PRIVACY POLICY

As part of our mission to create an easy manageable environment for an inspiring content development and to help brands to increase their online presence and get their story heard in the digital noise, we connect brands with social media influencers. Our aim is successful and authentic brand storytelling, which builds a strong connection between brands and consumers with the help of influencers in between. It is important to us that you feel comfortable and trust us with your information when you use the FAMENOTE website (the “Service”). Please take a few minutes to read this Privacy Policy, so that you understand what information we collect, how we use it and the reason why we do that. Before creating your account, please read the following terms in order to be informed for our privacy policy and to take your informed decision to share your information with us.

Identification of Parties:

FAMENOTE is a website owned by Octo Group Ltd., Leninova 14, 2400 Strumica, Republic of Macedonia, 0038970733425. As the service we provide is to connect influencers and brands, we are a controller of personal data according to the General Data Privacy Regulation 2016/679 of the European Parliament and of the Council. You at the other side as an Influencer, based in EEA or in the Republic of Macedonia, are a data subject and that means that you have certain rights as to be informed who, how and why collects, uses and stores your personal data and how you can control, make changes or delate it. For additional information about the data protection policy, you can contact our data protection officer and/ or our representative in a Member State at the European Union, using the contact information, given down below. After a connection (application for a campaign, setting a deal) between you as an Influencer and a Brand is made, the Brand becomes a controller of some of the information processed by us as both of you exchange some data in order to fulfill your contract. The only data the Brand as a registered member of FAMENOTE can see is the one that you have already shared in your linked account (Facebook, Instagram) and which is integrated in your FAMENOTE account, or which you have shared publicly in the FAMENOTE website or privately with him in a chat conversation via our platform.

Scope and consent:

Before you register in FAMENOTE – Octo Group Ltd., it is important you to understand that by using our Service, you allow us to collect, use, disclose, and retain your personal information and other information, given by you and/ or collected automatically by us from Third Parties. You can be sure that we will only use your information as described in this Policy.

By using the Service, you are also agreeing to our Terms of Use. Please make sure you read and agree with our Terms of Use if you want to use FAMENOTE.

Legal Basis for Data Processing:

The legal basis for data processing by us as a data controller is to fulfill our contractual obligations to you, for example to connect you with brands, to help you make a contract with them, to ensure that invoices are paid correctly. We use your personal information in order to fulfill our obligation to meet the criteria of both brands and influencers and at some point, we may use it for profile the data subject (for example based on the number of your followers, activity of your followers, etc.). In other cases (cookies and tracking policy, advertising, contacting with you) you have given your consent to the processing. Therefore, we process your personal data to comply with our legal obligations, as explained above. We process some information in order to meet our legitimate interests, for example to understand how you use our products services and to enable us to derive knowledge from that, which allows us to develop new products and services, and to personalize the service for you and the ads you see. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that your interests or fundamental rights and freedoms do not override our legitimate interests. In other cases the information is used to protect the vital interests of you as a data subject or of another natural person, or when necessary - for the performance of a task carried out in the public interest.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to Cookies and Tracking Technologies or when we process accurate location data for purposes other than performing the service). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy policy. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Octo Group Ltd. is the controller of data we collect and process according to this privacy policy. We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your data protection authority or to the court according to the applicable legislation.

Information we collect:

We collect information you provide directly to us when you use our Services. Depending on which Service you use, we may collect different information about you. We also gain information from Third Parties( Facebook, Instagram, Google) about you based on your consent and the purpose of our service as processing is necessary for the performance of the contract to which you are party or in order to take steps at your request prior to entering into a contract with us and/ or a Brand.This may include personal data as follows:

(1) Registration and Account Information:
We collect the content and other information you provide when you use our Services. This includes information used to create your account (e.g., a username, an email address, phone number), account preferences, and the content of information you post to the Services (e.g., text, photos, videos, links). When you use our Service you voluntarily give us personal information (e.g., name, email, birth date, age, phone number and, when necessary, billing information) and you are not anonymous to us. That means your name and photo (if you choose to provide them) will be visible to the other registered users (brands and other influencers).

(2) Social Media Information:
You sign in to your FAMENOTE account through third-party social media sites like Facebook and Instagram. By doing so you agree to give us on-going access to your personal information on such sites (e.g., your public profile, friend list, accounts you follow or who follows you, your email address, birthday, work history, education history, interests, current city, video and other shared via them by you, number of likes, what you like and who likes your posts). We do not have access to your private chats and conversations. We may receive certain information about you which is stored on social media sites if users of those sites give us access to their profiles and you are one of their friends or connections, depending upon your settings on those sites. For more information, please refer the Privacy Policy of Facebook and Instagram.

(3) Payment and Transactional Information:
As the aim of our service is to connect Influencers/ Content Creators and Brands for the purposes of the marketing and advertising, payments are supposed to be done because of the contracting between the mentioned parties. Payments are processed by third-party payment processors ( CaSys International, operated by Uni Banka AD Skopje ), so please refer to the applicable processor’s terms and privacy policy for more information about how payment information is processed and stored. The necessary information for the Privacy Policy of Uni Banka AD Skopje the following links - http://casys.com.mk/uploads/AboutUs/docs/Privacy_Policy.pdf, http://www.unibank.com.mk/categories/view/675.

(4)Other Information:
You may choose to provide other information directly to us. For example, we may collect information when you fill out a form, participate in contests, sweepstakes or promotions, apply for a job, communicate with us via third-party sites and services, request customer support or otherwise communicate with us.

(5)Information We Collect Automatically:
When you access or use our Services, we may also automatically collect information about you as follows:
(a)Log and Usage Data:
We may log information when you access and use the Service. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, user interactions (e.g., voting data), the requested URL, hardware settings, and search terms, your wireless network, and your mobile carrier. We may also collect your WPS location data – you can choose whether to allow this by changing your geolocation tracking settings.
(b)Information Collected from other online services:
We may receive information from other online services, which are pieces of data your browser stores and sends back to us when making requests. We use this information to improve your experience, understand user activity, and improve the quality of our Service.
(c)Location Information:
With your consent, we may collect information about the specific location of your mobile device (for example, by using GPS or Bluetooth). You can revoke this consent at any time by changing the preferences on your device, but doing so may affect your ability to use all of the features and functionality of our Services.
(d)Social Sharing:
We offer social sharing features or other integrated tools that let you share content or actions you take on our Services with other media. Your use of these features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features (e.g. Facebook and Instagram).
(e) Activity Information:
While using the chat integrated on our site, we will collect, and other users can see, whether you have received and seen messages sent to you, and information related to the messages you have sent and received, who messaged who, and at what time. We will receive interaction information from your use of our Services. When you deal with a Brand through our platform, we will collect and store the information about the conditions of your contract such as shared content by you as a creator, price and payment information.

Usage:

Our mission is to constantly improve our Services and provide you with new experiences. As part of this mission, we use your information for the following purposes of the processing for which the personal data are intended on the following legal basis for the processing:

(a) Provide and maintain the Services:
We use your Registration and Account information to register you for FAMENOTE, to create your User Account for our site; create your profile and make it visible. We use your information to process payments; personalize your experience by providing content (such as adverts) on the Service. Personalization may include automated decisions about what you will view and when, but it will not have legal effects on you.
(b) Improve the Services:
We use usage information (as described above) to better understand network behavior and trends, to your preferences and brand’s preferences in order to meet the expectations of both of you. This data processing allows us to send you preferable invitations for applications, to suggest your FAMENOTE profile to a certain Brand and/ or to make a list of applications based on certain criteria.
(c) Prevent Fraud & Spam; enforcement of law:
Processing the information mentioned above helps us to protect the safety of FAMENOTE – Octo Group Ltd. and our users, which includes blocking suspected spammers, addressing abuse, and enforcing the FAMENOTE – Octo Group Ltd. user agreement and the Terms of Service. We want FAMENOTE to be free of spam and fraudulent content so that you feel safe. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use. This may include URLs included in messages, which were reported as SPAM by other users, or were otherwise suspected to be unsolicited and using your operating system authentication services. We may use automated decisions to close an account based on such data and other logic we have created for this, in order to protect other users and prevent recurring breaches. If your account on Facebook or Instagram have been blocked, deleted or considered as inappropriate or if it doesn’t meet the conditions for being considered as an Influencer( less than 5 000 followers; fake profile, etc.), that will reflect your FAMENOTE account and you may not be registered or if you already have a registration it may be deleted. If your account has been blocked you can contact our support. We may use your information to comply with applicable laws.
(d) Send you technical notices, updates, security alerts, invoices and other support and administrative messages;
(e) Provide customer service;
(f) Communicate with you:
As part of the FAMENOTE family, we want to keep in touch with you. We use your information to contact you (via message, e-mail or other means) to maintain the FAMENOTE site, to send you adverts, offers or other e-mails about products, services, offers, promotions, and events, and provide other news and information we think will be of interest to you (for information about how to opt out of these communications, see contacts below). We also use your contact information and to discuss probable contracts, advertisings and other issues which may occur between you and us or between you and other users of FAMENOTE website.
(g) Monitor and analyze trends, usage, and activities in connection with our Services;
(h)Personalize the Services and provide advertisements, content and features that match user profiles or interests. As part of value added services provided by us or by a third party within FAMENOTE, we may use your information for the purposes of the direct marketing, to send you personal updates about new offerings which we believe you will find relevant. We may share with our service providers unique identifiers to determine the best way to tell potential new users about our services.
(i) Process Your Payments: We may use your Information like your name and bank account to process your payments and the payments made by the brand with which you have made a contract via FAMENOTE; the payments for our Services through a secured third-party service provider and, on an aggregate basis to determine charges for our service.

Data Retention:

Unless otherwise specified, we retain information as long as it is necessary and relevant for us to achieve the purposes referred to above or to enable us to comply with our legal data protection retention obligations. For personal data related to concluded contracts and processed payments, we may retain your data until complying the legal obligation (such as tax law, contract laws, intellectual property laws and others). When you delete your account, your profile is no longer visible to other users and disassociated from content you posted under that account. Please note, however, that the posts, comments, and messages you submitted prior to deleting your account will still be visible to others, unless you delete such content. We may also retain certain information about you as required by law or for legitimate business purposes after you delete your account. That means, after deactivation of your account, we will minimize the personal data we keep about you only to such data which we are required to keep to comply with laws, or other legal reasons. We may keep activity data on a non-identifiable basis to improve our services. Your posts on public accounts and communities may remain available if you do not delete them. You may delete your account information at any time by logging into your account and following the steps.

Disclosure:

Your data is kept safe with us, but we do share your personal information with third parties( recipients) we trust in order to provide you with our services, as follows:
(a) The Octo Group Ltd.:
We may share the information we collect about you with the FAMENOTE corporate family, including our company – Octo Group Ltd.. The information may be disclosed to: (i) provide joint content and our services (e.g., registration, coordination of membership accounts between the FAMENOTE corporate family, transactions, analytics and customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches. The information provided in your registration, if you link your Facebook or Instagram account to the FAMENOTE account, will be shared with Octo Group Ltd. to create the FAMENOTE account and/or to forbid its creation if you don’t fit in our conditions. For example if the number of your followers is less than 5 000, if there is any chance of you to be a bod or if a check you have appeared to be someone’s’ fake profile. Data about your use of the FAMENOTE account will also be shared to the joint account in case of deal between you and the brand you’ve negotiated with in order to complete the contract. The purpose of this practice is to provide joint content and a better service, and to allow you to enjoy the experience of using our website, as well as for fraud prevention and any other purpose described in the Privacy Policy and our Terms of Use. You can choose to delink your FAMENOTE account from the Instagram of Facebook account at any time by editing your profile on the app.
(b) Brands.
We share your information with them in order to fulfill our contract with you and with them as a connection between brands and influencers. We disclose basically the information that you have already provided and which is needed in order of profiling the best content creator for each campaign.
(c) Hosting Company( MK Host), App Providers and Other Third-Parties:
We may disclose your information to service providers and other third-parties under contract who help with providing you and others our Services on our behalf or other services provided by third-parties via our Services. Recipients are such as, but not limited to, fraud and spam investigations, payment processing, site analytics and operations, either providing special partnership features in our service, or using a unique identifier, which is not attributable to you. They are required to secure the data they receive.
(d) Advertising partners:
Our ad partners and network may use cookies and use related technologies to collect information when ads are delivered to you on our Services, but FAMENOTE – Octo Group Ltd. does not link to or provide your actual FAMENOTE – Octo Group Ltd. account details to these advertising partners. We may share a unique advertising identifier that is not attributable to you, with our third party advertising partners, and advertising service providers, along with certain technical data about you (your language preference, country, city, and device data), based on our legitimate interest. This includes partners managing our advertising placements and also advertisers themselves and their agencies or third parties managing their advertising demands. Your unique advertising identifier is created by your mobile device’s operating system and you can change it or choose not to share it at any time. If you want to know more, read our Cookies and Tracking Technologies Policy. We may partner with thirdparty advertisers, ad networks, and analytics providers to deliver advertising and content targeted to your interests and to better understand your use of the Services. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device.
(e) Analytics Partners:
We use analytics partners (such as Google Analytics) to help analyze usage and traffic for our Services. As an example, we may use analytics partners to analyze and measure, in the aggregate, the number of unique visitors to our Services. For more information about how you may control the collection and/or use of information for advertising and analytics purposes, please see “ Your Choices” or “Contacts”.
(f) Legal and Law Enforcement:
We may disclose your information to law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to enforcement of a contract or any illegal acts such as criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other FAMENOTE user to legal liability.
(g) New Owners:
We may share your information with another business entity, if we plan to merge with or be acquired by that business, or are involved in a transaction with similar financial effect. In such a situation we would make reasonable efforts to request that the new combined entity or other structure follow this Policy with respect to your personal information. If your personal information was intended to be used differently, we would ask the new entity to provide you with prior notice. If such a change is going to happen we will inform you in a suitable way.

Information You Share Publicly:

Some of our Services allow you to share information with others on a public basis. The information shared by you on your Facebook or Instagram profiles, is automatically integrated in your FAMENOTE account, and it is not protected by us. Facebook/ Instagram is considered as a third party, so please refer to those platforms Privacy Policy. If you post information on a public feature of our Services or through social media sites, plug-ins or other applications, do not forget this information is public on our Services and, depending upon your privacy settings, may also become public on the Internet. We cannot prevent or control further use of this information so please make sure you only post information that you are happy to be seen publicly. We may also further use such public information, for various reasons, such as improving our service and providing you with relevant content, and analyzing trends.

If you wish to remove a certain piece of content you have shared in the past, you can do that by deleting that content. It will be removed from our services but may remain on local devices of some users (assuming they have chosen to save it).

Your Choices:

We want you to have control over how to protect and limit the collection, use, and disclosure of, information about you. You can do this in your FAMENOTE – Octo Group Ltd. account. You can choose not to share your photo, opt not to receive location-based messages along with many other additional options, which are available within the site. You can also make additional choices on your phone’s settings by changing permissions such as location sharing and more. As mentioned above FAMENOTE may send you e-mails about offerings by us, by Brands or thirdparties, that we think may be of interest to you. If you do not wish to receive such e-mails, you may adjust your system settings to decline them and unsubscribe. At any time you can withdraw your consent for processing your personal information when that is the legal basis for it ( cookies, tracking systems, advertising, e-mail marketing, etc.) by using the site preferences or by contacting us. Have in mind that withdrawing your consent will not affect the lawfulness of processing your data before the withdrawing.

Cookies and Tracking Technologies:

When you visit our Website, our business partners and we may use cookies and other tracking technologies for a variety of purposes. Most web browsers are set to accept cookies by default. Some analytics providers may provide specific opt-out mechanisms (e.g. Google Analytics Optout), and we will provide, as needed, additional tools and third-party services that allow you to better understand cookies and how you can opt-out. You have the ability to opt out of having your web browsing information used for behavioral advertising purposes. If you prefer, you can usually choose to set your browser to remove or reject first- and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Your rights relating to your personal data:

You have the following rights:
(a) to access your personal information
(b) right of portability (receive your personal information in a usable electronic format and transmit it to a third party)
(c) correct the information we hold about you if it is incorrect or incomplete
(e) erase your personal information
(f) restrict our use of your personal information
(g) the right to withdraw your consent for personal data processing when it is based on this legal ground
(h) object to our use of your personal information
(i) lodge a complaint with your local data protection authority.

Accessing, Reviewing, and Changing Your Personal Information

As a registered member, you can review and change personal information at any time by accessing your account on the FAMENOTE website or contacting us. Please be sure to update your personal information promptly if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent you from re-registering.

Security:

We know that security is important to our users and we care about the security of your information. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use include firewalls, data encryption, physical access controls to our data centers and information access authorization controls. We need your help too: it is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third parties. We will inform you for any personal data breach because of a hack attack, unauthorized access or any other reason if we could not prevent that unfair use to happen. In case of loss of your information, please contact us.

Children’s Privacy:

Our Services are not intended for children under the age of 18. Therefore, we do not knowingly collect personal information via our websites, applications, services, or tools from anyone under 18. Although we welcome users from all walks of life, FAMENOTE – Octo Group ltd is not intended or directed at individuals under the age of 18. Therefore, individuals under the age of 18 may create an account or otherwise access or use the Services but before the beginning of the registration the person will be asked to confirm that Is not under 18, or that has an agreement from a parent/guardian.

International Transfer:

We operate internationally and provide our Services to FAMENOTE users worldwide allowing brands and influencers to communicate with each other across the globe. That means that your personal information may need to be processed in countries where data protection and privacy regulations may not offer the same level of protection as in your home country. We store and process your personal information on our computers in the the Republic of Macedonia and the information we collect is governed by EU data regulations - EU2016/679-EUR-Lex. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the Republic of Macedonia and other countries, where you may not have the same rights as you do under your or our local law. FAMENOTE – Octo Group Ltd. complies with the Republic of Macedonia – EU data regulations EU2016/679-EUR-Lex, choice, onward transfer, security, data integrity, access, and enforcement. If you have concerns about our compliance with the personal data regulations, you should contact us.

B2B Partners Data:

When you communicate with us for business purposes as a b2b partner of ours, we will save your contact data provided by you (phone number, email, address etc.), as well as any correspondence we have had. We use trusted third party processors to keep such data, all in accordance with the provisions of this privacy policy. You have the ability to opt out of our direct marketing emails at any time and to contact us with any request regarding your data. If you gain any personal data from us as your B2B partner, concerning other users of our platform you are responsible for its protection and legally obligated to follow this privacy policy and the applicable EU legislation.

Updates to this Policy:

From time to time, as our services evolve, we may update this Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the App. Please check the App frequently for updates. We may change this Privacy Policy from time to time. If we do, we will let you know by revising the date at the top of the policy. If we make a change to this policy that, in our sole discretion, is material, we will provide you with additional notice. We encourage you to review the Privacy Policy whenever you access or use our Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. If you continue to use our Services after Privacy Policy changes go into effect, you consent to the revised policy.

Applicable Law:

As mentioned above, FAMENOTE – Octo Group Ltd. complies with the legislation of the Republic of Macedonia and the EU data regulations EU2016/679-EUR-Lex, on the question of choice, onward transfer, security, data integrity, access, and enforcement. For any disputes on this data privacy policy, you may contact us and we encourage you to do so in order to find an agreeable decision for your concerns.

Contact Information:

If you still have questions about our privacy policy, please feel free to send us an email to hello@famenote.com, contact@octogroup.co, or using the contact form on the FAMENOTE website. FAMENOTE is powered by Octo Group Ltd., registered in the Republic of Macedonia, with UIC 4027016525430. You can find us in our office Leninova 14, 2400 Strumica, Republic of Macedonia or call us on the following number: 0038970733425. For further information you can also contact our Data Privacy Officer: Rade Grozdanov, Leninova 14, 2400 Strumica, Republic of Macedonia, 0038970733425, contact@octogroup.co and our Representative (Data Controller Representative according to Art. 4, n. 17 GDPR( EU) 2016/679 in a Member State of the European Union: Petia Georieva Atanasova, gr. Blagoevgrad, ul. Todor Aleksandrov 26 B, Bulgaria, 00359899019599, petia_atanasova1@abv.bg.

In the event you read this Privacy Policy in any language other than English, you agree that in the event of any lack of correspondence or misunderstanding, the English version shall prevail.

This Privacy Policy is updated and enforced on 25th of May 2018.