1. Preambule
1.1 At Fundozer kft., with its registration address at 1054 Budapest, Honved u 8.1. em. 2, Hungary and VAT Number HU 29215863 (“Fundozer”, “We”, “Us” or “Our”), accessible from fundozer.com, one of our main priorities is the privacy of visitors of our website fundozer.com (“Site”) / applications (“Apps”) and/or users who use the services we provide (“Services”). Hereafter we refer to users and visitors as “You”, “Your” or “User”. This Privacy Policy document contains types of information that is collected and recorded by Fundozer and how we use it.
2. Information We Collect
2.1 Fundozer collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each Your request. Fundozer's purpose in collecting non-personally identifying information is to better understand how You use the Site, Apps and/or Services. From time to time, Fundozer may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of the Site, Apps and/or Services.
2.2 Fundozer also may collect potentially personally-identifying information like Internet Protocol (IP) addresses of Users.
3. Advertisements and Opt-Out
3.1 Ads appearing on our Site or Apps may be delivered to Users by advertising partners, who may set cookies. These cookies allow the ad server to recognize Your device each time they send You an online advertisement to compile information about You or others who use Your device. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to You. This Privacy Policy covers the use of cookies by Fundozer and does not cover the use of cookies by any advertisers.
3.2 Such advertising partners may combine and use information from websites or applications on Your current browser or device with information from Your other browsers or devices for advertising purposes. To opt-out of such interest-based advertising and/or cross-device targeting, please use the methods provided below for opting out on each of Your browsers and on each of Your devices:
Network Advertising Initiative (NAI) – http://optout.networkadvertising.org/
Digital Advertising Alliance (DAA) – http://www.aboutads.info/choices/
Digital Advertising Alliance Canada (DAAC) – http://Youradchoices.ca/choices
Digital Advertising Alliance EU (EDAA) – http://www.Youronlinechoices.com/
3.3 Please note that opting out of interest-based advertising and cross-device targeting does not mean You will no longer receive online advertising. It does mean that the advertising partners from which You have opted out of receiving interest-based advertising or cross-device targeting by using the methods provided above will no longer deliver ads tailored to Your Web preferences and usage patterns on a particular web browser or device.
4. Links To External Websites
4.1 Our Site, Apps and/or Services may contain links to external websites that are not operated by us. If You click on a third party link, You will be directed to that third party's website. We strongly advise You to review the Privacy Policy and terms and conditions of every website You visit.
4.2 We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party websites, products or services.
5. Cookies and Web Beacons
5.1 Like any other website, Fundozer uses 'cookies'. These cookies are used to store information including Your preferences, and the pages on the website that the User accessed or visited. The information is used to optimize the Users' experience by customizing our web page content based on Your browser type and/or other information.
6. Use and Purpose of Information We Collect
6.1 Fundozer may make use of personal information to assist in the operation of the Site, Apps and/or Services, to ensure delivery of the services You may request, to provide information for Your efficient use of the Site, Apps and/or Services, to carry out marketing activities, to analyze the performance of certain parts of the Site, Apps and/or Services, and to enforce this Privacy Policy.
6.2 The personal information we collect may be used and/or disclosed without prior notice to You in specific cases where Fundozer is required to do so in accordance with the applicable law or a legitimate good faith belief that such action is deemed necessary or is required in an effort to comply with applicable laws and/or to safeguard and preserve Your rights, Fundozer, other users and the public.
6.3 We may further request Your consent to use or disclose Your personal information for different purposes.
7. Anonymous/Aggregated Information.
7.1 Anonymous or aggregated information that does not identify You personally, like usage and metrics information, may be shared with others, including partners, developers, potential investors, marketers, and business partners. Anonymous information helps us understand trends and User needs so that we can better design new products and services and refine existing products and services to serve our customers better.
8. Children's Personal Information.
Fundozer kft's., Sites, Apps, and/or Services are targeted at different audiences, including adult people, children, and adolescents. Below we provided the information regarding the collection of children's personal data on our Sites, Apps, and/or Services.
8.1 Children’s personal information on our Sites, Apps, and/or Services directed at adult users.
8.1.1. Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
8.1.2. Fundozer does not knowingly collect any Personal Identifiable Information from children under the age of 13 on our Site, Apps, and/or Services directed at adult users. If You think that Your child provided this kind of information on the Site, Apps, and/or Services directed at adult users, we strongly encourage You to contact us immediately and we will do our best efforts to promptly remove such information from our records.
8.2. COPPA Policy.
Fundozer kft., adhere to the Children’s Online Privacy Protection Rule (“COPPA”) on all its own Sites, Apps, and/or Services directed at children.
8.2.1. By using our applications that are specifically directed at children, users must certify that they are at least 13 years of age at the time of registration. If they are not 13 years of age, users must have consent from a parent or guardian to maintain usage of our services per the COPPA. Members represent that they are 13 years of age or have permission to represent themselves by transmitting data via our servers.
8.2.2. We may collect non-personally identifiable information (like IP address or UID) automatically to provide functionality and support our operations, however, we do not collect, use or share the personal data of your children (e.g. phone number, address, email, name, birth date, etc.). Please help us protect your children’s privacy by instructing them never to provide personal information (like their full name, e-mail address, home address, telephone number, etc.).
8.2.3. We consciously take all steps to prevent children from posting and disclosing personal contact information on our Site, Apps, and/or Services.
8.2.4. In compliance with COPPA regulations, we do not disclose any kind of information about users aged 13 or under without familial consent.
8.2.5. If You want to delete any kind of information that your children provided on our Site, Apps, and/or Services, we strongly encourage You to contact us at legal@fundozer.com immediately and we will do our best efforts to promptly remove such information from our records.
8.2.6. If you have any inquiries regarding collecting or maintaining your/your children`s personal information please contact us at legal@fundozer.com.
9. Security
9.1 Fundozer endeavors to take every precaution to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of the User’s personal information under our control. However, as it is not possible to ensure an absolute level of security in regards to electronic transmission and storage of data, Fundozer cannot provide a reasonable guarantee a complete and perpetual security of such information.
10. California Privacy Notice
If You are a resident of the State of California, we provide You with information on how to exercise Your disclosure choice options such as Your right to opt-out (which we may sometimes refer to as “unsubscribe”) or opt-in for use of Your Personal Information by third parties (such as advertisers and promotional partners) for marketing purposes.
10.1 What data is collected?
In the last 12 months we have collected the following Personal Information:
Upon Your visit - Device type, IP address, GEO (not precise; country/state/city only), version and type of OS;
The chart below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help You understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices can be found in this Privacy Policy.
Category |
Examples |
Collected |
A. Identifiers. |
A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. |
YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, address, telephone number, passport number, driver's license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. |
NO |
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
NO |
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
NO |
E. Biometric information. |
Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
F. Internet or other similar network activity. |
Browsing history and search history within our website; information on a consumer's interaction with a website and advertisement. |
YES |
G. Geolocation data. |
Physical location or movements. |
NO |
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
NO |
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
NO |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
NO |
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
However, please keep in mind that we do not collect any personally identifiable information, unless You provide it directly to us via Site’s contact form.
10.2 What are Your rights?
Under the California Consumer Privacy Act (“CCPA”) You are granted certain rights with respect to Your Personal Information. Only You, a resident of the State of California, a person that You authorize to act on Your behalf, or an entity registered with the California Secretary of State that You authorize to act on Your behalf, may exercise these rights. We are permitted to reject Your request if we reasonably determined that You are not a resident of the State of California.
California residents have certain rights with respect to the Personal Information collected by businesses. If You are a California resident, You may exercise the following rights regarding Your Personal Information, subject to certain exceptions and limitations:
The right to know any or all of the following information relating to Your Personal Information we have collected and disclosed in the last 12 months, upon verification of Your identity: the categories and specific pieces of Personal Information we collect, use, disclose, the categories of sources from which we collected Your Personal Information, our purposes for collecting or selling Your Personal Information, the categories of Your Personal Information that we have disclosed for a business purpose, and the categories of third parties with which we have shared Personal Information;
The right to request that we delete the Personal Information we have collected from You or maintain about You.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. However, please note that if the exercise of these rights limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide You our Services or engage with You in the same manner.
10.3 How to exercise Your rights?
To exercise any of the above rights, please contact us at legal@fundozer.com (alternatively You may use the “Do Not Sell My Personal Information” button in the footer of every Site page) and submit the required verifying information.
We use any Personal Information collected from You in connection with the verification of Your request solely for the purposes of verification.
We may require additional information to verify Your requests to exercise Your rights or understand the scope of Your request, although You will not be required to create any account on the Site to submit a request or have it fulfilled. You may designate an authorized agent to make a CCPA request on Your behalf.
Please consider that we do not sell Personal Information collected through our Services, including not knowingly selling Personal Information about consumers under the age of 16.
10.4 Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform You of the reason and extension period in writing. We will deliver our written response by email. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide Your Personal Information that is easily readable and should allow You to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell You why we made that decision and provide You with a cost estimate before completing Your request.
11. EUROPEAN UNION, UK AND SWITZERLAND ADDITIONAL NOTICE
11.1 We respect Your privacy rights and provide You with reasonable access and rights to the Personal Data, as this term is referred to for individuals located in the European Economic Area (EEA), pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as GDPR), that You may have provided through Your use of our Services.
11.2 Where we transfer Your Personal Information outside the European Economic Area (EEA) to countries that do not offer an appropriate level of protection, we rely on approved standard EU Model Clauses so these transfers are conducted in accordance with applicable laws and using adequate and appropriate safeguards.
11.3 We have assigned Data Protection Officer (DPO). You may reach him via legal@fundozer.com. Our DPO is tasked with ensuring that we acknowledge and abide its data protection responsibilities.
11.4 If You live in one of the countries of the European Economic Area (EEA) and wish to access, amend, delete, transfer, don’t store or don’t process any Personal Data we hold about You, You may contact our DPO at legal@fundozer.com.
11.5 You may update, correct, or delete Your Personal Data and preferences at any time by request to us at legal@fundozer.com.
11.6 We will not store personal information for more than 24 months from the date of Your last active session on the Site, Apps or Services for more than 24 months from the date of termination of an agreement between us and You (whichever is earlier), however we may retain information You submit for prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
12. Changes to Privacy Policy
12.1 Fundozer reserves the right to update and/or change the terms of the Privacy Policy, and as such We will post those change to the Site so that our Users are always aware of the type of information We collect, how it will be used, and under what circumstances, if any, We may disclose such information. Changed to the Privacy Policy become effective upon the date of posting them on the Site. It is Your responsibility to regularly review the Privacy Policy and Your continued usage of the Site after the posting of the changes indicated Your agreement to such changes.
13. How to Contact Us
13.1 If You have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at legal@fundozer.com
Last Updated: May 7, 2021