Privacy Policy | Fazzaco

Effective on February 1, 2021

1 Your Privacy Matters

Fazzaco's mission is to provide a platform for the exchange of information and to facilitate effective collaboration for people in the global forex industry. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy, Settings and our Help Center.

2 Introduction

Our registered users (“Members”) exchange knowledge and professional insights, post and view relevant content, and find business. Content and data on some of our Services is viewable to non-members (“Visitors”).

2.1 Services

This Privacy Policy applies to Fazzaco.com, apps, H5, communications and services (“Services”), including off-site Services, such as our ad services, but excluding services that state that they are offered under a different privacy policy.

2.2 Data Controllers and Contracting Parties

2.2.1 EU Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the General Data Protection Regulation (“GDPR“) and other applicable data protection laws.

We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

2.2.2 EU User Rights

You may request to:

1.Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

2.Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.

3.Request rectification of your Personal Data that is in our control.

4.Request erasure of your Personal Data.

5.Object to the processing of Personal Data by us.

6.Request to restrict processing of your Personal Data by us.

7.Lodge a complaint with a supervisory authority.

However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.

2.2.3 Transfer of data outside the EU

EU users – please note that some data recipients may be located outside the EU. In such cases, we will transfer your personal data only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

2.2.4 California Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA“).

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

2.3 Change

Fazzaco (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

3 Data We Collect

3.1 Data You Provide To Us

Registration

To create an account you need to provide data including your name, email address and/or mobile number, and a password.

Profile

You have choices about the information on your profile, such as your gender, company, position, city or area, contact and business email. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. You can set whether to show your data in Settings-Privacy.

3.2 Data From Others

Content and News

You and others may post content that includes information about your company (as part of articles, posts, comments, videos) on our Services. We also may collect public information about your company, such as industry-related news, and make it available as part of our Services.

Related Companies and Other Services

We receive data about you when you use some of the other services provided by us or our affiliates, including Microsoft.

3.3 Service Use

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

3.4 Cookies and Similar Technologies

We use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. If you are outside the Designated Countries, we also collect (or rely on others who collect) information about your device where you have not engaged with our Services (e.g., ad ID, IP address, operating system and browser information) so we can provide our Members with relevant ads and better understand their effectiveness. You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

3.5 Your Device and Location

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

3.6 Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement from our Services.

3.7 Sites and Services of Others

We receive information about your visits and interaction with services provided by others when you log-in with Fazzaco or visit others’ services that include some of our ads, cookies or similar technologies.

3.8 Third-party shared information

In order to implement the function of the message push service, which is used to push you service alerts, subscription information, etc., we use the JPush SDK with the following information.

1. SDK product name: JPush SDK

2. App product applied system: Android and iOS system

3. Personal information type: personal common device information, location information, network information

4. Personal information fields: device information, geographic location, network information, read and write external storage

5. Use or purpose: push messages

6. Processing methods: desensitized display of personal information using replacement, de-identification, and anonymization

7. JPush SDK's contact information: support@jiguang.cn

8. Terms of JPush SDK's privacy policy: https://www.jiguang.cn/en/license/privacy

9. Date and time of transmission: March 24, 2021, per service use, via the Internet

10. Period of Retention and Use: until membership is revoked or contract is terminated

Among others, key terms are defined as follows：

1. Device information: including device identifier (IMEI, IDFA, Android ID, MAC, OAID and other related information), application information (application crash information, notification switch status, software list and other related information), device parameters and system information (device type, device model, operating system and hardware related information)

2. Network information: including IP address, WiFi information, base station information and other related information

3.9 Other

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

4 How We Use Your Data

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.

4.1 Services

We use your data to authorize access to our Services and honor your settings.

Stay Connected

We use data about you (such as your profile, profiles you have viewed) to help others find your profile, suggest connections for you and others. You can also opt-in to allow us to use your precise location.

Productivity

Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with.

4.2 Communications

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Fazzaco inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

4.3 Advertising

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

1.Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;

2.Member-provided information (e.g., profile, contact information, title and industry);

3.Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, page visits, videos you watch, clicking on an ad, etc.);

4.Information from advertising partners, vendors and publishers; and

5.Information inferred from data described above.

Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you.

Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

4.4 Developing Services and Research

Service Development

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

Other Research

We seek to create economic opportunity for Members and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

4.5 Customer Support

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

4.6 Security and Investigations

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members,Visitors or others.

5 How We Share Information

5.1 Our Services

Profile

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines).

Posts, Likes, Follows, Comments

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

1.When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere . Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).

2.Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.

3.When you follow a person or organization, you are visible to others and that “page owner” as a follower.

4.When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

Enterprise Accounts

Your employer may offer you access to our enterprise Services. Your employer can review and manage your use of such enterprise Services.

5.2 Others’ Services

Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.

5.3 Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

5.4 Legal Disclosures

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Fazzaco, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

5.5 Change in Control or Sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

6 Your Choices & Obligations

6.1 Data Retention

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services.

6.2 Rights to Access and Control Your Personal Data

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you, you can:

1.Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

2.Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

3.Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

4.Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

Residents in the Designated Countries and other regions may have additional rights under their laws.

7 Other Important Information

7.1 Security

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

7.2 Cross-Border Data Transfers

We process data both inside and outside of the Republic of Seychelles and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

7.3 Lawful Bases for Processing

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Fazzaco Services you have requested) and “legitimate interests.”

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer.

7.4 Direct Marketing and Do Not Track Signals

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

7.5 Contact Information

If you have questions or complaints regarding this Policy, please first Fazzaco online and Fazzacoe will make an effort to reply within a reasonable timeframe: service@fazzaco.com.