PRIVACY POLICY

This Privacy Policy was last updated on April 8, 2020.

At Frateri, (“Company”, “we”, “us”, or “our”) we care deeply about protecting your privacy. We’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of your personal information that we receive through our website located at https://frateri.com (the “Site”) and via our mobile device application (the “App”).  When you visit our Site and use our services, you trust us with your personal information. We take your privacy very seriously and in this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. 

This Privacy Policy applies to all information collected through our Site, and/or any related services, sales, marketing or events (we refer to them collectively in this Privacy Policy as the (“Services“).  Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meaning as in our Terms and Conditions. So, please make sure that you have read and understood our Terms and Conditions.

By using any of our Services, or by providing us your personal information, you agree to this Privacy Policy and agree to be bound by our Terms and Conditions. If there are any terms in this Privacy Policy that you do not agree with, please discontinue the use of our Site and our services. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at: info@frateri.com.

ABOUT US

Frateri is a personality typology website. At Frateri, you will find the best recommendations or contents on personality types and traits and other psychology related content. We offer you access to our services through our Site and/or App and we provide directions to recruiters and business owners that want to assess candidates and employees. We also offer our Services to job seekers who want to practice the psychometric tests and know more about themselves and other persons interested in personality content.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT WILL HELP YOU MAKE INFORMED DECISIONS ABOUT SHARING YOUR PERSONAL INFORMATION WITH US.  

  1. WHAT INFORMATION DO WE COLLECT?
  1. Personal information that you disclose to us.

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Site and/or App or otherwise by contacting us.

The personal information that we collect depends on the context of your interactions with us and the Site and/or APP, the choices you make and the products and features you use. The personal information we collect can include the following:

  1. the personal information  you provide when you register to use our Site and/or App, including your name, email address and date of birth;
  2. the personal information you provide for financial account information, such as credit card number and other payment information. Please note, we do not retain credit card information;
  3. the personal  information you provide when you subscribe to our services ,what you subscribe, and how frequently you subscribe;
  4. the personal information you provide when you report a problem with our Site or when we provide you with customer support;
  5. the personal information you provide when you correspond with us by phone, email or otherwise; and
  6. the personal data you provide when you connect your account to another service such as LinkedIn, Facebook or Twitter, the other service may send us your registration or profile information on that service that you authorize. This information enables cross-platform data sharing to improve your user experience.
  1. Information automatically collected

We automatically collect certain information when you visit, use or navigate the Site and/or App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and/or App and other technical information.  If you access our Site with your mobile device, we may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address. This information is primarily needed to maintain the security and operation of our Site and/or App, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in Cookie Policy.

  1. Information collected from other Sources

We may acquire information from other trusted sources to update or supplement the information that you provide or that we collect automatically. We may use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services or other offers that may be of interest to you, and for internal business analysis or other business purposes. 

  1. Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our online services, as well as information collected offline, across other computers or devices that you may use, and from third party sources.

  1. HOW DO WE USE YOUR INFORMATION?

We use your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  1. To send you marketing and promotional communications for Business Purposes and/or with your consent. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you.
  1. ii.To send administrative information to you for information related to your account, our business purposes, and/or for legal reasons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms and conditions, and this Policy.
  1. iii.Deliver targeted advertising to you for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. 
  1. iv.Request Feedback for our Business Purposes and/or with your consent. We may use your information to request feedback and to contact you about your use of our Site.
  1. v.To protect our Site for Business Purposes and/or Legal Reasons.  We may use your information as part of our efforts to keep our Site safe and secure (for example, for fraud monitoring and prevention).
  1. vi.To enable user-to-user communications with your consent. We may use your information in order to enable user-to-user communications with each user’s consent.
  1. vii.To enforce our terms, conditions and policies for our Business Purposes and as legally required.
  1. viii.To respond to legal requests and prevent harm as legally required. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  1. ix.For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site, products, services, marketing and your experience.
  1. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We do not share your personal information except in the limited circumstances described here. We may share your personal information in the following situations:

  1. Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  1. ii.Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  1. iii.Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. For example, payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Site, which will enable them to collect data about how you interact with the Site over time.  This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand your online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  1. iv.Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  1. Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to our Site and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy for further information.
  1. vi.Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  1. vii.Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
  1. viii.With your Consent. We may disclose your personal information for any other purpose with your consent.
  1. ix.Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Site) or otherwise interact with public areas of the Site, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity.
  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

  1. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Your information, including Personal Information that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accepting this Policy, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

  1. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

This Privacy Policy only addresses the collection, processing and use (including disclosure) of data by us. This Site may contain various links to third-party websites. These websites may provide additional information, goods, services and/or promotions. These sites are owned and operated independently of Frateri, and have their own separate privacy and data collection practices. Any information you provide to these websites will be governed under the terms of their privacy policy, if any. Frateri has no responsibility or liability whatsoever for the independent actions or policies of these independent sites, and is not responsible for the content or privacy practices of such websites.

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. Operationally, access to personal information is restricted to authorized personnel who are under duty to maintain the confidentiality and security such information. We will take reasonable and appropriate technical measures to ensure that your personal information is stored in a secure manner. However, we shall have no liability for disclosure of data due to errors in transmission or the fraudulent, negligent or other illegal acts of a third party, such as “hacking”. Any transmission of personal information on or through the use of our Site is at your own risk. You should only access to the Site and our Services within a secure environment. Should you have a reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.

  1. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 16 years of age.  By using the Site, you represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site.  If we learn that personal information from users less than 16 years of age has been collected, we will take reasonable measures to promptly delete such data from our records.  If you become aware of any data we have collected from children under age 16, please contact us at info@frateri.com

  1. WHAT ARE YOUR PRIVACY RIGHTS?
  1. Account information: You may at any time review or change the information by contacting us using the contact information provided below.

You can request to delete or update your information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and/or comply with legal requirements.

  1. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails. 

You can also opt-out by contacting us using the contact information provided below.

  1. WHAT IF YOU ARE EEA RESIDENTS?

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Our privacy practices intend to meet the requirements of the General Data Protection Regulation of the European Union (“GDPR”).

If you wish to be informed about what personal data, we hold about you and if you want it to be removed from our systems, please contact us.

Under GDPR, EAA residents have specific rights related to their personal information.

  1. Right to access: You have the right to request access to your personal information held by us. Request is to be made in writing, electronically and information will be provided in a commonly used electronic format. Request will be handled within one month of receipt of the request, and free of charge with exception of where requests are manifestly unfounded or excessive, we hold the right to charge reasonably fee taking into account the administrative costs of providing that information.
  2. Right to rectification: you have the right to have personal information rectified if inaccurate or incomplete. Where the personal information in question has been disclosed to a third party, they will be made aware of the rectification where possible. 
  3. Right to erasure: You have the right to request the deletion or removal of personal data in the following circumstances:

Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed. When you withdraw consent. When you object to the processing and there is no overriding legitimate interest for continuing the processing. The personal data was unlawfully processed. The personal data has to be erased in order to comply with a legal obligation. This does not provide an absolute “Right to be forgotten”. Where the personal data in question has been disclosed to a third party, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so. Personal data will be erased by removal from our internal and cloud servers.

  1. Right to restrict processing: You have a right to “block” or suppress processing of personal data if you contest its accuracy; have objected to the processing; processing is unlawful and you oppose erasure; we no longer need the personal data but you require the data to establish, exercise or defend a legal claim. Where the personal data in question has been disclosed to a third party, we will inform them about the restriction on processing of the data, unless it is impossible or involves disproportionate effort to do so.
  2. Right to data portability: You have the right to obtain and reuse your personal data for your own purposes. Requests are to be made in writing, electronically, and will be handled within one month of receipt of the request.
  3. Right to object: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics. Requests will be dealt with by immediate effect with no right for refusal.

Should a data breach occur, we have compliant procedures in place to investigate and report the matter to the individual. In the event of a breach, it will be reported to you within 72 hours of discovery. A record of any breaches will be kept by Frateri.

If you wish to exercise any of these rights, please contact us. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your
request as soon as reasonably practicable and in any event, within one month of your request. 

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

  1. WHAT ARE THE PRIVACY RIGHTS FOR CALIFORNIAN RESIDENTS?

This section 12 applies to Californian residents and supplements the information contained in this Policy. It applies solely to all visitors, users, and others who reside in the State of California, the United States of America. We adopt this notice to comply with the California Consumer Privacy Act (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Your California privacy rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. 

  1. Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  1. The categories of Personal Information that we have collected.
  2. The categories of sources from which we collected Personal Information.
  3. The business or commercial purpose for collecting and/or selling Personal Information.
  4. The categories of third parties with whom we share Personal Information.
  5. Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
  6. Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.  
  1. Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months. 
  1. Deletion.  You can ask us to delete the Personal Information that we have collected from you.
  1. Opt-out of sales.  If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. We share your Personal Information with third parties in the following circumstances, which California law classifies as a “sale” of your Personal Information:
  1. supplying your data to third parties with your express consent (e.g. where you opt in to receive third party marketing or where you have requested to be contacted by a third party);
  2. supplying your data to list brokers (but only where you have consented to be contacted by third parties);
  3. supplying attendee data to third parties who provide services in connection with our events, and sending your data to suppliers of certain products and services (where you have consented to hear from such third parties); 
  4. like many companies, we use services that help deliver interest-based ads, content and services to you.  California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads, content and services more likely to interest you. 
  1. Minors.  If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 16 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
  1. Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.  

You may exercise your California privacy rights by submitting a request form or emailing info@frateri.com quoting ‘California Privacy Rights’ in the subject header.

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

To learn about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws. 

  1. DO WE MAKE UPDATES TO THIS POLICY?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is published. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

  1. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

We welcome your comments or questions about this Policy. You may contact us in writing at: info@frateri.com.