Confidentiality Policy

Policy regarding the processing of personal data

We respect your privacy and are committed to protecting your personal data. This policy on the processing of personal data (the “Policy”) will inform you about how we handle your personal data, your privacy rights and how the law protects you.

Services means any products, services, content, features, technologies or functions and all relevant web pages, applications and services we offer you.

Platform means the web pages, mobile applications, mobile web pages or other online properties through which we provide the Services.

1. About us

GO Forward S.R.L. is a data operator with the registered office at bd IC Bratianu no 28, Constanta, Romania, responsible for your personal data. GO Forward S.R.L. is the parent company that delivers your services in accordance with the Terms and Conditions of use to our terms and conditions page (collectively referred to as “Pigeon Marathon”, “Pigeon Marathon”, “us”, “new” or “our” in this Policy). Our contact details can be found in section 13.

The local data operator that processes your personal data is: the company GO Forward SRL, the Romanian legal person, with headquarters in Constanta, bd IC Bratianu no. 28, registered at the Trade Register Office near the Constanta Court under no. J13 / 1695/2019, CUI 41030076, fiscal attribute RO.

2. What data do we collect about you?

2.1.1 Data provided by direct interactions

Registration, use of the Platform and other account information

When you register with our Platform for the use of the Services we provide, we may collect the following information about you:

• when you register on the Platform for the Announcements section, you will be required to be required by first name, first name, telephone number and email address;
• when you register on the Platform for the Profiles section, you are required to have your name, first name, phone number, email address and photos.

2.1.2 Data we collect automatically when you use our Services

When you interact with our Platform or use our Services, we automatically collect the following information about you:

Device information

• We collect device specific information, such as operating system version, unique identifiers. For example, the name of the mobile network you are using. We associate the device identifiers with your account on our platform.

Location information

• Depending on the authorizations granted on your device, if you publish an article on our Platform, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi hotspots and mobile towers. Your location data allows you to view user articles near you and helps you post articles from you. If we need your location data, you will first receive a pop-up window where you will be prompted to you choose to allow or disallow access to your location data. If you do not allow us access to your location data, you may still use our Services, but with limited functionality. If you do not allow us to access your location data, you can change this at any time later from the settings on our website or the Platform application and disable location sharing permissions. For more details on the purposes of using your location data and how this data is processed, please see Section 4.2 (ii) of this Policy.

Customer Data and Authentication

• Technical details, including Internet Protocol (IP) address of the device, time zone and operating system. Also, we will keep your login information (registration date, date of last password change, date of last successful authentication), type and version of your browser

Clickstream data

• We collect information about your activity on our Platform, which includes the web pages from which you accessed our Platform, the date and time of each visit, the searches you performed, the advertising banners or the content you clicked on, your interaction with them types of advertising, the duration of your visit and the order in which you visit the content of our Platform.

Cookies and similar technologies

• We use cookies like modules to manage user sessions, to store language selection preferences and to offer you relevant advertisements. “Cookies” are small text files transferred by a web server to the hard disk of your device. Cookies can be used to collect the date and time of your visit, browsing history, your preferences and your username. You can set your browser to refuse all or some cookies or to warn you when web pages set or access cookies. If you disable or refuse cookies, please be aware that certain parts of our Services / Platforms may become inaccessible or may not function properly. For more information on the cookies we use, please refer to the Cookies and Similar Technologies Policy.

2.1.3 Data from third parties or publicly available sources

We receive your personal data from various third parties and from public sources, as follows:

1. Certain technical and usage information from analytics providers, such as Google.
2. Contact information regarding business operations in advertising networks, such as data providers in connection with operations and service partners. (Example: business activity data); and

Data regarding the use of the services from the Platform, related to the Services or transactions. (Example: data directly related to ads posted on the platform to prevent fraud and reporting of such cases to the respective entities).

3. About minors.

Our services are not intended for minors under 16 and we do not intentionally collect data from persons under 16. If we find that a person under 16 has provided us with personal data, we will delete them immediately.

4. About the processing of personal data.

We will only use your personal data when the law permits. Most commonly, we will use your personal data in the following situations:

• If necessary for our legitimate interests to improve the Services and ensure a secure and secure Platform;
• If we are obliged to comply with a legal or regulated obligation;
• If you give us your explicit consent;

In certain circumstances, we may process your personal data based on your consent. If we do so, we will notify you of the purpose and category of personal data that we process when we ask for your consent.

We have described below how we use your personal data and the legal bases on which we rely. We also identified what our legitimate interests are, where appropriate.

4.1 About granting access and providing the Services through our Platform

If you sign in using your mobile phone number or email id, we will use your first and last name, phone number and / or email address to identify you as a user and to identify you granted access to the Platform.

The above authentication data is also used for the delivery of our Services in accordance with the Terms of Use.

We use your email address and mobile phone number (via SMS) to give you suggestions and recommendations about our Services that may be of interest to you.

We process the information above for proper execution of our contract with you and based on our legitimate interest in conducting marketing activities to provide you with Services that may interest you.

4.2 To improve your Platform experience

We use clickstream data for:

• provide you with personalized content, such as giving you more relevant search results when using our Services.
• determine how much time you spend and how you navigate the Platform to understand your interests and improve our Services based on this data. For example, we can provide suggestions on what content you can visit based on the content you have accessed.
• to monitor and report the efficiency of providing campaigns for our business partners and internal business analysis.
• prevent too many ads from displaying the same ads to the same user.

We use your location data for the following purposes:

• to compile anonymous and aggregated information about the characteristics and behavior of Porumbel Maraton / Marathon Pigeon users, including for the purpose of business analysis, segmentation and development of anonymous profiles.
• to improve the performance of our Services and to personalize the content we direct to you. For example – with location data, we show ads in your vicinity to improve your shopping experience. To this end, Google Maps is integrated into our Platform. Google Maps is made available to us and Google as independent operators. This means that both Google and we are responsible for processing your location data in the context of Google Maps. In any case, we will not process your location data for purposes other than those explained in this Privacy Policy. However, Google may process this location data for its own purposes, as explained in the Google Privacy Policy which can be accessed here. Your use of Google Maps through our Platform is subject to the Google Maps Terms of Use.
• to measure and monitor your interaction with third-party advertising banners placed on our Platform.

iii. With the help of your registration data, which includes email and phone number, we determine different devices (such as personal computers, mobile phones, tablets) through which you access the Platform. This allows us to associate your activity on the Platform on different devices and helps us to provide you with an appropriate experience regardless of the device you are using.

We process the information above based on our legitimate interest to improve your experience on our Platform and to properly fulfill the contract with you.

4.3 To provide you with a secure and secure Platform

1. We use your telephone number, authentication data and unique device identifiers to manage and protect the Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting and data hosting).
2. We analyze the communications made through our chat function to prevent fraud and to promote security by blocking spam or abusive messages that can be sent to you by any other user.

We process the above information for the proper execution of our contract with you, to improve our services and based on our legitimate interest in preventing fraud.

4.4 To provide you with a powerful customer support service

1. We record your conversations with the members of the customer relations team or the sales team members, only subject to your explicit agreement;

We process the personal data mentioned above to further analyze your interaction with our customer relationship team or sales team members (as applicable) and to improve the way our team members serve Porumbel Maraton / Marathon Pigeon customers.

You may withdraw your consent at any time and free of charge by submitting a request to the Pigeon Marathon / Pigeon Marathon, at the contact details provided in point 13 below. All processing activities carried out until the withdrawal of the consent remain valid.

5. Information on changes made to our Policy

We may change this Policy from time to time. We will post changes to this page and inform you via email or Platform. If you do not agree to the changes, you can close your account by accessing the account settings and selecting deletion of the account.

6. User rights

In certain circumstances, you have rights under data protection law regarding your personal data.

If you want to exercise any of the rights below, go to your account / privacy settings.

The right to request access to your personal data (commonly referred to as “requesting access of the data subject”). This allows you to receive a copy of the personal data we hold about you and verify that we process it legally.

The right to request the correction of any data we have about you. This allows you to correct any incomplete or inaccurate data we hold about you, although it may be necessary to verify the accuracy of the new data you provide to us.

The right to request the restriction of the processing of your personal data. This allows you to request us to suspend the processing of your personal data in the following scenarios: (a) if you want to establish the accuracy of the data; (b) if we use the data illegally; (c) if you need to keep the data, even if we do not need it anymore, because you need to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we must verify that we have compelling legal reasons for using it.

The right to request the deletion of your personal data. This allows you to ask us to delete or delete your personal data where there are no compelling reasons to continue processing it. You also have the right to ask us to delete or delete your personal data if you have successfully exercised your right to object to processing (see below), if we have processed your information illegally or if we are you are obliged to delete your personal data in order to comply with local law. Please note that, for certain purposes, we are legally obliged to keep your data. Please see section 10 for more details.

The right to oppose the processing of your personal data if we are based on a legitimate interest (or of a third party) and something in your particular situation makes you want to object to the processing for this reason, because you feel that it has an impact on your rights. and your fundamental freedoms. You also have the right to object if we process your personal data for direct marketing purposes. In some cases, we can demonstrate that we have compelling legitimate reasons to process your information, which go beyond your rights and freedoms.

The right to request the transfer of your personal data to you or a third party. We will provide you or a third party of your choice with your personal data in a commonly used structured format that can be read by the computer. Please note that this right applies only to the automated information for which you initially gave us consent to use them or if we used the information to execute a contract with you.

The right to withdraw your consent at any time to the processing of your personal data. This does not affect the legality of any processing that we have already carried out on the basis of the consent given above.

No fee is usually required: you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repeated, or exaggerated. Alternatively, we may refuse to comply with your request in these circumstances.

Response deadline: We try to respond to all legitimate requests within one month. Occasionally, it may take more than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

In addition, you have the right to complain at any time to the data protection authority. You can find the contact details in section 14.

7. Marketing and Communication

We will communicate with you via email, SMS or notification from the application regarding the Services / Platform to confirm your registration on the Platform, to inform you if the registration of the ads is effective / has expired and for others. transactional messages in connection with our Services. Because it is imperative that we provide you with such transactional messages, you may not be able to opt out of such messages.

However, you may request that we no longer send you marketing communications at any time by accessing the deactivation link in the email or SMS sent or by changing the communication settings in your account. If you have trouble changing these settings, please contact us.

You may receive marketing communications from us if:

• you have requested such information from us;
• use our Platform or Services;
• you provided us with the details when you entered a competition; or
• you signed up for a promotion.

8. Disclosure of your data.

It is possible to disclose personal data to the parties presented below, for the purposes set out in section 4 above.

Affiliate companies – We can share your data with other companies within the Porumbel Maraton / Marathon Pigeon group that are both inside and outside the EEA and help us provide business operations services such as product enhancements, customer support. clients and fraud detection mechanism. Any sharing of personal data outside the European Economic Area (“EEA”) will always be subject to the safeguards described in Section 9 or to a data transfer agreement that clearly defines the parties’ obligations and provides the technical and organizational measures for protect your data.

Third Party Service Providers: We use third party service providers to help us provide certain aspects of our Services, such as cloud storage equipment such as Amazon Web Services and Microsoft Azure. Service providers may be located inside or outside the “SEE”.

We carry out checks on third party service providers and ask them to respect the security of your personal data and to treat them in accordance with the law. We do not allow them to use your personal data for their own purposes and we only allow them to process personal data for specific purposes and in accordance with our instructions.

Customers, legal entities, acting on the Platform as sellers and / or pigeons: in order to provide you our services associated with the categories “Announcements” and “Columbofili Catalog” but also to facilitate the publication of your ads and profiles, we will make the users public to our Porumbel Maraton / Marathon Pigeon platforms, your identification data such as name, first name, telephone, email address, photos, presented directly by you to the users through the Platform.

Advertising and analytics providers: To improve our Services, we will sometimes distribute your information to data analytics providers that help us analyze how your data is being used by our Platform / Service. We share your information with them in an unidentifiable form for monitoring and reporting the effectiveness of campaign delivery to our business partners and for internal company analysis. This information will typically include cookie ID, IP address (shortened), reference URL, as well as browser and device information. To control and manage your creative settings, you can access the settings via a link at the bottom of our website. For more details about advertisers and analytics providers, see the Cookies and Similar Technologies Policy.

Criminal prosecution bodies, public authorities and others: we may disclose your personal data to criminal prosecution bodies, public or governmental authorities and other relevant third parties in complying with legal or regulatory requirements. We may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire or merge with other businesses. If there is a change in our company, then the new owners may use your personal data in the same manner as described in this Policy.

Information available to the public: in order to provide you with our services associated with the categories “Announcements” and “Columbofili Catalog” but also to facilitate the publication of your ads and profiles, we will make publicly available to our platform users Porumbel Maraton / Marathon Pigeon, your identification data as names , first name, telephone, email address, photos, presented directly by you to the users through the Platform. Please note that all information you provide to other users may always be shared by other users, so please exercise discretion in this regard.

Publicly available information on other sites Porumbel Marathon / Marathon Pigeon: When your posting is relevant to other platforms managed and developed by Porumbel Marathon / Marathon Pigeon, such as our website www.flymp.eu or the site www.marathon.ro and you choose to make your personal data of other Porumbel Maraton / Marathon Pigeon users visible, these personal data, that is, your name or your account number (depending on your privacy settings), the content of your ad, as well as your data. identification (name, first name, email address and mobile phone number) but also your images in case of visiting the “Columbofil Catalog” page, will be automatically displayed on such platforms.

9. International transfers

When we transfer your personal data to a non-EEA country, we ensure that a similar degree of protection is granted by ensuring that at least one of the following protection measures is implemented:

• We will only transfer personal data to countries that have been deemed to provide an adequate level of protection of personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• If we use certain service providers, it is possible to use specific contracts approved by the European Commission that provide personal data with the same protection that they have in Europe. For more details, see European Commission: Model contracts for the transfer of personal data to third countries.
• If we use US-based service providers, we may transfer data to them if they are part of the Privacy Protection which requires them to provide similar protection to personal data shared between Europe and the US. For more details, see European Commission: EU-US Privacy Shield.

10. Data storage

The data we collect about you will be stored and processed both inside and outside the EEA, on secure servers, to give users the best possible experience. For example – for quickly building web pages or mobile applications.

We will keep your personal data for as long as necessary to fulfill the purposes we envisioned when we collected it, including for the purpose of meeting any legal, accounting or reporting requirements.

To determine the appropriate period of retention of personal data, we consider the quantity, nature and sensitivity of personal data, the potential risk of injury caused by unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can perform these purposes by other means and applicable legal requirements.

If there is no activity in your account for 24 months, we reserve the right to delete your account, including all personal data stored in your account, which means you will no longer be able to access and use it. However, you can be sure that we will not delete your account if you have open transactions or are entitled to a loan repayment or repayment from us. Before deleting your account, we will contact you to verify if you do not want to continue using your account.

 

11. Technical measures and security of data processing

All the information we receive about you is stored on secure servers and we have implemented appropriate technical and organizational measures to protect your personal data. Pigeon Marathon / Marathon Pigeon is constantly evaluating the security of the network and the adequacy of its internal information security program, which is intended to: (a) help you secure your data against accidental or illegal loss, access or disclosure; (b) identify reasonably foreseeable risks to the security of the Porumbel Maraton / Marathon Pigeon network, and (c) minimize security risks, including risk assessment and periodic testing. In addition, we ensure that all payment information is encrypted using SSL technology.

Please note that despite the measures we have implemented to protect your data, data transfer over the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties.

12. Links to third party websites

Our platform may contain references to web pages or third-party applications. If you click on one of these links, please note that each of these pages or applications will have its own privacy policy. We do not control these web pages / applications and we are not responsible for these policies. When you leave our Platform, we encourage you to read the privacy policy of each webpage you visit.

13. Contact.

For any additional information or to exercise your rights, please check your account / privacy settings or contact our Data Protection Officer, using the Contact Form.

If you would like to contact us to request information regarding the processing of your personal data you can send a letter to the address: GO Forward SRL, Romanian legal person, with headquarters in Constanta, bd IC Bratianu no 28, Romania.

14. Data Protection Authority

The competent supervisory authority for the Porumbel Maraton / Marathon Pigeon group of companies is:

Friedrichstr. 219, Besuchereingang: Puttkamerstr. 16-18 (5th floor), 10969 Berlin, Germany

Phone: 030 13889-0, Telefax: 030 2155050

E-Mail: mailbox@datenschutz-berlin.de

For local data protection issues, you can contact the local authority represented by:

National Authority for Data Protection

Address: Magheru Boulevard 28-30, Sector 1, Bucharest

Website: http://www.dataprotection.ro/