Effective Date: May 17, 2018
Figoura Ltd cares deeply about the privacy of its visitors and users and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors, users (our new and returning students as well as past students) regarding such information.
We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.
Course registered students are also advised to read the joining instructions which contains specific information about the use of videography and photography and how that is used where required for promotional material on our website.
1. Please read carefully!
2. What information do we collect?
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users and Students:
1. Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
2. Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal account), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
Figoura Ltd is a data controller within the meaning of the act and we process personal data.
3. How do we collect such information?
There are two main methods we use:
1. We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website, Information is also collected through the use of “cookies” and other tracking technologies, as further detailed in Section 6 below.
2. We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services (dance classes); when you place purchases; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g., our contact form, emails).
3. We also collect information from third party sources as described in Section 5 below.
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
1. To provide and operate the Services;
2. To further develop, customize and improve our Services.
3. To provide our Users with ongoing customer assistance;
4. To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section 7 below);
5. To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
6. To enhance our data security and fraud prevention capabilities;
7. To consider Applicants’ candidacy for working at the Figoura Ltd; and
8. To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
1. our use of your Personal Information is necessary to attain your details as part of your enrolment, and create a register of participants in the classes,
2. to provide you with our customer assistance, or
3. our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
4. our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
Whilst our dance classes and Services are permitted to children under 18 years of age, no one under age 18 should provide any Personal Information directly to us through any of our Services unless supervised and agreed by their parent or guardian. We do not knowingly collect Personal Information from children under 18. Parents and guardians should supervise their children's activities at all times.
5. Where do we store your information?
Figoura Ltd Visitors’ and Figoura Ltd Users’ Personal Information may be maintained, processed and stored by Figoura Ltd as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
Figoura Ltd users and applicants Information will be maintained, processed and stored
as necessary in secured cloud storage provided by our Third Party Services or locally on secured machines where Figoura Ltd operates from. Figoura Ltd. is based in the United Kingdom.
All our third parties used for storage are governed by such third parties’ policies and not ours.
6. Sharing personal information with third parties
Figoura Ltd does not share personal information with third parties unless consented to do so by an individual.
There are however circumstances however where Figoura Ltd may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
6.1. Law Enforcement, Legal Requests and Duties:
Where permitted by local data protection laws, Figoura Ltd may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
6.2. Protecting Rights and Safety:
Figoura Ltd may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Figoura Ltd, any of our Users, or any member of the general public, with or without notice to you.
6.3. Social Media Features and Framed Pages:
Our Services include certain Social Media features such as the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
Figoura Ltd, uses third party applications that use certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users with a better experience.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, our website provider uses several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by FigouraLtd, and we therefore cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
8. Communications from Figoura Ltd
8.1. Promotional Messages:
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from Figoura Ltd through such means.Figoura Ltd also operates the Greek Folk Dance Festival which also falls under this category.
If you do not wish to receive such promotional messages or calls, you may notify Figoura Ltd by emailing firstname.lastname@example.org any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information and interest in our business.
8.2. Service and Billing Messages:
Figoura Ltd may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended; reply to your e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints; contact you regarding your registration for classes, or notify you of material changes in our Services.
For communication we also have a mailing list which we run by a secure third party which all users are added to and have the option to opt out or unregister at any time as well as update your information.
9. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information. That’s why Figoura Ltdis taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a Figoura LtdVisitor or User/Student, and you wish to receive a copy, and/or request us to make corrections to the Personal Information that you have stored with us, or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties you can mail your request to Figoura Ltd, 3A Cranley Gardens, London N13 4LT.
We will make all reasonable efforts to honour your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations. You may also correct, update or remove certain parts of such Personal Information by yourself, on the 3rdparty mailing list which we run with that feature.
10. Data Retention
We may retain your Personal Information for as long as required or until you request the data to be removed or may remove your details through direct access of the mailing list.
We may continue to retain such Personal Information even after you cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
Where your Personal Information is no longer required we will ensure it is securely deleted.
Figoura Ltd has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures.
Regardless of the measures and efforts taken by Figoura Ltd, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other User Content you upload, publish or otherwise share with Figoura Ltd or anyone else.
We therefore encourage you to set strong passwords for your User login account where this is used on our website, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others (for example, making a comment in the “Public” domain instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at dance@figoura,com
12. Public forums and user content
Our Services offer publicly accessible blogs and forums. Please be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at: email@example.com. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.
13. Updates and interpretation
14. Contacting us
You may also contact us by mail at: Figoura Ltd. 3A Cranley Gardens, London N13 4LT