- This policy sets out how we handle your personal information if you’re a Friends Of Habanos (hereafter, FOH) user or visitor to our Sites. It applies across Friends Of Habanos, FOH Classifieds, Kenfessions (the “Sites”).
The type of personal information we collect
- We collect certain personal information about visitors and users of our Sites.
- The most common types of information we collect include things like: user-names, member names, email addresses, IP addresses, other contact details, survey responses, blogs, photos, support queries, forum comments, content you direct us to make available on our Sites (such as item descriptions) and web analytics data.
How we collect personal information
- We collect personal information directly when you provide it to us, automatically as you navigate through the Sites, or through other people when you use services associated with the Sites.
- We collect your personal information when you provide it to us when you complete membership registration, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
How we use personal information
We will use your personal information:
Where this is necessary for purposes which are in our legitimate interests. These interests include:
- operating the Sites;
- verifying your identity when you sign in to any of our Sites;
- responding to support tickets, and helping facilitate the resolution of any disputes;
- updating you with operational news and information about our Sites and services e.g. to notify you about changes to our Sites, website disruptions or security updates;
- carrying out technical analysis to determine how to improve the Sites and services we provide;
- monitoring activity on the Sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;
- managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
- managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
- training FOH staff about how to best serve our user community;
- improving our forum community;
- providing general administrative and performance functions and activities; and
Where you give us consent:
- providing you with marketing information which we feel may interest you; and
- For purposes which are required by law.
- For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
- Where this is necessary for purposes which are in our legitimate interests. These interests include:
When we disclose your personal information
We will disclose personal information to the following recipients:
- subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers which are located in Australia, US; technical and customer support services which are located in Australia; marketing and analytics services which are located in Australia; security and fraud prevention services which are located in Australia; subscription management services which are located in Australia; identification verification services located in Australia. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
- our professional advisers (lawyers, accountants, financial advisers, etc.) which are located in Australia.
- regulators and government authorities in connection with our compliance procedures and obligations;
- a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
- a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
- a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
- a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
- other recipients where we are authorised or required by law to do so.
Where we transfer and/or store your personal information
- We are based in Australia so your data will be processed in Australia. Some of the recipients we have described in the section above, and to whom we disclose your personal information, are based outside Australia. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How we keep your personal information secure
- We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in Australia. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.
How you can access your personal information
- You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites at any time. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy.
Marketing Choices regarding your personal information
- Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving information from us), we send you marketing communications by email containing information that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
- You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.
Cookies and web analytics
- For general information on cookies, see http://www.allaboutcookies.org.
When you visit our Sites, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
- your IP address or proxy server IP address’;
- the domain name you requested;
- the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
- the date and time of your visit to the website;
- the length of your session;
- the pages which you have accessed;
- the number of times you access our site within any month;
- the file URL you look at and information relating to it;
- the website which referred you to our Sites; and
- the operating system which your computer uses.
Information about children
- Our Sites are not suitable for children under the age of 18 years, so if you are under 18 we ask that you do not use our Sites or give us your personal information.
Information you make public or give to others
How long we keep your personal information
When we need to update this policy
- We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
- When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
If you’re a user or visitor in the European Economic Area these rights also apply to you:
- For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
How you can access your personal information
- You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
- These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
- Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
- If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
Friends Of Habanos, effective date 25 May 2018.