course, will no longer be visible. 
    • In practice, we delete or anonymize your information after deleting your account unless: 
    • we must retain them to demonstrate compliance with applicable law (for example, records of your consent to the Terms and Conditions, Privacy Policy and other similar consents are retained for 3 years); 
    • there is a problem, a statement or a dispute that forces us to keep the relevant information until it is resolved; 
    • or the information must be kept for our legitimate business interests, such as fraud prevention and increasing the safety and security of users. For example, information may be stored to prevent a user who has been banned for unsafe behavior from opening a new account. 
    • Please note that although our systems are designed to perform data deletion processes in accordance with the above instructions, we cannot promise that all data will be deleted within a certain time frame due to technical constraints. 
    • The Site Administrator may keep statistical reports generated by using the information collected from the Site and / or Application for a long period, but such reports do not identify the User and will not be used in any other way that could affect the protection of personal data or User privacy.