Privacy Policy Festivus Media BV

Festivus Media BV takes your privacy very seriously, treats all your personal information with great care, and assures you that your personal data will only be used in accordance with this Privacy Policy. This Privacy Policy sets out how Festivus Media BV uses and protects any information that you provide Festivus Media BV when you use our website and our services. In short, we use your personal data to offer you our services, to get in touch with you, to inform you about our service and to be able to make you personal offers. If you have questions regarding the use of your personal data please contact us through compliance@festivusmedia.com.

Who is Festivus Media BV?

Festivus Media BV provides a service by means of a platform (“Platform”) where users can get in touch and communicate with each other through messages. The services of Festivus Media BV are provided by Festivus Media B.V. Festivus Media B.V. is located at Bezuidenhoutseweg 161 (2594AG) ‘s-Gravenhage and is registered with the Chamber of Commerce under number 60194235. Festivus Media B.V. is responsible for the manner in which your personal data is being collected, used and stored.

The Data we Process

Account and messages


In order to make use of our Platform, you need to create an account. To create your account we ask you to provide us with your name, email address and password. This information is mandatory. You can also add extra information, such as your profile picture, telephone number, location, gender, age, date of birth, physical characteristics, relationship status and sexual orientation or flirt preferences. Your extra information is saved in your account and you can update or delete this information at all times. Furthermore, this extra information may qualify as special category of personal data which we only process based on your consent. You are at all times entitled to withdraw your consent by sending an email to compliance@festivusmedia.com. Please be advised that if your messages to users of the Platform contain (special) personal data, we process that data in order to provide you the service.

Payment details
In order to gain full access to the Platform, which among other things includes the option of sending and receiving messages, you need to buy credits. For this purchase we process your payment details which include your phone number. In order to process your payment, you will be transmitted to the website of your bank, credit card company or other payment provider. You will be transferred back to the Platform once you have completed your payment.

Contact form
You can contact us by using the contact form on the Platform. In this contact form we ask you to provide us with the following information: name, email address and message. We use this information to reply to your questions, request and complaints.

Newsletter
You can sign up for our newsletters. If you have signed up for the newsletter, we will use the email address you provided to send you our newsletter. If you no longer wish to receive newsletters, you can use the unsubscribe option included in each newsletter.

Personal offers
On the basis of the personal information collected by Festivus Media BV, a profile is created. Based on this profile, we try to tailor our offers to you as well as possible. These offers are sent to you by email.

For this we use:

The functionalities that you use;

Your surfing behaviour on the website;

The amount that you spent on credits;

Your flirt preferences;

Data collected by using cookies.

This use of your personal data is based on your consent. If you no longer wish your information to be used for this purpose, you can withdraw your consent by sending an email to compliance@festivusmedia.com.

Statistical research
Festivus Media BV wishes to deliver services of the highest quality. In order to accomplish this Festivus Media BV needs to perform statistical research. Based on the outcome of the research we can make adjustments to our services and/or the Platform. Festivus Media BV uses your personal data for this statistical research. The results of the research are always aggregated. This means that the data in the research results can no longer be traced back to you.

Automatically generated data
Festivus Media BV requires certain information in order for the Platform to work as optimal as possible (for example, to display content correctly and to keep the Platform secure). That is why we collect automatically generated data on your use of the Platform. This information consists of:

the device type (i.e. tablet or smartphone) you use;

the IP address (and geolocation) of your device;

operating system of your device;

browser software you use;

web pages you visit;

the internet service provider that you use.

Third party disclosure
We will not provide your personal data to third parties without your consent, unless the following cases apply:

We provide your personal data to (sub)processors (inter alia the hosting party and entities that employ the people that reply to your messages) which may process personal data under the responsibility of Festivus Media B.V. Festivus Media B.V. assures that it has contractually guaranteed that these (sub)processors will not process data outside the scope of this Privacy Policy, and that technical and organizational measures are taken to safeguard your personal data against (inter alia) unintentional loss or destruction or damage of your personal data.

We may provide your personal data to any third parties if you have explicitly consented to the transfer for these parties to process your personal data, and/or insofar as this information cannot be traced back to you.

We may provide your personal data to third parties inhase we are obligated to do so under applicable law and/or regulations, as a result of a lawsuit and/or if we believe that this is necessary to protect our rights.

What we do with your information?

We will process your personal data for the following purposes and on the basis of the following legal grounds:

	Purpose	Legal basis
Account & Message	To provide the Platform and its functionalities to you and to bring you in contact with profiles that match your preferences.	The processing is necessary for the performance of a contract to which you are party. In case special categories of personal data are being processed, the processing is based on your consent.
Contact form	To answer any questions and / or to be able to contact you.	The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, i.e. in order to provide its (customer) services to you.
Newsletter	To subscribe you to our mailing list and send you updates on our service.	The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, i.e. in order to send you the newsletter to which you subscribed.
Personal offer	To send you personal offers	The processing is based on your consent.
Statistical research	to generate statistical data and to (anonymously) use this data for research purposes.	The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, i.e. in order to provide the website as user friendly as possible and to improve our services.
Automatically generated information	To secure, adjust and improve the Platform.	The processing is necessary for the purposes of the legitimate interests pursued by Festivus Media BV, namely for information security.
Third party disclosure	To provide information about you to third parties and/or to give access to third parties to information about you, providing, this is necessary for the execution of the services; you have given your consent; or this is necessary based on law and/or regulations, as a result of a lawsuit and/or if it is necessary to protect our rights.	The processing is necessary for the performance of a contract to which you are party; you have given consent to the processing of your personal data for this purpose; the processing is necessary for compliance with a legal obligation to which Festivus Media BV is subject.

Security

Festivus Media BV is committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, Festivus Media BV takes appropriate technical and organizational measures to protect your personal data against loss or any form of unlawful processing.

Furthermore, if personal data is stored outside the EEA, Festivus Media BV ensures that this storage is in accordance with the law and that an adequate level of protection is guaranteed. Festivus Media BV has signed the EU Model Clauses with these parties and / or the transfer of data is based on the EU-US Privacy Shield.

Links to other websites

The Platform may contain hyperlinks which take you to the website or application of a third party, such as social media sites. Festivus Media BV has no authority over those third party services and/or websites. For the use of those services and/or websites of third parties a separate privacy statement might be applicable. This Privacy Policy is exclusively applicable to personal data that is obtained through the Platform. Festivus Media BV does not accept any responsibility or liability for the (use and/or content of the) services and/or websites of third parties.

Storage term

Festivus Media BV will store your personal data as long as necessary to perform the purposes of processing as stated in this Privacy Policy.

Controlling your personal information

Under the privacy legislation, you have a number of rights as a data subject. This chapter of the Privacy Policy states these rights and how you can invoke these rights.

Response

Festivus Media BV will try to respond to your request as soon as possible, but in any case within four (4) weeks. If Festivus Media BV needs more time, Festivus Media BV will inform you of this. In no case Festivus Media BV will respond to you later than two months.

Your requests can be sent to compliance@festivusmedia.com. Please use the email address known to us so we can identify you. In order to ensure that the information you request is actually yours, we may ask you to send a valid proof of identity.

If Festivus Media BV cannot (fully) determine to which personal data your request relates, Festivus Media BV can ask you to (further) specify your request. The possibility exists that Festivus Media BV rejects a request from you, for example because your request is unfounded or excessive or because Festivus Media BV (legally) cannot or does not have to comply with your request. Festivus Media BV will also notify you of a rejection. Festivus Media BV informs you that you can, in case Festivus Media BV rejects your request, file a complaint with the Competent Data Protection Authority.

Right of access

You have the right to submit a request to find out whether Festivus Media BV processes personal data relating to you. If this is the case, Festivus Media BV will provide you with a copy of the personal data collected in accordance with the law.


Right to rectification

You have the right to submit a request for rectification of inaccurate personal data. If possible, you also have the right to provide additional personal data in order to complete the collection of your personal data.

Right to be forgotten

You have the right to request the deletion of (certain) personal data relating to you (the right to be forgotten). If your request is granted, Festivus Media BV will delete the relevant personal data.

Right to restriction of processing

You have the right to file a request to restrict the processing of your personal data. This means that, if the request is granted, Festivus Media BV will not process your personal data during the term of restriction.

Right to object

You have the right to, under certain circumstances, object to the processing of your personal data, for example if Festivus Media BV processes your personal data based on legitimate interest. If you object, Festivus Media BV will weigh your privacy interest against the business interest of Festivus Media BV. Should your interest override the interest of Festivus Media BV, Festivus Media BV will no longer process your personal data.

If your personal data is used for direct marketing purposes, you can always object to this processing. In that case Festivus Media BV will no longer process your personal data for that purpose.

Right to data portability

You have the right to submit a request for data portability. If granted, Festivus Media BV will make your data available to you in a structured, commonly used and machine-readable format in order for you to transfer it to a third party.

Can this privacy statement be amended?

This Privacy Policy may be amended from time to time. The amendments will be published on the Platform. Should any material change be executed, you will be informed of such change.

Complaints or questions?

In case you have any complaints or questions with regard to this Privacy Policy and the manner in which Festivus Media BV processes your personal data, you have the right to report this via compliance@festivusmedia.com. In case you and Festivus Media BV are not able to resolve your complaint(s) with regard to the aforementioned data processing, you are also have the right to file a complaint to the competent Data Protection Authority.

Updated: October 2018