Privacy Policy

Effective Date: April 2025

1. Introduction and Purpose

This Privacy Policy outlines our principles and practices regarding the collection, storage, processing, and protection of your personal data. It also explains your rights regarding the personal data we process. We are committed to complying with the EU General Data Protection Regulation (GDPR), ensuring transparency, and adhering to the principles of lawfulness, purpose limitation, and data minimization.

2. Definitions and Terminology

Personal Data: Any information relating to an identified or identifiable natural person (e.g., name, email address, payment details, IP address, device identifiers).

Processing: Any operation or set of operations performed on personal data, whether automated or not, including collection, storage, use, disclosure, and deletion.

Consent: Freely given, specific, informed, and unambiguous indication of the data subject’s wishes.

Controller: The entity that determines the purposes and means of processing personal data.

Processor: The entity that processes personal data on behalf of the Controller.

3. Contact Information and Data Controller Details

The Data Controller for FreshContentWorld is:

Company: COMPU-VISIONUK LTD
Company Number: 14893319
Address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email for Legal/Privacy Inquiries: privacy@freshcontentworld.com
Telephone: [Insert Telephone Number if applicable]

4. Collection and Types of Processed Data

Personal Data: We collect information provided during registration and while using our service, including but not limited to your name, email address, payment details, IP address, and device identifiers.

Non-Personal Data and Aggregated Information: This includes data that does not identify you personally (e.g., aggregate statistics, page views, browsing patterns).

Data Collected by Analytical Systems: We use third-party services for analyzing user behavior and optimizing our Site’s functionality. These services include:

• Google Analytics: Collects data on traffic, referral sources, and user activity in aggregated form.
• Simple Analytics: Provides information about visits and interactions without using traditional cookies.
• Heap Analytics: Automatically collects user behavior data for analysis.
• Hotjar: Generates heatmaps, tracks clicks, and records sessions to identify usability issues.

For all these systems, data is anonymized and aggregated wherever possible to minimize privacy risks. We recommend reviewing the privacy policies of these services for detailed information.

5. Lawful Grounds for Data Processing

We process your personal data on the following lawful bases:

• Consent: Your explicit consent provided during registration or use of our service.
• Contractual Necessity: To provide you with a subscription service, manage your account, and fulfill our contractual obligations.
• Legitimate Interests: To ensure the security and smooth operation of our service, perform market analysis, and improve our services.
• Legal Obligations: To comply with statutory obligations, such as financial reporting, tax, and other legal requirements.

6. Purposes and Methods of Data Processing

Main Purposes:

• Provision and maintenance of subscription services and access to mobile content.
• Conducting analytics and performance optimization using tools such as Google Analytics, Simple Analytics, Heap Analytics, and Hotjar.
• Processing payments through secure payment gateways (e.g., Stripe).
• Carrying out marketing research and sending promotional materials (only when explicit consent is provided).

Protection Measures: We employ technical and organizational measures—including encryption, anonymization, access controls, and regular backups—to protect your data from unauthorized access, alteration, or disclosure.

7. Data Retention and Deletion Policy

Your personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. You have the right to request the deletion or anonymization of your data in accordance with GDPR provisions.

8. Data Transmission to Third Parties

We may share your data with trusted third-party partners for purposes such as payment processing, analytics, and service improvement. These include payment systems, analytics platforms, and other service providers.

If your data is transferred outside the European Economic Area (EEA), we implement appropriate safeguards (e.g., standard contractual clauses, certification mechanisms) to ensure your data remains protected.

9. Use of Cookies and Similar Technologies

We use cookies and similar technologies for several purposes:

• Functional Cookies: To enable core functionality of the Site.
• Analytical Cookies: To collect aggregated data on user interactions (via Google Analytics, Simple Analytics, Heap Analytics, Hotjar).
• Marketing Cookies: To deliver personalized content and advertisements, subject to your consent where required by law.

You can manage or disable cookies through your browser settings or our Site’s cookie management tools.

10. Data Subject Rights

You have the following rights concerning your personal data:

• Right of Access: Request details on the data we process about you.
• Right to Rectification: Update or correct inaccurate information.
• Right to Erasure: Request deletion or anonymization of your data, subject to applicable legal constraints.
• Right to Restrict Processing: Ask for limitations on the processing of your data.
• Right to Data Portability: Receive your data in a structured, machine-readable format for transfer to another controller.
• Right to Object: Object to the processing of your data, particularly for direct marketing purposes.
• Right to Lodge a Complaint: Contact the relevant supervisory authority if you believe your data rights have been infringed.

11. Data Security Measures

We implement various security measures to protect your data, including:

• Encryption of data during transmission and at rest.
• Robust authentication and access control mechanisms.
• Regular security audits and continuous monitoring.
• Periodic reviews and updates of our security protocols.

12. Changes to the Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be communicated to you via email or through a notice on the Site, and the revised policy will be posted with a new effective date. Continued use of our services indicates your acceptance of the updated policy.

Effective Date: April 2025