3. HOW WE USE YOUR DATA?

We use, store, combine and process information, including personal information, about you to provide, understand, improve, and develop the Byte Flick Platform, create and maintain a trusted and safer environment and comply with our legal obligations.

• To Identify. Personal identification information is collected and processed for the purposes of User identification as well use of services and domain name registration. Additionally, this information may be used to provide Users with support, letting them know about upcoming updates or improvements, providing information regarding changes of any Terms of Use (including changes to this Policy) as well as other important information.
• To Create and Maintain Trusted Environment. We verify or authenticate information or identifications provided by you (such as ID number, email or phone numbers). We also use collected information to detect and prevent fraud, spam, abuse, security incidents, and other illegal and harmful activities.
• To Create Aggregated Statistical Data, to Carry out Market Research and Analysis necessary for running out our business, to improve our services we use aggregated and/or inferred non-personal information enabling us to evaluate our customers’ needs, sales and other trends of our activities.
• To Stay Connected. We use information about data usage, devices, operating systems to diagnose problems with our servers, to administer our Platform, adopt decision when to retire SDK’s/OS versions, to identify characteristics of major users so that we may optimize our applications and services and make your browsing and purchasing experience more enjoyable.
• To Customize Marketing. To provide more customized offers to our Users, we may conduct data analysis based on information you provide to us, your interactions with the Byte Flick Platform and its Users.
• To Send Service and Billing Messages. Byte Flick may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the communication channels available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your hosting plan; or notify you of material changes in our Services. Such kind of communication is essential, for this reason, no opt-out possibilities are given to avoid receiving such Service and Billing Messages unless you are no longer a Byte Flick User (which can be done by deactivating your Account).
• To inform you about the status of unfinished order. We may send you an email notification about the status of your unfinished order. Such notifications are based on our legitimate interest in improving your experience with us and assisting you with any issues related to your orders. You have the full right to opt-out of receiving such notifications at any time through the unsubscribe link provided in the email or your account settings.
• To Register Domain. In certain jurisdictions or pursuant to the rules of the ICANN or certain registries, domain name registration information has to be made available and accessible to the public through a “WHOIS” search. The WHOIS database is a publicly accessible database that lists the domain name registration information for a particular domain name, the name server(s) to which the domain name points, and the domain name’s creation and expiration date. The domain name registration information you provide is stored by Byte Flick and is made available to the public through WHOIS searches. Byte Flick may deposit your domain name registration information with a third-party escrow provider to comply with ICANN requirements. At times, Users may receive solicitations that result from searches of the publicly available WHOIS database by other companies or individuals. Any such solicitations or e-mail communications do not come from Byte Flick and Byte Flick is not responsible for the use of WHOIS information by third parties.Byte Flick acts only on the basis of ICANN rules and requirements. For more information see: https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.
• To contact you. In order to notify you regarding your Account, to troubleshoot problems with your Account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes, we may contact you via email, telephone, text messages, and portal.
• To get feedback. We may contact you via email to invite you to review any services and/or products you received from us in order to collect your feedback and improve our services. We might use an external company, to collect your feedback which means that we will share your name, email address and reference number for this purpose.
• To provide, operate and improve the Services.
• To enhance data security and to prevent fraud.
• To comply with applicable laws and regulations.

4. JOB APPLICATIONS

Byte Flick welcomes all qualified Applicants to apply to any of the open positions published at https://www.byteflick.org/career, by sending us their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website, or through any other means provided by us.

We understand that privacy and discreteness are crucial to our Applicants and are committed to keep Applicants Information private and use it solely for Byte Flick‘s internal and group companies’ recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).

Byte Flick may retain Applicants Information submitted to it for no longer than one year after the applied position has been filled or closed. We collect this information to re-consider Applicants for other positions and opportunities at Byte Flick; we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at Byte Flick.

If you previously submitted your Applicants Information to Byte Flick, but now wish to access it, update it or have it deleted from our systems, please contact us at gdpr@byteflick.org.

5. DIRECT MARKETING AND SERVICE EXPIRATION NOTICES/RENEWAL REMINDERS

When creating an Account at our Platform, subject to the available preferences, you are free to give consent and/or opt-out from receiving various offers and/or notices directly to your e-mail, phone (SMS and/or Whatsapp messages) or in your Account. We use provided contact details and your preferences for direct marketing (by sending various offers or newsletters) and/or Service expiration notices / renewal reminders.

This communication, depending on your preferences, may be personalized taking into account any other information which you have provided to us (e.g. location, social media profile information, purchase history etc.) or we have collected or generated from other sources as described below.

Please note that in case you subscribe to service expiration notices / renewal reminders via SMS/WhatsApp, it is our right, but not an obligation, to send such notices / reminders for each Service.

Right to object / revoke consent

If a User wishes to change their preferences communication (revoke consent or object), they are free to exercise such option at any time they wish by (1) following the instructions to unsubscribe in the received email (usually, by clicking on a link for that purpose at the bottom of our e-mail) / text message; (2) visiting and adjusting User’s personal account settings (communication preferences).

You may also at any time refuse to receive information from us by sending an email to gdpr@byteflick.org.

6. OTHER USES OF YOUR PERSONAL DATA

• Developing Platform. We use data, including public feedback, to conduct research and development for the further development of our platform in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth.
• Customer Support. We use data to help you and fix problems. We use the data (which can include your communications) to investigate, respond to and resolve complaints and issues (e.g., bugs).
• Aggregate Insights. We use data to generate aggregate insights. We use your data to produce and share aggregated insights that do not identify you.
• Security and Investigations. We use data for security, fraud prevention and investigations. We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our Terms of User or this Policy and/or attempts to harm our Users.

7. SOURCES OF PERSONAL DATA

We collect and receive your Personal data from yourself (including your device) as well as from the following sources:

• Social network operators (such as Facebook, Google, etc.);
• Third-party service providers, suppliers and our partners;
• Other legal sources.

8. RETENTION AND DELETION

We generally retain your personal information for as long as is necessary to provide our services and to comply with our legal obligations. Where your personal information is no longer required we will ensure it is securely deleted.

If you would like to stop us using your personal information, you shall request that we erase your personal information and close your Byte Flick Account.

After de-activation of Account, we will still retain the following data for the purposes of compliance with applicable legal requirements (such as tax, accounting, legal reporting, AML, other), for as long as we are legally required by virtue of such legal requirements:

• profile with de-personalised information (we will change your email into user@deleted.com, erase your name, surname and contact information) like purchased services, login information, payment information, etc.

Please also note that we may further retain some of your personal information in such cases (i.e., after closure of your Byte Flick Account):

• as long as it is necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. If Byte Flick suspends your Byte Flick Account for safety reasons, we may retain certain information from that Byte Flick Account to prevent that User from opening a new Byte Flick Account in the future;
• the extent necessary to comply with our legal obligations. Byte Flick may keep some of your information for tax, legal reporting and auditing obligations;
• to resolve disputes;
• to enforce our agreements and/or pursue or protect our legitimate interests;
• as we protect Byte Flick Platform from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time;
• domain name registration data – at the moment of writing this Policy, in order to register domain, we are requested to provide personal information about the owner of domain; this information is shown in WHOIS directory and is public. For more information, please visit https://www.icann.org/registrants.

9. DATA TRANSFERS AND USE OF THIRD-PARTY SERVICES

While collecting and processing your Personal Data, we may perform data transfers to various third parties.

9.1. With your consent

We will share your Personal Data with companies, organizations or individuals outside our group of companies when we have your consent to do so.

9.2. Where do we process your personal data?

• Users’ Personal Information may be maintained, processed and stored by Byte Flick and our authorized affiliates and service providers in the United Kingdom, Pakistan and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
• Job Applicants Information will be maintained, processed and stored in Pakistan, in the applied position’s location(s), and as necessary, in secured cloud storage provided by our Third-Party Services.
• Byte Flick affiliates and service providers (such as third-party data centres, servers, website design, administration services, online traffic and website analysis, statistics, direct marketing services, mailers, messengers, email service provider (when you choose to purchase or use such services), etc.), that store or process your personal data as well as personal data of your users on Byte Flick’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction (see below).
• Domain name registration data and identification data is shared with third parties in accordance with ICANN rules. For more information see https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.

We may share non-personally identifiable information publicly as well as with our partners – publishers, advertisers. For example, we may share information publicly to show trends about the general use of our platform.

If we are involved in a merger, reorganization, acquisition or sale, we will continue to ensure the confidentiality of any Personal Data and give all affected Users appropriate notices.

Standard contractual clauses for data transfers outside the EU or EEA. Your personal data as well as personal data of your users might be transferred to processors, sub-processors or other data recipients established in third countries (i.e., data centers and servers, located outside EU or EEA). For such transfers to be compatible with the requirements of GDPR, we have concluded with the data processors and/or sub-processor relevant agreements on such data transfers outside EU or EEA, which comply with the European Commission approved standard contractual clauses for data transfers from data controllers in the EU to data processors and/or controllers established outside the EU or European Economic Area (EEA). For more see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en. For the said purposes and to the extent relevant we have deemed that the said agreements were concluded on your behalf and under your instructions, as the case may be, all in line with Art. 46 of GDPR.

Other grounds for data transfers outside the EU or European Economic Area (EEA). Your personal data as well as personal data of your users might be transferred to data recipients established in third countries on other legal grounds compatible with the requirements of GDPR (Art. 45-49).

Transfer, disclosure of data to competent authorities. In certain situations, Byte Flick may be asked to disclose personal data in response to lawful requests by public authorities, other competent authorities, including when it is required to meet national security or law enforcement requirements, and will do so where permitted by local data protection laws.

9.3. Data Localisation Obligations

If you reside in a jurisdiction that imposes “data localisation” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.

You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere.

9.4. Targeting, advertising

We also use Facebook, Google, as well as other advertising and marketing tools. You should carefully read the privacy policy of these service providers. More information on the targeted advertising, as well as your opt-out rights and other rights, you will find on the respective websites of these service providers – https://lt-lt.facebook.com/policies/ads#; https://policies.google.com/technologies/ads.

9.5. Our Legal Obligation to Use or Disclose Personal Data

We will reveal your Personal Data to state and public authorities without your prior permission only when we are legally required to provide information, including taking legal action to defend our rights, as well as the cases, where we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Terms of Services, including investigation of potential violations, detect, prevent or otherwise address fraud, security or technical issues.

9.6. Other

We may share your personal data in manners other than as described above, pursuant to your explicit consent, or if we are legally obligated to do so.

10. DATA SECURITY

Byte Flick has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

Regardless of the measures and efforts taken by Byte Flick, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other User Content you upload, publish or otherwise share with Byte Flick or anyone else.

We therefore encourage you to set strong passwords for your User Account and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm.

If you have any questions regarding the security of our Services, you are welcome to contact us at gdpr@byteflick.org.

11. YOUR RIGHTS

You are entitled to a range of rights regarding the protection of your Personal Data, which are subject to limitations, restrictions and conditions as laid down in GDPR and applicable law. Those rights are:

• the right to access the information we process about you;
• the right to rectify incorrect/inaccurate information about you;
• the right to transfer all or part of the information collected about you to you or another data controller, where technically feasible (the right to data portability; with limitations and restrictions as specified in the EU General Data Protection Regulation);
• the right to erase any data concerning you. Users may demand erasure of data without undue delay for legitimate reasons, e.g. where data is no longer necessary for the purposes it was collected, or where the data has been unlawfully processed;
• the right to the restriction of data processing. Users, for legitimate purposes, may obtain restriction of data processing from the controller;
• the right to object to the processing of Personal Data when processing is carried out on the basis of legitimate interest, as well as in cases of use of your personal data for direct marketing purposes, as specified above in this Policy.

Some of the rights as above are easy to exercise: i.e., you may at any time access and edit, update or amend your details, opt out of receiving communications from us and our partners by visiting and adjusting your personal account settings, or by e-mail: gdpr@byteflick.org

When you object to processing of Personal Data when processing is carried out on the basis of legitimate interest, we will carefully consider such a request, which may result in your Account closure or de-activation.

Users have the right to lodge a complaint with the national Data Protection Agency in their country of residence in the event where their rights may have been infringed. However, we recommend attempting to reach a peaceful resolution of the possible dispute by contacting us first.

12. ACCEPTANCE OF POLICY

We assume that all Users of Byte Flick Platform have carefully read this document and agree to its contents. If someone does not agree with this Policy, they should refrain from using our website and services. We reserve the right to change our Policy at any time and inform by using the way as indicated in Section 14. Continued use of Byte Flick’s website and services implies acceptance of the revised Policy.

We will ask for your consent before using information for a purpose other than those set out in this Policy.

13. APPLICATION OF POLICY

This policy is only applicable to Byte Flick (byteflick.org). Our Policy applies to all of the services and solutions that are offered by us. Our Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include our services or other sites linked from our services.

14. POLICY AMENDMENTS

We reserve the right to update or modify this policy at any time without prior notice. Any changes will be effective immediately upon posting on our website and the date of the last update will be indicated at the top of the page. If we make changes that are material, we will provide you with appropriate notice via email notifications before such changes take effect.

15. QUESTIONS AND CONCERNS

If you have any questions, suggestions or complaints regarding privacy policy, please feel free to contact Data Protection Officer at gdpr@byteflick.org