1. Who we are
1.1 We are FS Holding LTD located at Cyprus, 111020, 229 Makariou III Avenue Meliza Court, Limassol City, 3105 Limassol.
2.1 By making available the Services we, acting reasonably and in good faith, believe that you:
(a) provide true information about yourself to the extent necessary for use of the Services;
2.2 We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3. Information we collect about you
3.2 We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.
|Information Collected||Purpose||Legal Basis|
|1. Your e-mail adress||We use this information in order to manage and administer the Services provided to you. We use this information in order to to communicate with you||Legitimate interests|
|2. Data you provide for registering on the Site including your name, surname, date of birth, gender, mobile phone number, shipping and billing address and/or email||
We use this information in order to manage and administer the Site including providing our services to you. We use this data to enable us to fulfill our obligations to you as part of the Site Services.
We also use this information in order to provide you with recommendations we feel you may be interested in, updates and information on our products and services we think you may be interested in.
We use this information in order to generate recommendations and tailor and improve the adverts that are presented on the Site.
|Legitimate interests Performance of our contract with you|
|3. Additional data received when you access the Site, including information regarding technical devices, technical interaction with the Site (your host IP-address, your operating system, type of a browser, geographic position, your installed apps, the Internet provider) and your browsing behavior and further actions on the Site.||Additional data received when you access the Site, including information regarding technical devices, technical interaction with the Site (your host IP-address, your operating system, type of a browser, geographic position, your installed apps, the Internet provider) and your browsing behavior and further actions on the Site.||Legitimate Interests|
|5. Information that is received as the result of your using payment functionality on the Site (e.g. first and last four digits of your card number that are needed for the option of matching these details with user’s id number).||Information that is received as the result of your using payment functionality on the Site (e.g. first and last four digits of your card number that are needed for the option of matching these details with user’s id number).||Legitimate interests Performance of our contract with you|
|6. Information that you submit to us via contact form when send us an email (certain information about you including your name, address and other related details you provide)||
Purpose: We use the information we collect from you for the purposes of:
• Providing you with an appropriate reply to your request;
• Protecting the rights and interests of FS Holding LTD and others.
3.3 We process your data for the purposes identified above, as necessary, (1) for the legitimate interests of us and other third parties, including maintaining and administrating the Services; (2) to comply with our legal obligations;
3.4 "Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law."
4. Data sharing
4.1 "We may share your personal information with companies, organisations and individuals inside and outside of the FS Holding LTD where one of the following circumstances applies:
• to other companies in our group, for administrative and management, subject to us taking reasonable measures to ensure that your information is kept secure at all times;
• to trusted third parties businesses, or persons who perform services and process your personal information for us for the purposes listed above, based on our instructions, subject to us taking reasonable measures to ensure that your information is kept secure at all times; in particular we may share your information with delivery and shipment companies such as DHL, UPS, FedEx, Ceska Posta, SDEK Russia; and
• to companies, organisations or individuals outside of the FS Holding LTD if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:
o meet any applicable law, regulation, legal process or enforceable governmental request;
o detect, prevent or otherwise address fraud, security or technical issues;
or o protect against harm to the rights, property or safety of FS Holding LTD, our customers or the public, as required or permitted by law.
4.2 We may share your data with our affiliates. Sometimes we may also need to share your data with a third party in order to provide our services to you or to administer the Site.
4.3 FS Holding LTD and our selected third party partners with our permission, using their own ad servers, can show advertisements to you.
5. International Transfers
5.1 We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.
5.2 The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
6. Retention Periods
6.1 We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
6.2 You may request to remove your data on our Services by contacting the Service support (see Section 10 for details).
7. Your Rights
7.1 "You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to the processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority. "
7.2 If you would like to exercise these rights, please contact Support Service at [email protected] or send your request to us, in writing to 229 Makariou III Avenue Meliza Court, Limassol City, 3105 Limassol. We will aim to respond to you within 30 days from receipt of the request. We will need to verify your identity before we are able to disclose any personal data to you.
8. Security Measures
8.1 We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
9. Changes to this Policy
10. Contact Us
10.2 All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
10.3 The e-mail address of our DPO is [email protected]