Privacy Policy
Who We ARE
Our website address is: https://www.favoritesgroup.com
1. Preamble
We as Favorites Group, Inc. (“Favorites Group”), give utmost importance to the privacy of our Visitors during their visit of our website with domain name www.favoritesgorup.com (“Website”) regardless of their country of access.
2. Purpose of This Policy
This Privacy Policy (“Policy”) is prepared with a privacy-prioritizing attitude in order to provide detailed information to Visitors regarding the identity of Favorites Group as a data controller; data processing and its legal bases, reasons; rights of Visitors (“Data Subject”), which can be exercised against Favorites Group.
3. Scope of This Policy
a. In Terms of Legislation
Since, Favorites Group is a USA based company but has numerous Visitors from different countries; it is hard to determine which legislation should be applied to its activities and business. Therefore, Favorites Group intends to reflect its compliance with different legislations about privacy and data protection. For this reason, Favorites Group shows considerable effort to act in accordance with General Data Protection Regulation (“GDPR”), California Consumer Privacy Act (“CCPA”) and other applicable data protection regulations.
b. In Terms of Related Person
Data Subject may be referred as Visitor for visiting the Website and they will be covered in this Policy.
c. In Terms of Data
Information that makes it possible for related person to be identified directly or indirectly by any other person (“Personal Data”) is in the scope of this Policy. Accordingly, it can be safely said that confidential information, which cannot be considered as Personal Data, is excluded from this Policy.
4. Identity of Favorites Group as a Data Controller
For any and all data processing that occurs through accessing the Website, Favorites Group, Inc. residing at 16912 Coastal Highway, Lewes/Delaware is a data controller (“Controller”).
5. Occasions for Personal Data Processing
Favorites Group processes personal data during including without limitation below-mentioned situations:
- accessing to Website,
- contacting with Favorites Group regarding different requests and questions by filling out the contact form (“Contact Form”).
6. Principless for Processing Personal Data
Favorites Group considers below-mentioned principles while Processing Personal Data:
- Processing Personal Data lawfully, fairly and in a transparent manner in relation to the Data Subject,
- Processing Personal Data accurately and where necessary, kept up to date,
- Processing Personal Data for specific, explicit, and legitimate purposes,
- Processing Personal Data relevantly, limitedly and proportionately to the purposes for which they are processed,
- Processing Personal Data in a manner that ensures appropriate security of the Personal Data and kept in a form which allows identification of Data Subjects for no longer than it is necessary for the processing reasons.
7. Processed Personal Data
| Categories of Personal Data | Type of Personal Data |
|---|---|
| Technical Information | Internet Protocol (IP) address, device and browser type, time zone settings, and version, operating system and platform |
| Usage Information | The pages that Data Subject have visited on the Website and time spent, the frequency of access of Website, the links accessed, language preferences |
| Identifying Information | First and Last Name data of the Data Subject who filled out the Contact Form on the Website |
| Contact Information | E-mail Address data of the Data Subject who filled out the Contact Form on the Website |
8. Reasons and Legal Bases for Processing Personal Data
Personal Data given to or collected by us shall only be processed when necessary for a reasonable cause and when there is a legal basis for processing. Reasons and legal bases of processing are listed limitedly in this Policy and this Policy will be updated if a reason or a legal basis change.
a. First Name and Last Name
| Processin Reasons | Legal Bases |
|---|---|
| Identifying the person who filled out the Contact Form | Legitimate interest |
b. E-Mail Address
| Processing Reasons | Legal Bases |
|---|---|
| Communicating with the person who filled out the Contact Form | Legitimate interest |
c. Usage Information
| Processing Reasons | Legal Bases |
|---|---|
| Improving the Website | Legitimate interest |
d. Cookie
| Processing Reasons | Legal Bases |
|---|---|
| Improving the Website | Legitimate interest |
e. IP Address
| Processing Reasons | Legal Bases |
|---|---|
| Complying with legal obligation | Legal obligation |
f. Device & Browser Type
| Processing Reasons | Legal Bases |
|---|---|
| Improving the Website | Legitimate interest |
9. Rights of Data Subjects
Data Subjects are endowed with some rights to ensure their Personal Data to be processed on a lawful basis. Regarding our processing of your personal data, you have the following data protection rights:
- a. Right to be informed, by which the Data Subject may request information about their Personal Data being processed by Favorites Group.
- b. Right of access, by which the Data Subject may request to learn their Personal Data being processed by Favorites Group.
- c. Right of rectification, by which the Data Subject may request Favorites Group to correct or complete their Personal Data.
- d. Right to restrict processing, by which the Data Subject may request to limit the way their Personal Data is used.
- e. Right to erasure, by which the Data Subject may request to have their Personal Data erased.
- f. Right to data portability, by which the Data Subject may request to receive their Personal Data in a machine-readable format and/or request Favorites Group to transfer their Personal Data to another controller.
- g. Right to object, by which the Data Subject may request Favorites Group to stop processing their Personal Data.
- h. Rights in relation to automated decision-making, by which the Data Subject may request Favorites Group to stop processing their personal data in cases where Personal Data is being processed via automated decision-making.
10. Transfer of Personal Data
Favorites Group transfers Personal Data to third parties only when there is an explicit and informed consent from the Data Subject except for the below-mentioned cases, which have their own legal bases for the transfer:
- a. Law Enforcement and Judiciary Authorities: Favorites Group may be obliged to disclose Personal Data when required to do so by law, including but not limited to legal claims, legal investigations, lawful requests or legal proceedings.
- b. Third-Party Marketing Services: Usage Information and Cookie data may be transferred to YouTube, Twitter, Comscore, LinkedIn, Instagram, Google, Facebook, DoubleClick, Branch, and Atlas Solutions in order to conduct marketing and remarketing activities.
[Facebook Pixels and SDKs – Firebase or Google Analytics SDKs | Google Adsense for Website and Google Admob for Mobile App advertising]
Such transferring activity is limited to the usage of Facebook Pixel, Facebook Software Development Kits (SDK), Google Software Development Kits (SDK), Google AdSense and Google AdMob. To limit such activity, for the tracking purposes, Visitors should check their device settings to activate “Limit Ad Tracking” function. Visitors may also visit www.facebook.com/ads/settings and www.adssettings.google.com to opt-out such tracking activities.
11. Period of Retention
Favorites Group stores Personal Data in view of Data Minimization Principle, which necessitates Personal Data to be kept only for the required period. Required period is assigned considering the nature of the Personal Data, the potential risks of a Personal Data breach, processing reasons, and whether or not such reasons can be achieved in a different manner.
12. Methods of Securing Personal Data
Appropriate technical and organizational measures are enacted to ensure the safety, protection and the encryption of the Personal Data in order to prevent any Personal Data breach such that may be caused by accidental or unauthorized destruction, loss, theft or; unauthorized use, alteration and disclosure.
In this context, Favorites Group;
- a. Sign non-disclosure agreements with parties who have limited or unlimited access to Personal Data.
- b. Organize awareness trainings about data protection inside its organization.
- c. Entitles its employees with limited authorization according to their work line.
- d. Transfer Personal Data on a ‘need-to-know’ basis.
e. Process and store personal data on safely secured and encrypted cloud servers.
13. Contact Information of Favorites Group
Data Subjects may contact FAVORITES GROUP in case of having questions, comments, or feedback via [email protected] and Website.