Privacy Policy
Last Updated: June 10, 2021
In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Flycatcher Ltd. (together, “Flycatcher” “we”, “our” or “us”) use, collect, and store personal data we collect or receive from or about you (“you”) such as in the following use cases:
- When you browse or visit our website, https://www.flycatcher.toys/ (“Website”);
- When you make use of, or interact with, our Website
- When you subscribe to our distribution list(s) / newsletter(s)
- When you contact us (e.g. submit a request)
- When you shop our products through Shopify on store.flycatcher.toys (“Store”)
- When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
- When we use the personal data of our resellers, distributors, agents, partners and/or finders (e.g. contact details)
- When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” or “personal information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.
Table of contents:
- What information we collect, why we collect it, and how it is used
- How we protect and retain your personal data
- How we share your personal data
- Additional information regarding transfers of personal data
- Your privacy rights
- Use by children
- Interaction with third party products
- Log files
- Analytic tools
- Specific provisions applicable under California privacy law
- Contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.
|
Specific personal data we collect |
Why is the personal data collected and for what purposes? |
Legal basis (GDPR only, if applicable) |
Third parties with whom we share your personal data |
Retention period |
Consequences of not providing the personal data |
|
|
When you browse or visit our Website and/or the Store |
||||||
|
Cookies, analytic tools and log files. For more information, please read our cookies policy |
|
Consent Legitimate interest (e.g. essential cookies) |
3rd party platforms such as for the following purposes: |
For more information, please read our cookies policy |
Certain Website and/or the Store features may not be available Read more about the purposes of each cookie here |
|
|
When you make use of, or interact with, our Website |
||||||
|
When you subscribe to our distribution list(s) / newsletter(s) |
||||||
|
|
Consent |
3rd party platforms such as for the following purposes:
|
Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. |
Cannot send you marketing communications |
|
|
When you contact us (e.g. customer support, need help, submit a request) |
||||||
|
|
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. respond to a query sent by you) |
3rd party platforms such as for the following purposes:
|
Your Personal Data will be stored until we no longer need the information and proactively delete it (our data retention for this kind of Personal Data is generally 3 years) or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. |
Cannot assist you and respond your query Cannot provide support |
|
|
When you shop our products through our Store |
||||||
|
|
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to communicate with you) |
3rd party platforms such as for the following purposes:
|
Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. |
Cannot provide you our products or fulfill our contract Cannot process your payment information Cannot arrange for shipping Cannot provide you with invoices and/or order confirmations Cannot communicate with you Cannot screen our orders for potential risk or fraud Cannot provide you with information or advertising relating to our products or services |
|
|
When you attend a marketing event and/or we exchange business cards and you provide us with your personal data |
||||||
|
|
Consent Legitimate interest (e.g. to send you more information about Flycatcher) |
3rd party platforms such as for the following purposes:
|
Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. |
Cannot establish a business connection Cannot send you marketing communications |
|
|
When we use the personal data of our resellers, distributors, agents, partners and/or finders (e.g. contact details) |
||||||
|
|
Processing is necessary for the performance of a contract to which our customer is a party. Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g. send you contract-related communications). |
3rd party platforms such as for the following purposes:
|
Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. |
Cannot discuss business terms and to perform the applicable agreement Cannot communicate with our resellers and distributors |
|
|
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn) |
||||||
|
|
Legitimate interest (e.g. send you more information about Flycatcher) |
3rd party platforms such as for the following purposes:
|
We don’t store any Personal Data |
Cannot reply or respond to your request |
|
Finally, please note that some of the abovementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
- HOW WE PROTECT AND RETAIN YOUR INFORMATION
- Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy.
- HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your personal data as follows:
- With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
- To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
- In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
- Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
If you want to receive the list of the current recipients of your personal data, please make your request by contacting us to support@flycatcher.toys.
- ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
- Storage: AWS with servers located in the US. Your Personal Data collected from the Store will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.
- Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
- Access from the US: Due to the Court of Justice Decision 2016/1250, Flycatcher is in the process of analyzing its strategy and making the relevant updates to this Privacy Policy and Flycatcher’s practices.
- Access from the UK: Access from the UK does not require additional transfer mechanism.
- Internal transfers: Transfers within the Flycatcher group will be covered by an internal processing agreement entered into by members of the Flycatcher group (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
- You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
- You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
- You have the right to object, to or to request restriction, of the processing;
- You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
- You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
- You can exercise your rights by contacting us at support@flycatcher.toys. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
IMPRORTANT – Our services do not intend to collect Personal Data for children. If you believe your child is participating in an activity that collects Personal Data and you or another parent have NOT received an email providing notice or seeking your consent, or any other communication from us, please feel free to contact us at: support@flycatcher.toys. At any time, you can request the deletion of any Personal Data of children in association with a particular profile (to the extent such Personal Data was provided), and we will delete from our records the Personal Data we have collected in connection with that profile from all valid claims. Please keep in mind that a request to delete records may also lead to a termination of a profile, account, membership, or other service.
We also note that we will not use parent emails provided for parental consent purposes to send market materials to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
- INTERACTION WITH THIRD PARTY PRODUCTS
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
- LOG FILES
We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
- ANALYTIC TOOLS
- Google Analytics. The Website and the Store use a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website and/or Store. We use the information we get from Google Analytics to maintain and improve the Website/Storeand our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
- Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
We reserve the right to remove or add new analytic tools.
10.1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@flycatcher.toys. Please note that we are only required to respond to one request per customer each year.
- Our California Do Not Track Notice (Shine the Light): Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
10.3. Deletion Of Content From California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to support@flycatcher.toys. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at support@flycatcher.toys.