1. How We Collect, Use and Disclose Information

What Information Do We Collect?

You may choose to provide us with your name, telephone number and email address when you use our services. We may collect certain Personal Information using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality. Providing your Personal Information to us is voluntary. However, if you do not provide your Personal Information to us, you will not be able to access some or all of our services.

How do We Use Your Information?

When you provide Personal Information to us, we will use it to contact you about billing questions related to the website you requested.

When and to Whom Will We Disclose Your Information?

Due to the nature of your request, we will reference your Personal Information in order to contact you and look up your account.

We also disclose Personal Information to our service providers (for example, credit card processing companies, billing services) as reasonably necessary or appropriate to provide services on FFNHelp. Our service providers are legally required by us to protect your Personal Information. Because many of FFNHelp operate or use service providers located in different countries, your Personal Information may be transferred to a country in which you do not reside, and while in that foreign country, may be accessible to its law enforcement authorities.

We may be required to disclose your Personal Information in order to comply with a court order, subpoena, search warrant, or a lawful request by public authorities, including to meet national security or law enforcement requirements. In addition, we expressly reserve the right to disclose your Personal Information when we have a good faith belief that disclosure is necessary to protect our rights, to enforce our agreements, policies, and rules governing your use of FFNHelp, and/or to report information concerning a threat of serious injury or death.

2. Our Use of Cookies and Your Options; Pixel Tags

FFNHELP uses "cookies" to store and sometimes track information to make your online experience easier and more personalized

Cookies are small pieces of data that are stored by a user's web browser on the user's storage drive. Cookies may record information that is accessed by a user on a webpage in order to simplify subsequent interactions with that website by the same user, or to streamline the user's transactions on related webpages. Cookies make it easier for a user to move from webpage to webpage and to complete transactions over the Internet.

Most major web browsers are set up so that they will initially accept cookies, but you may modify your computer's preferences to issue you an alert when a cookie is downloaded, or to disable the ability of third parties to download a cookie to you. If you choose to reject all cookies, there are areas of FFNHELP that may not function properly. You may obtain further information about cookies and how they function at: http://en.wikipedia.org/wiki/HTTP_cookie.

We may also use standard Internet technology, such as web beacons or 1x1 "gifs" and other similar technologies (collectively "Pixel Tags"). A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Members and may be associated with cookies on the Members' storage drives. We use Pixel Tags to track your use of FFNHelp, for advertising, marketing, or promotional purposes, and to determine whether you opened an email message from us. The information also enables us to customize the services we offer.

3. How We Protect Your Information

FFNHelp uses reasonable security measures to help protect and prevent the loss, misuse, and alteration of the information under our control. We use industry standard efforts, such as firewalls, to safeguard your Personal Information. While "perfect security" does not exist on the Internet, or elsewhere, our technical staff works hard to help ensure your secure use of our services.

4. Where we are Located

FFNHelp is located in the United States. If you are visiting FFNHelp from outside the United States, you must be aware that your Personal Information may be transferred to, stored, and processed in the United States or other countries in which FFNHelp or its service providers are located. The data protection and other laws of the United States and these other countries might not be as comprehensive as those in your country, and your Personal Information may be accessible to law enforcement authorities in the United States or of other countries.

When you use FFNHelp, you consent to us transferring your Personal Information (which includes, for the avoidance of doubt, your Sensitive Personal Information) from your country to the United States or countries in which FFNhelp or its service providers are located for the purposes described in this Policy.

5. Removing Your Personal Information and Registering Privacy-Related Complaints

You have the right to ask in writing whether we hold any Personal Information about you, and to see that information as well as how we collect, use or disclose your Personal Information. We note that we may not be able to provide you with all of the information you request, depending on the circumstances. There may be a charge for any copy of Personal Information requested.

We may retain in our files certain data (including credit card information) if necessary to:

• resolve disputes
• troubleshoot problems
• comply with credit card merchant banking and association agreements, rules or regulations
• enhance security, reduce fraud, or comply with the law, or
• enforce any agreements, policies, and rules governing your use of FFNHELP

For all other requests to access, update, modify or delete your Personal Information, please:

• Email us at: privacy@friendfindernetworks.com, or
• mail us at: FriendFinder Networks Inc. at 910 E. Hamilton Ave, Sixth Floor, Campbell, CA 95008, USA, Attn: Privacy, or
• telephone us at: (408) 702-1040.

You are entitled to contact us using the above contact information to register a privacy-related complaint. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right. We will also let you know what other complaint procedures may be available to you.

6. Revisions to this Privacy Policy

We reserve our right, in our sole and absolute discretion, to revise, amend, modify or revoke this Privacy Policy at any time, and in any manner to the fullest extent permitted by law. If the changes are significant, we will provide a more prominent notice. Changes to this Privacy Policy will be effective by posting revisions on FFNhelp.

Specific Disclosures for the European Economic Area

(This section is effective on May 25, 2018)

This section applies to data processing activities of data subjects residing in the European Economic Area as well as, regardless of residence, to the processing of any Personal Data in the European Economic Area. To the extent there is any conflict between the Specific Disclosures for the European Economic Area and any other part of the Privacy Policy or Terms of Use, this section shall control.

For purposes of this section, the following definitions apply:

• “Personal Data,” means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• “Sensitive Personal Data” or “Special Categories of Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

1. Legal Basis for Processing

We collect and process your Personal Data to assist in resolving billing issues on our affiliated entities’ websites (the “Services”). FFNHelp does not request or require that you provide us with any Sensitive Personal Data. Kindly do not share Sensitive Personal Data unless we specifically request it.

In some cases, we will ask for your consent so that we may process your Personal Data. However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent.

1.1. CONSENT FOR PROCESSING SENSITIVE PERSONAL DATA

Should it ever be necessary, we will obtain your explicit consent to process your Sensitive Personal Data. If so, in certain limited circumstances, we may process or otherwise disclose your Sensitive Personal Data without your consent to protect the vital interests of you or of another person where the data subject is physically or legally incapable of giving consent, or where it is necessary to establish, exercise, or defend legal claims, including to comply with law enforcement or other legal or judicial orders or requests for such purposes.

1.2. CONSENT FOR PROCESSING NON-SENSITIVE PERSONAL DATA

In cases where we are not already authorized to process the Personal Data under applicable law, we may ask for your consent to process your non-Sensitive Personal Data, including:

• Use of Cookies
  Our Site uses cookies and similar technologies to improve user experience and for analytics. In those jurisdictions that require it, we allow the data subject to give explicit permission or to deny the use of certain categories of cookies.
  
  If you want to block the use and saving of cookies from this website on to their computers hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the website. For information on how to disable cookies, refer to your browser’s documentation.

1.3. PROCESSING PERSONAL DATA WHERE CONSENT NOT REQUIRED

In certain cases where we are not processing Sensitive Personal Data, separate consent may not be required, including:

• For the performance of a contract.
  To perform our contractual obligations to you, including fulfilling orders or purchases you have made, contacting you in relation to any issues with your order or use of our Services, in relation to the provision of our Services, or where we need to provide your Personal Data to our service providers related to the provision of the Services.


• To comply with legal obligations.
  To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.


• To protect data subjects’ vital interests.
  To protect the vital interests of you or of another person.


• Legitimate Interests.
  To operate our business and provide our Services (other than in performing our contractual obligations to you) for our “legitimate interests” and for the purposes of applicable law, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Legitimate interests may include:
  • To communicate with you regarding the Services
  • To assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties.
  • To develop, provide, and improve our Services.
  • To enforce our Terms of Use or this Privacy Policy, or agreements with third parties.

2. WITHDRAWING YOUR CONSENT

You may at any time withdraw the consent you provide for the processing of your Personal Data or Sensitive Personal Data (if any) for the purposes set forth in this Privacy Policy by contacting us here, provided that we are not required by applicable law or professional standards to retain such information.

3. DATA SUBJECT RIGHTS

You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, you also have the right to request access to, modification of, or deletion of such Personal Data.

You also have the right in certain circumstances to receive the Personal Data concerning you that you provided to us, to restrict processing of your Personal Data, or to transmit such data to another controller.

To exercise your rights with respect to your Personal Data, please contact us at here.

As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service. We will respond to reasonable requests as soon as practicable and as required by law.

4. DE-IDENTIFIED OR ANONYMIZED DATA

We may create de-identified or anonymous data from Personal Data by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized data is not subject to this Privacy Notice.

5. DATA RETENTION

We will retain your Personal Data for as long as long as you maintain an account or subscription agreement or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You may have a right to lodge a complaint with a supervisory authority.

7. CONTACT US

For questions regarding this Privacy Policy, please contact us at: here.

FFNHELP PRIVACY POLICY Effective on: April 4, 2019