Privacy Policy

1 Introduction

1.1 Foxcoo is committed to protecting your privacy. This Policy describes what we do with your data and applies to all processing of data that identifies you or may be used to identify you with (“Personal information”) by Foxcoo, such as but not limited to processing via the Foxcoo.com website (hereinafter: “Website”). Foxcoo complies with the European General Data Protection Regulation (hereinafter: “GDPR”)

1.2 Foxcoo may amend this Policy at any time. In case the Policy is amended, the amended Policy will be made available to you through publication of the amended Policy on the Website. Should you have any questions after reading this Policy, or would like to exercise the rights as entailed in this Policy, please contact Foxcoo via the above stated details.

1.3 For ease of reference, each section of this privacy policy is set out below:

Introduction
What Personal information do we process?
For what purposes do we process Personal information?
Who may receive your Personal information?
How long do we store your Personal information?
How do we secure your Personal information?
What are your rights?
What are your choices?
What else is there to know?

2 What Personal information do we process?

2.1 Foxcoo is a data controller under the GDPR. This means that with regard to any Personal information referred to in this Policy, we are responsible for determining the purpose for which we process this data, and determine the means necessary for the processing of this data. As a data controller, we process the data set out in this section.

Information that is processed automatically

2.2 When you access our Website, we may collect automatically generated information about you and/or your device. We do not have the intent of identifying you with this information, but as it may be possible to identify you directly or indirectly on the basis of this information, we are required to mention it in this Policy. Automatically generated information may include:

Your IP address;
Your (mobile) device identifier;
Information about your settings, such as screen ratio, screen resolution, language settings, browser information (user agent) and/or operating system;
Query-string;
Your Website preferences
Your location and time zone;

Information voluntarily provided by you

2.3 Access to the Websites, their content and any web search results generated by using the Websites in general do not require you to submit personal details to us. We do not require you to create an account, nor do we need your email address or other contact details in order to provide our services.

2.4 We do understand that under certain circumstances, you may want to provide us with more information about yourself, for example in relation to any enquiry you may want to make with us. When you are reaching out to us, we may process the following information about you, in addition to the information that is processed automatically:

Your name;
Your company name;
Your email address;
Your website;
Any other Personal information you provide us with;

2.5 If you choose to voluntarily provide us with any personal details, we recommend that you limit the provision of such data to the absolute minimum, and to not provide us with any sensitive Personal information, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data or data about your sex life or sexual orientation.

Information that is processed by our partners

2.6 Third parties may be able to process data related to you through our website in order to provide us with certain products and services. Such third parties may use technologies such as cookies, ad tags or ad beacons to collect information about your interaction with any products and services (such as advertisements) they offer through the Website. Data that is processed by such partners may include:

Marketing Our advertisement partners may process data on advertisements shown on our Website and on third party websites, including on their relevance and effectiveness;
Loyalty program Some of our Website offer you the opportunity to participate in a third party loyalty program. We are not the data controller with regards to such loyalty program, but merely a data processor processing data on behalf of the third party loyalty program provider. Any processing activities related to loyalty programs are subject to such party’s privacy policy.

2.7 Any information collected by third parties, such as the above information, may be combined with information about you that is retrieved from other sources, including sources not being our Website. If you have consented thereto, they may use so called behavioural targeting or profiling techniques to track your activity across multiple websites, browsers and devices, and to personalize advertisements shown to you. The use by third parties of any such techniques are subject to that party’s individual privacy policy, not this Foxcoo Policy. Foxcoo does not track its Website users, and does not use any behavioural targeting or profiling techniques.

3 For what purposes do we process Personal information?

3.1 Primary purposes for which we process your Personal information are to offer you the best services possible, to optimize our Website and services and to ensure continuity thereof. More specifically, your personal details can be used for the following purposes:

To provide our services: this may seem rather obvious, but we may need certain information about you in order to be able to provide our services. However, as set out above, identifying you as a user is not our main intention. It is however unavoidable that we process certain data such as IP-address, device identifier and other automatically collected Personal information as set out above.
To customize our services: you have the option to customize the Website experience to your needs. In order to be able to remember your customizations, we may process Personal information about you, such as a unique ID and your IP address.
To improve our services: our Website and services are constantly involving, and we are constantly working on improving your user experience and adding new functionality to our Website. Processing among others analytics data (in an aggregated form) is essential to this.
To secure our services: in order to be able to provide your with the best user experience possible, it is necessary to keep out ‘the bad guys’, such as hackers, automated bots or other threats. We are therefore constantly monitoring our services and the use of our services. When we identify a possible threat, we may take immediate action in order to avoid disruption or wrongful or fraudulent use of our services.
To communicate with you: when you contact us, we process your contact details such as name and email address and any other Personal information you may provide to us in order to be able adequately revert to you on your enquiry.
For marketing purposes: data on your visit to our Website may be used by our advertisement partners in order to serve you with advertisements about our services elsewhere. As indicated, we do not use any behavioural targeting or profiling techniques.
To exercise and safeguard our rights: though we trust you will use our Website and services in accordance with the law and our terms of service, we may need to exercise our legal rights among others in case you infringe our intellectual property, engage in fraudulent acts or act in violation of this Policy or our terms of service.
Compensation of our partners: as we show and run advertisements certain Personal information may be needed in order to calculate the compensation to be paid to or received by or from our partners.
To comply with a legal obligation: we may be required by law or by a court order to process (and/or transfer) certain Personal information.

3.2 We have multiple legal grounds for the processing of your Personal information. Applicable legal grounds are listed below:

Execution of a contract with you: most processing activities are carried out in order to provide you with our services. We provide our services on the basis of our terms of service, a contract entered into with you when using our services.
Your consent: should certain processing activities not be related to our contract with you, we may process your Personal information on the basis of your consent.
Compliance with a legal obligation: we may under certain circumstances be legally required to process your Personal information.
Our legitimate interests: your Personal information may be processed by us for purposes of our legitimate interests, such as our commercial interests. This may be the case with among others (re)marketing and compensation of our partners.

4 Who may receive your Personal information?

4.1 Foxcoo may transfer your personal inform to third parties, being:

Suppliers: when such is necessary to enable the use Website and services, we may transfer your Personal information to suppliers, subcontractors and business partners, such as but not limited to our hosting partner company that host the Websites.
Group companies: we may provide Personal information to other companies within the Foxcoo website, if this is necessary for compliance, internal reporting, auditing or security purposes.
Advertisement partners: Information on your Website visit may be provided to advertisement partners in order to serve you with (relevant) advertisements on our Website and elsewhere, and to measure effectiveness of advertisements.
Law enforcement agencies: we may be under an obligation to provide your information to law enforcement, regulators, courts or other public authorities in relation to an official (court) order. In addition we may provide your data to law enforcement agencies, regulators, courts or otherwise in order to exercise our rights.
Fraud prevention: we may engage third parties in order to investigate or prevent any fraudulent acts or to protect our assets and/or rights.
Third parties: we may transfer data to third parties acquiring or merging with Foxcoo, or purchasing part or all of our assets, or in case of a restructuring. Parties we transfer your Personal information to may be situated outside the European Economic Area. We have implemented appropriate safeguards to protect Personal information from unlawful processing. Where we are the data controller and engage a third party as a data processor, such third parties shall always act and process the Personal information on behalf of Foxcoo and the instructions we provide them with.

5 How long do we store your Personal information?

5.1 We retain your Personal information for as long as necessary in order to fulfil the associated purpose as set out above. After that, we may retain your Personal information if this is required or necessary in order to comply with applicable law or in order to be able satisfy any legal, reporting or audit requirements. Where possible we anonymize or pseudo-anonymize your Personal information or retain it in an aggregated form only.

6 How do we secure your Personal information?

6.1 We highly value the security of your Personal information. Therefore we have implemented technical and organizational measures to protect your Personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To keep your Personal information safe, the following measures are implemented:

Encrypt the transfers of data via the Website;
Protect the servers on which your Personal information is stored with passwords and appropriate security measures;

7 CCPA ( California Consumer Privacy Act) privacy rights (Do Not Sell My Personal Information)

7.1 California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above, if you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, you may do so through the means set forth above under “Notice of Your Choices about Our Use and Sharing of Personally Identifiable Information”. To find out more about your opt-out rights and how we comply with this law, please contact us at the email address or postal address set forth in that section above.

Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting us at the email address or postal address described above. We will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Company does not control.

7.2 Under the CCPA ( California Consumer Privacy Act), among other rights, California consumers have the right to:

Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

8.1 We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

9 What are your rights?

9.1 Applicable data protection laws and regulations guarantee you certain rights:

Objection: Depending on the situation, you have the right to consent or object to the processing of your Personal information and the conditions under which this processing takes place.
Access: You have the right to request from us, without constraint, at reasonable intervals and without excessive delay or expense, i) a confirmation as to whether or not Personal information regarding you is being processed, ii) information on the purposes for which Personal information is processed, iii) the categories of Personal information concerned, and iv) the recipients or categories of recipients to whom the Personal information is disclosed. You have the right to receive, in an intelligible form, a communication of the Personal information being processed and of any available information as to the source(s). Furthermore, you have the right to knowledge of the underlying logic of the automated processing of Personal information relating to you.
Rectification, erasure, blocking or deletion: You, where appropriate, have the right to rectification, erasure, blocking or deletion of your Personal information that is not processed in compliance with data protection laws and regulations, in particular when the nature of the data is incomplete or inaccurate.
Notification: You have the right to a notification to third parties to whom your Personal information has been disclosed, when you have been granted any rectification, erasure, blocking or deletion as stated above, unless such notification proves to be impossible or requires a disproportionate effort from us.
Withdraw consent: where we are processing Personal information relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time.
Complaint with relevant authority. You have the right to file a complaint with the relevant data protection authorities.

9.2 In order to fulfil your possible requests pursuant to the rights as stated above, we may request specific additional information from you to identify you with or we may ask you for information to identify you with. We only collect and process such specific data with the purpose of executing your above stated rights insofar this is requested by you.

10 What are your choices?

10.1 As indicated, you may choose to withhold your consent to certain processing activities, such as the processing of your personal information by our advertisement partners. The easiest way to do so is by opting out through among others these sites:

10.2 As an alternative to the above, you may set your web browser or mobile device settings in such a way that certain technologies, such as third party cookies, are blocked as a general rule. For more information on how to do this, we refer to the help-section of your web browser or mobile device.

10.3 Any further information on cookies and other technologies used on our Website is included in the Foxcoo cookie policy.

11 What else is there to know?

11.1 This Policy is effective until terminated by Foxcoo. If you no longer agree to be bound by this Policy, you must cease your use of the Website and can no longer use the Website.

11.2 Should you have any questions after reading this Policy, or would want to exercise any right as stated in this Policy, please do not hesitate to contact us via the contact form.

Updated: 02-16-2021