1.1 We are committed to
safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we
are acting as a data controller with respect to the personal data of our
website visitors and service users; in other words, where we determine the
purposes and means of the processing of that personal data.
Insofar as those cookies are not strictly necessary for the provision of
when you first visit our website.
1.4 In this policy,
"we", "us" and "our" refer to Fighters
Generation LLC. For more information about us, see Section 13.
2.1 This document was created
using a template from Docular (https://docular.net).
3. How we use your personal data
3.1 In this Section 3 we have set
(a) the general categories of
personal data that we may process;
(b) in the case of personal data
that we did not obtain directly from you, the source and specific
categories of that data;
(c) the purposes for which we may
process personal data; and
(d) the legal bases of the
3.2 We may process data about your
use of our website and services ("usage data"). The usage data
may include your IP address, geographical location, browser type and
version, operating system, referral source, length of visit, page views
and website navigation paths, as well as information about the timing,
frequency and pattern of your service use. The source of the usage data is
our analytics tracking system. This usage data may be processed for the
purposes of analysing the use of the website and services. The legal basis
for this processing is consent or our legitimate interests, namely
monitoring and improving our website and services.
3.3 We currently do not collect account data / information for user accounts on this website.
3.4 We currently do not collect profile data / information for user profiles on this website.
3.5 We may process your personal
data that is provided in the course of the use of our services
("service data"). The service data may include the timing,
frequency and pattern of service use. The source of the service data is
you. The service data may be processed for the purposes of operating our
website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with
you. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business.
3.6 We may process information
that you post for publication on our website or through our services
("publication data"). The publication data may be processed for
the purposes of enabling such publication and administering our website
and services. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.
3.7 We may process information
that you provide to us for the purpose of subscribing to our email
notifications and/or newsletters ("notification data"). The
notification data may be processed for the purposes of sending you the
relevant notifications and/or newsletters. The legal basis for this
processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract.
3.8 We may process information
contained in or relating to any communication that you send to us
("correspondence data"). The correspondence data may include the
communication content and metadata associated with the communication. Our
website will generate the metadata associated with communications made
using the website contact forms. The correspondence data may be processed
for the purposes of communicating with you and record-keeping. The legal
basis for this processing is our legitimate interests, namely the proper
administration of our website and business and communications with users.
3.9 In addition to the specific
purposes for which we may process your personal data set out in this
Section 3, we may also process any of your personal data where such
processing is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital
interests of another natural person.
3.10 Please do not supply any
other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to
4.1 We may disclose your personal
data to any member of our group of companies (this means our subsidiaries,
our ultimate holding company and all its subsidiaries) insofar as
reasonably necessary for the purposes, and on the legal bases, set out in
4.2 We may disclose your personal
data to our insurers and/or professional advisers insofar as reasonably
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, obtaining professional advice, or the establishment,
exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.
4.3 We may disclose email
addresses to our suppliers or subcontractors insofar as reasonably
necessary for sending you our email newsletter, if you have requested it
(you can inform us at any time if you no longer require the newsletter).
4.4 In addition to the specific
disclosures of personal data set out in this Section 4, we may disclose
your personal data where such disclosure is necessary for compliance with
a legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another natural person. We may
also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
5. International transfers of your
5.1 In this Section 5, we provide
information about the circumstances in which your personal data may be
transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our
website are situated in US, Europe and UK. The European Commission has
made an "adequacy decision" with respect to the data protection
laws of each of these countries. Transfers to each of these countries will
be protected by appropriate safeguards, namely EU-U.S. Privacy Shield
5.3 Mailing databases are situated
in US and Australia. The European Commission has made an "adequacy
decision" with respect to the data protection laws of each of these
countries. Transfers to each of these countries will be protected by
appropriate safeguards, namely EU-U.S. Privacy Shield and Swiss-U.S.
5.4 You acknowledge that personal
data that you submit for publication through our website or services may
be available, via the internet, around the world. We cannot prevent the
use (or misuse) of such personal data by others.
6. Retaining and deleting personal
6.1 This Section 6 sets out our
data retention policies and procedure, which are designed to help ensure
that we comply with our legal obligations in relation to the retention and
deletion of personal data.
6.2 Personal data that we process
for any purpose or purposes shall not be kept for longer than is necessary
for that purpose or those purposes.
6.3 We will retain and delete your
personal data as follows:
(a) Profile data containing
personal data will be retained for
FightersGeneration.com. This website works with third-party advertising companies to serve ads when you visit the site. These companies may use aggregated information (not including your name,
address, email address or telephone number) about your visits to this and other sites in order to provide advertisements about goods and services of
interest to you.
(b) Cookie data will be retained
for no longer than 30 days.
6.4 Notwithstanding the other
provisions of this Section 6, we may retain your personal data where such
retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital
interests of another natural person.
7.1 We may update this policy from
time to time by publishing a new version on our website.
7.2 You should check this page
occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes
to this policy by email or through the private messaging system on our
8. Your rights
8.1 In this Section 8, we have
summarised the rights that you have under data protection law. Some of the
rights are complex, and not all of the details have been included in our
summaries. Accordingly, you should read the relevant laws and guidance
from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under
data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict
(e) the right to object to
(f) the right to data portability;
(g) the right to complain to a
supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to
confirmation as to whether or not we process your personal data and, where
we do, access to the personal data, together with certain additional
information. That additional information includes details of the purposes
of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal
data. The first copy will be provided free of charge, but additional
copies may be subject to a reasonable fee. Provision of such information
will be subject to:
(a) the first copy will be
provided free of charge, but additional copies will be subjected to a GBP
10 administration fee; and
(b) the supply of appropriate
evidence of your identity (for this purpose, we will usually accept a
photocopy of your passport certified by a solicitor or bank plus an
original copy of a utility bill showing your current address).
8.4 You have the right to have any
inaccurate personal data about you rectified and, taking into account the
purposes of the processing, to have any incomplete personal data about you
8.5 In some circumstances you have
the right to the erasure of your personal data without undue delay. Those
circumstances include: the personal data are no longer necessary in
relation to the purposes for which they were collected or otherwise
processed; you withdraw consent to consent-based processing; you object to
the processing under certain rules of applicable data protection law; the
processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information; for
compliance with a legal obligation; or for the establishment, exercise or
defence of legal claims.
8.6 In some circumstances you have
the right to restrict the processing of your personal data. Those
circumstances are: you contest the accuracy of the personal data;
processing is unlawful but you oppose erasure; we no longer need the
personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defence of legal claims; and you
have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to
store your personal data. However, we will only otherwise process it: with
your consent; for the establishment, exercise or defence of legal claims;
for the protection of the rights of another natural or legal person; or
for reasons of important public interest.
8.7 You have the right to object
to our processing of your personal data on grounds relating to your
particular situation, but only to the extent that the legal basis for the
processing is that the processing is necessary for: the performance of a
task carried out in the public interest or in the exercise of any official
authority vested in us; or the purposes of the legitimate interests
pursued by us or by a third party. If you make such an objection, we will
cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your
interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.
8.8 You have the right to object
to our processing of your personal data for direct marketing purposes
(including profiling for direct marketing purposes). If you make such an
objection, we will cease to process your personal data for this purpose.
8.9 If you consider that our
processing of your personal information infringes data protection laws,
you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of
your habitual residence, your place of work or the place of the alleged
8.10 To the extent that the legal
basis for our processing of your personal information is consent, you have
the right to withdraw that consent at any time. Withdrawal will not affect
the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your
rights in relation to your personal data by contacting us using the
details outlined in section 13.
9. About cookies
9.1 A cookie is a file containing
an identifier (a string of letters and numbers) that is sent by a web
server to a web browser and is stored by the browser. The identifier is
then sent back to the server each time the browser requests a page from
9.2 Cookies may be either
"persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid
until its set expiry date, unless deleted by the user before the expiry
date; a session cookie, on the other hand, will expire at the end of the
user session, when the web browser is closed.
9.3 Cookies do not typically
contain any information that personally identifies a user, but personal
information that we store about you may be linked to the information
stored in and obtained from cookies.
10. Cookies that we use
(a) authentication - we use
cookies to identify you when you visit our website and as you navigate our
help us to determine if you are logged into our website;
an element of the security measures used to protect user accounts,
including preventing fraudulent use of login credentials, and to protect
our website and services generally;
to help us to display advertisements that will be relevant to you (cookies
used for this purpose are: Google AdSense, Google AdExchange, Avocet,
PulsePoint, Teads, Skimlinks, Monetizer 101);
help us to analyse the use and performance of our website and services
(cookies used for this purpose are: Google Analytics, ComScore, Google Tag
Manager, Crazy Egg, Facebook Audience, Google Analytics Audience);
(f) cookie consent - we use
11. Cookies used by our service
11.1 Our service providers use
cookies and those cookies may be stored on your computer when you visit
11.2 We use Google Analytics and
Comscore to analyse the use of our website. Google Analytics and Comscore
gather information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use
11.3 We publish Google AdSense
interest-based advertisements on our website. These are tailored by Google
to reflect your interests. To determine your interests, Google will track
your behaviour on our website and on other websites across the web using
cookies. You can view, delete or add interest categories associated with
your browser by visiting: https://adssettings.google.com.
You can also opt out of the AdSense partner network cookie using those
settings or using the Network Advertising Initiative's multi-cookie
opt-out mechanism at: http://optout.networkadvertising.org.
the cookies from your browser your opt-out will not be maintained. To
ensure that an opt-out is maintained in respect of a particular browser,
you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
12. Managing cookies
12.1 Most browsers allow you to
refuse to accept cookies and to delete cookies. The methods for doing so
vary from browser to browser, and from version to version. You can however
obtain up-to-date information about blocking and deleting cookies via
12.2 Blocking all cookies will
have a negative impact upon the usability of many websites.
12.3 If you block cookies, you
will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and
operated by Fighters Generation LLC.
13.2 We are registered in the
United States of America.
13.3 You can contact us by email,
using this email address: firstname.lastname@example.org.