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PRIVACY POLICY

Welcome to our website available at http://fabiosamedia.com/(“Website”). We value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we handle your information when you visit our Website. Please read this policy carefully.

1.WHO WE ARE

The Website is operated by our company - WILLE TECH LIMITED, an entity incorporated under the laws of Cyprus, with registration number HE373066 and registered office at Kinyra 1, KINYRAS TOWER, 3rd floor, 'Agios Andreas, 1102, Nicosia, Cyprus (also referred “Company”, “Fabiosa Media”, "we", "us", "our").

2.WHAT INFORMATION DO WE COLLECT?

We do not collect, store, or process any personal information from you and other users/visitors to our Website. Our Website is purely informational and does not include any features that require the collection of personal data. The only information stored is an access token for the website administrator, which is used to facilitate secure access to the administrative functions of the website. This token is stored locally on the administrator’s device. It does not pertain to or affect any visitors to the website, and no visitor information is collected or stored. Our Website does not use cookies, tracking pixels, or any other form of tracking technology. We do not perform any form of user tracking or data analytics. Our Website does not use any third-party services that collect data from visitors. We do not share any information with third parties.

3.WHAT ARE LEGAL BASES FOR PROCESSING OF DATA

Currently, we do not collect or process any personal data. However, should this change in future, please be aware of what the legal bases could be for such processing if needed in the future:
  • Legitimate Interests: We process your data to pursue our legitimate business interests, which include:
    • Improving our Website;
    • Communicating with you regarding use of the Website and/or Bidding Events and your participation in them;
    • Protecting our legal rights and interests;
    • Ensuring the security and functionality of our Website;
    • Preventing fraud and ensuring the integrity of our Bidding Events.
  • Cooperation Performance: We process your data to enhance our cooperation with you, such as:
    • Managing and fulfilling agreements formed off the Website between you and the Company;
    • Providing support related to your use of the Website.
  • Legal Compliance: We process your data to comply with legal obligations, such as:
    • Maintaining records for tax, audit, and regulatory purposes;
    • Complying with lawful requests and legal processes;
    • Ensuring compliance with data protection laws and regulations.
  • Consent: We process your data based on your consent in situations where:
    • You have provided explicit consent for specific processing activities, such as receiving marketing communications;
    • You have agreed to our use of local storage and similar technologies through the consent banner on our Website.

4.YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

Currently, we do not collect or process any personal data. However, should this change in future, you are entitled to data-related rights as described below.

Please note that the below listed rights are based on European laws, namely the General Data Protection Regulation (the “GDPR”). Depending on your country of residence, those rights may have different interpretations. Should you wish to assert your country-specific rights, kindly let us know, and we will review your case individually.
Right to AccessYou can request confirmation about whether we process your personal data and, if so, access a copy of your data and information about how it is processed.
Right to RectificationYou have the right to correct any inaccurate personal data and to have incomplete data completed.
Right to Erasure (Right to be Forgotten)You can request that we delete your personal data under certain conditions. You may request data erasure only if:
  • Your personal data is no longer necessary for the purposes for which it was initially collected,
  • You have withdrawn your consent to personal data processing, and the consent was the sole legal basis for the processing,
  • You have successfully objected to the processing based on a balancing of interests relating to your particular situation,
  • Your personal data has been unlawfully processed,
  • Your personal data has to be erased for compliance with a legal obligation, or
  • You are an underage person and used our Website by mistake.
Further, your right to erasure is subject to restrictions. If we have transferred personal data to third parties, we will either initiate the deletion of your data from such third parties or inform them about the erasure, insofar as required by applicable law. In order to avoid any unnecessary legalese and keeping in mind the general use of such words, we will interpret all user requests asking us to “delete my data” as requests for erasure of data under Article 17 of GDPR.
Right to Restriction of ProcessingYou have the right to request, under certain conditions, restriction of processing (i.e. the marking of stored personal data to restrict its future use). The requirements for restriction of processing are as follows:
  • The accuracy of your personal data is contested, and we must verify the accuracy of your data;
  • The processing is unlawful but you do not want your personal data to be erased, and instead you request restriction of use of your personal data;
  • We no longer need your personal data for the purposes of processing, but you need the data for the establishment, exercise, or defense of legal claims;
  • You have objected to data processing, and we are verifying whether our legitimate interests override yours.
Right to ObjectYou have the right to object to the processing of your personal data in whole or in part at any time, and in any form, in the event that our processing is based on a legitimate interest (balancing of interests). In order to process your objection, we kindly request you to refer to your particular situation as to why you believe that your rights and freedoms are at a particular risk (see Article 21 of GDPR for more details). Please note that the right to objection is not absolute, and we will stop the processing of your data only provided we cannot demonstrate compelling legitimate grounds for processing.
Right to Data PortabilityYou have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transfer it to another controller.
Right to Withdraw ConsentIf you have given consent for the processing of your personal data, you can withdraw it at any time via the contact options provided at the bottom.
Right to Lodge a ComplaintIf you believe your data has been processed unlawfully, you can lodge a complaint with the relevant data protection authority. Here is the contact information for the supervisory data protection authority:

Data Protection Commissioner,

Address: Kypranoros 15, Nicosia 1061, Cyprus

Postal address: P.O.Box 23378, 1682 Nicosia, Cyprus

Tel: +357 22818456

Fax: +357 22304565

Email:commissioner@dataprotection.gov.cy

If you are a California resident, in addition to those established under the GDPR described above, you have additional rights under the California Consumer Privacy Act (“CCPA”):
Access to Specific Information and Data PortabilitySeparately and in addition to “Right to access” and “Right to rectification” under the GDPR, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months only. Once we receive and confirm your verifiable consumer request, we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
If we sold or disclosed your personal information for a business purpose, we will disclose such facts separately.

Please note that you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Right to Request DeletionWhile the right to request deletion of data under the CCPA and the right to erasure under the GDPR as defined above are fundamentally similar, please note that under the CCPA, we are not required to comply with your request if we need to retain your information for specific reasons. For your convenience, an abridged version of these exceptions is provided below. For more detailed information, please refer to the full text of the CCPA or the additional clarifications from the California Attorney General.
Under the CCPA, we may retain your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you have provided informed consent.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Otherwise use the personal information internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Non-DiscriminationCalifornia consumers have the right to non-discrimination when exercising their rights under the CCPA. Specifically, we cannot deny you access to the Website, provide you with a different level or quality of service compared to other California users, or threaten you with any of these actions.
Right to request information on data transfer for third party’s direct marketing purposesYou can request information regarding the disclosure of personal information to third parties for their direct marketing purposes according to California’s “Shine the Light” law (Civil Code Section § 1798.83).
Right to Prohibit Sale of InformationWe do not sell personal data. If this changes, you will have the right to opt out of the sale of your personal data
Please note that the above listed rights are based on “GDPR” and “CCPA”. Depending on your country of residence, those rights may have different interpretations. Should you wish to assert your country-specific rights, kindly let us know, and we will review your case individually.

5.RETENTION OF DATA

Since we do not collect or process any personal data, we do not retain any personal data.

6.CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time by posting the updated notice on this webpage. Please review it regularly. If we make significant changes, we will notify you through the Website or by other means.

7.CONTACT US

Please send us any notices regarding these Privacy Policy by email to legal@fabiosamedia.com or our registered address:
WILLE TECH LIMITED
Kinyra 1, KINYRAS TOWER, 3-d floor, 'AgiosAndreas
Nicosia, 1102
Cyprus
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