Privacy Notice

1. What does fnfwall do?

fnfwall is the platform to let you know someone as their friends and family do. Our Website (located at https://fnfwall.com) or “Platform” provides information about us and allows individuals to sign-up as fnfwall Users.

The wall that fnfwall Users are able to create is referred to in this Privacy Notice as “User Wall“. User Wall is by default not accessible by the public.

We are headquartered in Pune, India. For more information about fnfwall, please see the “About” section of our Website.

2. How does this Privacy Notice apply to me?

This Privacy Notice only applies to personal information we collect as a controller from:

• visitors to our Platform (“Platform Visitors”);
• individuals, or representatives of individuals that sign up to use our fnfwall services via a paid plan (“Paid Plan Users”) or free plan (“Free Plan Users“), together our “fnfwall Users“;
• individuals that visit and interact with User Walls (“Wall Visitors”);
• individuals who respond to our surveys, marketing materials or participate in trade promotions or competitions that we may run from time to time.

This Privacy Notice, applies to the processing of personal information by fnfwall as a controller. When we talk about fnfwall acting as a “controller”, we mean that fnfwall determines the purpose and the means of the processing (i.e. we make decisions about how we will handle your personal information).

If you provide us with information about another person (if, for example, you are a representative of an individual), you must provide them with a copy of this Privacy Notice and let that other person know that we use their personal information in the ways set out in this Privacy Notice.

3. What personal information do we collect?

The personal information that we may collect about you broadly falls into the following categories:

• Information you provide voluntarily: When you sign up to become a fnfwall User, use or interact with our fnfwall services or staff, visit our Platform, visit a User Wall, respond to a survey or participate in a trade promotion we may ask you to provide personal information voluntarily. For example, if you are a Free Plan User we will ask you to provide your email address, name, username, and marketing preferences. If you are a Paid Plan User we will also ask for your full name, billing email address, and payment method in order to facilitate billing. You may also provide personal information voluntarily if you respond to our surveys, marketing materials, or through your participation in trade promotions and competitions we may run from time to time.
• Information that we collect automatically: When you visit our Platform, use our fnfwall services, interact with a User wall, respond to a survey or participate in a trade promotion we collect certain information automatically from your device. We may collect information about how your device has interacted with our Platform, fnfwall services or User walls, including the walls accessed and stories clicked.
  
  Collecting this information enables us to better understand you, and what content is of interest to you. We use this information for our internal analytics purposes, to improve the quality and relevance of our Platform and fnfwall services, and in future to provide hints and tips to our fnfwall Users and to make recommendations of walls you might be interested in viewing. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “How do we use cookies and similar tracking technology” below. Further, we may undertake automatic scanning of User walls and stories to determine if any content should be removed or any User walls should be suspended in line with our Community Standards and/or Terms of Service.
• Information that we obtain from third party sources: From time to time, we may receive personal information about you from third party sources (including from service providers that help us run marketing campaigns or competitions and our partners who help us provide our fnfwall Services). In all cases, we will only receive such data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
• Children’s data: Our services are not intended for use by children under the age of 18 (the “Age Limit”). If you are under the Age Limit, please do not use the fnfwall services and do not provide us with your personal information. If you are a parent or guardian and you are aware that an individual (of whom you are a parent or guardian) under the Age Limit has provided us with personal information, please contact us. We will, upon notice or discovery, take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about that individual.
• Recruitment: In future, when we begin with our hiring, if you apply for a role at fnfwall, then the personal information will only be collected, used and accessed for recruitment purposes only. The data will be retained for a maximum of two years and will then be anonymized for statistical purposes.

4. Why do we collect your personal information?

In general, we will use the information we collect for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. These include:

• To provide and deliver the fnfwall services and to assess, maintain and improve the performance and functionality of the fnfwall services.
• To ensure the fnfwall services are relevant to you and your device, to notify you about changes to the fnfwall services, and in future to deliver targeted and/or localized content based on your user data, location and preferences.
• For consumer research and to allow you to participate in surveys or interactive features of the fnfwall services when you choose to do so.
• To provide customer support and to process and respond to a request, complaint or Intellectual Property Report or Counter Notice that you may have made.
• To monitor the usage of the fnfwall services and to detect, prevent and address technical issues.
• To process payments for Paid Plan Users.
• To conduct business planning, reporting, and forecasting.
• To deliver promotional materials, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted out of receiving such information.
• For the administration of our business including for fulfilling and exercising our obligations and rights, exercising or defending legal claims, to comply with our legal obligations and law enforcement requests, and managing the relationship with you.
• To verify your identity and to detect fraud and potential fraud, including fraudulent payments and fraudulent use of the fnfwall services.
• To include fnfwall User content as part of our advertising and marketing campaigns to promote fnfwall.
• To inform our algorithms so we can deliver the most relevant recommendations to you in future, including of User walls that you may be interested in.

5. Legal basis for processing personal information

Our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific circumstances in which we collect it.

However, we will normally collect personal information from you only where we have your consent, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). As indicated above, we require certain personal information to enter into a contract with you as a fnfwall User. Without your personal information, we will be unable to provide you with fnfwall services available to fnfwall Users.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to develop and improve the fnfwall services, to provide additional functionality, to ensure appropriate security and content moderation. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us.

6. Who may we disclose your personal information to?

We may disclose your personal information to the following categories of recipients:

• to our third-party services providers (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Platform or fnfwall services), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. We also facilitate third party payment providers and this is set out in more detail below;
• to the extent we introduce social media log-ins, we may provide personal data to the relevant social media provider to facilitate such log-in;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and
• to any other person with your consent to the disclosure.

In order to facilitate paid products and/or services within the fnfwall service, we use third party payment processors. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policies and their own terms and conditions. These payment processors adhere to the standards set by payment card industry data security standards (“PCI-DSS”) as managed by the Payment Card Industry Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:

• Razorpay (their privacy policy can be viewed at https://razorpay.com/privacy/);
• PayPal (their privacy policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full);

7. Disclosure of personal information to other countries

Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, fnfwall may transfer personal information to India and other countries in which we may expand our business. fnfwall may also subcontract certain activities and share your personal information with third-parties located outside of India (which is where we are headquartered).

The countries in which these organizations are located will vary, but, in the course of our business operations, we generally disclose personal information to organizations located in India. Such transfers are made in order to provide the fnfwall services and carry out the activities specified in this Privacy Notice.

However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Privacy Notice and applicable data protection laws. We have implemented similar appropriate safeguards with our third-party service providers. No transfer of your personal information will take place to an organization or another country unless we believe there to be adequate controls in place including the security of your data and other personal information.

8. How do we use cookies and similar tracking technology?

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you.

9. How long do we retain your personal information?

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods relevant to legal action.

10. How do we secure your personal information?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

In addition, we limit access to your personal information to employees, agents, contractors and other third-parties who have a business need for access. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Therefore, we have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. What are your rights in relation to personal information?

You have the following data protection rights - If you wish to access, correct or update your personal information, you can do so at any time by updating your account section.

Depending on the country which you live in and the laws that apply to you, you may also have additional data protection rights. If you are resident in the UK or the European Economic Area, these rights include:

• To delete your personal information. You can do so at any time by choosing the delete option on any of your published stories or delete your account.
• To object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by connecting with us on support@fnfwall.com.
• To opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time by connecting with us on support@fnfwall.com. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with us using the contact details provided under the Contact Us heading below. We will confirm receipt of your complaint and, if we believe necessary, we will open an investigation.

We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, then we will contact you with the result as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may contact the local privacy and data protection authorities in your jurisdiction.

13. Changes to This Privacy Notice

We may update our Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy notice, it’s your responsibility to check this page now and then for any changes.

Your continued use of the Platform after any changes to the Privacy Notice is taken as your acceptance of the revised policies. If you don’t agree with the changes, we ask you to please stop using fnfwall and terminate your account.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

14. Contact

If you have any questions about this Privacy Notice, our privacy practices or if you would like to make a request about any personal information we may hold about you, including correction of personal information, please contact us:

• By email using: support@fnfwall.com
• By visiting this page on our Platform: fnfwall.com/contact.php
• By post at Jaglen Platforms Pvt Ltd, 204, Sapphire Chambers, First Floor, Suite #1075, Baner Gaon, Pune, Haveli, Maharashtra, India, 411045.

fnfwall

Jaglen Platforms Pvt Ltd