Last Updated: June, 2024.

BEREALFAN PRIVACY POLICY

BRF Technology (hereinafter referred to as "the Company"), a corporation registered in Cyprus, with registered office address at 25 Voukourestiou Street, Neptune House, 1st Floor, Suite 11, CY – 3045, Limassol, Cyprus. The Company acts as the data controller for personal information gathered through its website. The Company is dedicated to safeguarding and respecting your privacy.

This privacy policy (referred to as "the Policy") delineates the categories of personal data collected and utilized when you visit and interact with www.berealfan.com (hereinafter referred to as "the Website"), as well as the manner in which such data may be utilized.

This Policy elucidates the identity of the Company, the rationale and methods behind processing personal data acquired through your usage of the Website, and delineates your rights as the data subject, along with providing means to contact us for any inquiries.

Upon furnishing us with personal data, we are bound by legal obligations towards you concerning the utilization of said data.

1. Introduction

It is imperative that you peruse this Policy in conjunction with any other privacy notices or fair processing notices disseminated on the Website contemporaneously with the collection or processing of your personal data (such as notices displayed when signing up for email updates or utilizing our services). This Policy complements other notices on the Website, including our Website Terms and Conditions/Platform Terms and our Cookies Policy, and should be construed harmoniously with said terms. This Policy does not supplant or supersede these terms.

By accessing or utilizing the Website, you acknowledge agreement to our terms (inclusive of any subsequent amendments) and this Policy. Should you dissent from the terms of this Policy for any reason, please refrain from using the Website.

We retain the prerogative to revise, update, or modify this Policy at our discretion to reflect alterations in our operations or changes in applicable legislation. In the event of significant changes, we will endeavor to notify Website users, potentially through notifications upon subsequent login attempts. However, it remains your responsibility to review this Policy before each utilization of the Website and to acquaint yourself with any alterations. The date of the last update is indicated at the beginning of this Policy for ease of reference.

Please be advised that the Website is not intended for individuals under the age of 18 ("Children"), and we do not knowingly collect personal data pertaining to Children. Should you believe that we have inadvertently collected personal data concerning your Child, please contact us at www.berealfan.com to request cessation of data processing regarding your Child.

2.Data Collection

Definition of Personal Data: When this Policy references "personal data", it pertains to information about you that can identify you, including but not limited to your name, date of birth, contact details, and IP address. By legal mandate, all organizations processing personal data in the UK are obligated to adhere to specific protocols and provide you with adequate information regarding its usage. You possess various rights to request information from these organizations regarding data usage and prevent unlawful processing. Further details about these rights can be found in the "Rights of Data Subjects" section of this Policy.

Types of Data Collected: The personal data collected from you depends on the information voluntarily provided as you engage with the Website. This may encompass:

  • Identity Data: Including but not limited to your name, date of birth, gender, and details from identification documents.
  • Contact Data: Such as email addresses, phone numbers, billing, and delivery addresses.
  • Financial Data: Where provided, includes bank account and payment card details.
  • Transaction Data: Details concerning payments, services purchased, or transactions conducted.
  • Technical Data: Comprising IP addresses, login data, operating systems, and browser details.
  • Profile Data: Encompassing usernames, passwords, social media details, interests, preferences, and uploaded content.
  • Location Data: Information regarding your Website access location.
  • Usage Data: Details about your Website interactions.
  • Audio Visual Data: Recordings and contributions made to the Website.
  • Marketing and Communications Data: Your preferences for receiving marketing material.

3. Data Collection Methods

Direct Interactions with Us: When utilizing the Website, you are likely to provide personal data through responses to questions or forms during account setup. This includes Identity, Contact, and Financial Data. Any self-provided or volunteered data, including uploads to the Website, is also collected.

Use of the Website: Interactions with other users result in the collection of both uploaded content and data regarding your interactions. This includes messages sent, posts viewed or liked, and details of services accessed or purchased.

Automated Technologies: Personal data is collected through technologies like cookies during Website interactions. This includes device and browser information, IP addresses, page interactions, and URLs. Such data is used to ensure Website functionality, security, and to monitor online traffic and audience engagement.

For further information on these technologies and the cookies utilized, please refer to our Cookies Policy.

Third Parties or Public Sources: We collaborate with third parties who may collect anonymous usage data or statistical information. Personal data may also be obtained from sources like Twitter or Google accounts used for Website login.

Updating Your Information: To amend previously provided information, please contact us at support@berealfan.com.

4. Utilization and Disclosure of Personal Data

Lawful Basis for Processing Personal Data

We shall only process your personal data when permitted by law. Typically, we process personal data under the following circumstances:

  • With your explicit consent or when you have otherwise granted permission;
  • When necessary to fulfill contractual obligations between us;
  • When it is in our legitimate interests (or those of a third party) and your fundamental rights do not supersede those interests; and
  • When compelled to comply with legal or regulatory mandates.

Examples of Data Utilization and Associated Lawful Basis

Below are instances illustrating how we may utilize the information gathered about you, along with the lawful basis for each usage:

OperationExamples of the categories of personal data we may collectLegal grounds for processing
To furnish you with our services and enroll you as a new subscriberIdentity, contact, financial, transactional, technical, profile, and marketing communications dataExecution of a contract with you
To handle and deliver your orders and subscriptions, including: (a) Managing payments, fees, and charges (b) Retrieving and collecting owed fundsIdentity, contact, financial, transactional, technical, profile, and marketing communications dataExecution of a contract with you. Essential for our legitimate interests (to recuperate owed debts to us and creators)
To utilize the recordings, contributions, or uploads you've provided on the Website, encompassing but not limited to distributing, broadcasting, and publicizing themIdentity, contact, profile, and audiovisual informationExecution of a contract with you
Testing new products, tracking popular products and services, developing innovative customer engagement methods, and overseeing interactions with third partiesIdentity, contact, financial, transactional, profile, and marketing communication dataExecution of a contract with you. Essential for our legitimate interests (to analyze customer usage of our products/services, to enhance and expand our business)
To comply with applicable laws and regulations, mitigate risk for ourselves and our customers, address complaints, and endeavor to prevent criminal activitiesIdentity, contact, financial, transactional, profile, and usage dataEssential for our legitimate interests (in conducting our business, ensuring network security, and preventing fraud). Essential to comply with our legal/regulatory obligations
To administer our relationship with you, including informing you of any alterations to the Website or services rendered thereinIdentity, contact, profile, transactional, and marketing communication dataTo undertake requisite measures to facilitate a contract with you. Execution of a contract with you. Essential to comply with our legal/regulatory obligations. Essential for our legitimate interests (to maintain updated records and analyze customer usage of our products/services)
To facilitate your participation in or completion of a surveyIdentity, contact, profile, usage, and marketing communication dataExecution of a contract with you. Essential for our legitimate interests (to analyze customer usage of our products/services, to enhance and expand our business)
To manage and safeguard our business and the Website, which includes troubleshooting, data analysis, credit and fraud checks, and system testingIdentity, contact, and technical dataEssential for our legitimate interests (in conducting our business, providing administration and IT services, ensuring network security, preventing fraud, and in the context of business reorganization or group restructuring exercises). Essential to comply with our legal/regulatory obligations
To distribute relevant content, newsletters, and advertisements, including providing suggestions and recommendations about content or services that may be of interest to you, through the Website, or to tailor your experience on the Website accordinglyIdentity, contact, profile, usage, marketing and communications, transactional, and technical dataEssential for our legitimate interests (to promote products, surveys, and services we offer that you may find interesting). Essential for our legitimate interests (to analyze how customers use our products/services, to enhance them, to expand our business, and to inform our marketing strategy)
To employ data analytics for enhancing and optimizing the effectiveness and functionality of the Website, our services, marketing efforts, customer relationships, and user experiencesAll categories of data that we collectEssential for our legitimate interests (in optimizing the Website's content and ensuring that you receive pertinent commercial communications while using it)
To address your inquiries when you have reached out to us via email or telephone, or engaged in surveys or reviewsIdentity, contact, marketing communications data, and technical informationEssential for our legitimate interests (in responding to and contacting you regarding the inquiries you have made concerning the services we provide, and assessing your responses to our surveys)
To create new services for our users and to innovate and enhance the services they utilize most frequentlyAll categories of data that we collectEssential for our legitimate interests (in operating, developing, and expanding our business)

Marketing and Advertising We may utilize your personal data to formulate an understanding of your potential interests or needs. This enables us to determine which services and offers may be pertinent to you (referred to as marketing).

You will only receive marketing communications from us (such as emails or text messages) if you have requested information from us or purchased content, goods, or services from us or via the Website, and you have not opted out of receiving marketing at the time of purchase.

Opting Out of Marketing

To unsubscribe from marketing messages at any time, please click on the unsubscribe link at the bottom of any marketing message. Alternatively, you may contact us directly if you prefer not to receive any marketing materials from us.

Should you choose to 'opt-out' of receiving marketing messages from us, we may retain your email address or other contact details on file to ensure compliance with your opt-out request.

Sharing your Personal Data

Depending on how and why you provide us with your personal data, we may share it in the following manners:

  • With any member of our company group, including our subsidiaries and ultimate holding company.
  • With selected official bodies to prevent and detect fraud or credit risks, such as government bodies, tax authorities, law enforcement agencies, and fraud protection agencies.
  • With selected third parties who provide services or aspects of the Website's functionality, such as hosting or storing data for us.
  • With analytics and search engine providers who assist us in improving and optimizing the Website.
  • With creators of profiles, content, and channels that you have subscribed to or purchased on the Website.
  • With selected third parties who provide professional services, such as insurers, accountants, auditors, and lawyers.

We may also disclose your personal data to third parties in the following circumstances:

  • In the event of a business sale or acquisition.
  • If BRF Technology or its assets are acquired by a third party.
  • To comply with legal obligations or assist lawful authorities in crime investigation.
  • To enforce the Website's terms of use or protect our rights, property, or safety, and that of our customers or others.

Service Providers

Our service providers offer administrative, statistical, and technical services. We only provide service providers with the minimum amount of personal data required to fulfill the services we request and stipulate that they protect this data and refrain from using it for any other purpose. We ensure all our data processors sign contracts with us, committing to respecting individual rights and assisting us in helping you exercise your rights as a data subject.

Links to Third-Party Sites

We may provide links to third-party websites, plugins, and applications not affiliated with the Website. These sites are beyond our control and are not covered by this Policy. Accessing third-party sites using provided links may result in those operators collecting personal data from you in accordance with their own privacy policies. Please review these policies before submitting any personal data to those websites.

5. Data Retention Period

We will retain your personal data on our systems only for as long as necessary to provide you with the requested services, including fulfilling any legal, regulatory, tax, accounting, or reporting obligations. We may retain your personal data for a longer period in the event of a complaint or if there is a reasonable belief of potential litigation concerning our relationship with you.

Accordingly, your personal data will be retained as long as you maintain a registered account on the Website, whether actively used or not. If you delete your account, we may need to retain some personal data associated with the account or transactions made using it for up to six years (for the reasons outlined above).

You may request the deletion of some or all of your data earlier under certain circumstances. Refer to the "Rights of Data Subjects" section below for further information. Additionally, we may anonymize your personal data for research or statistical purposes, in which case this information may be used indefinitely without further notice.

6. Security Measures

BRF Technology takes the protection of your information seriously. We have implemented appropriate security measures to prevent unauthorized access, use, alteration, or disclosure of your personal data, including the use of secure servers, encryption, and passwords.

If you have chosen a password, or one has been provided to you, to access certain parts of the Website, you are responsible for keeping it confidential and should not share it with anyone.

Access to your personal data is limited to employees, agents, contractors, and third parties with a business need-to-know. They will only process your personal data as instructed and are subject to confidentiality obligations.

We have established procedures to address any suspected personal data breaches and will notify you and any applicable regulator of a breach if legally required to do so.

7. International Data Transfers

If you are located in Europe, please note that we may use service providers located outside of the UK and/or the European Economic Area (EEA). These service providers may assist us in fulfilling your requests, processing payment details, and providing services or support.

We aim to minimize international data transfers that occur without your prior knowledge and authorization. Where transfers are necessary, we ensure appropriate safeguards are in place to securely hold your personal data and uphold your data subject rights.

Personal data transfers are either made to countries recognized by the European Commission as providing adequate protection or to countries without adequate protection but governed by the European Commission's standard contractual clauses or other appropriate cross-border transfer solutions.

By submitting your personal data, you consent to its transfer, storage, or processing. For more information on the mechanism used for transferring your personal data, please contact support@berealfan.com.

8. Rights of Data Subjects

For individuals residing in the UK or the EEA, the following outlines your rights concerning your personal data held by BRF Technology. This section provides a summary of the relevant legislation in your jurisdiction and should be understood as such, not as a substitution or extension of your legal rights.

This section does not apply if you do not reside in one of the regions mentioned above.

If you are a resident of one of the regions mentioned above, you have the following rights regarding your personal data held by BRF Technology:

Right of Access

You have the right to request access to the personal data we hold about you, commonly referred to as a "subject access request." This right allows you to obtain a copy of your personal data to ensure its accuracy and lawful processing. However, it does not entitle you to request personal data about others or unrelated documents.

You can exercise this right by informing us in writing of your subject access request, without the need for a specific form.

Your Right to Rectification and Erasure

You may request the correction of any personal data we hold about you if you believe it to be incorrect or inaccurate. Additionally, you can ask us to erase your personal data if you believe it is no longer necessary, commonly known as the “right to be forgotten.” However, we may request verification of any new data provided by you and may retain personal data if we have a legal obligation to do so or for other legitimate reasons. You can exercise this right by informing us in writing of your request to rectify or erase your personal data and providing the basis for your request.

Your Right to Restrict Processing

If we process your personal data based on legitimate interests, you have the right to request the cessation of such processing if it affects your fundamental rights and freedoms or if you question the validity of these interests. You may also request processing restrictions in certain circumstances, such as disputing data accuracy or when the data is no longer needed for processing but is necessary for legal purposes.

You can exercise this right by informing us in writing of your request to stop processing relevant aspects of your personal data and specifying the relevant condition for your request.

Your Right to Portability

You may request to receive your personal data, processed by automated means, in a commonly used machine-readable format for transfer to a third party.

While this right may not frequently apply to our interactions, we are open to considering such requests if you wish to transfer your data to a third party.

Your Right to Object to Processing

You have the right to object to the processing of your personal data based on legitimate interests. We will comply with your objection unless we have compelling legitimate reasons for continued processing or need to process your data for legal purposes.

Your Right to Stop Receiving Communications

If you receive marketing communications from us, you have the right to opt-out at any time by using the provided ‘unsubscribe’ link in each communication or by contacting us directly at support@berealfan.com.

Your Right to Object to Automated Decision Making and Profiling

You have the right to be informed about any automated decision making and profiling of your personal data and to object to it. You can exercise this right by contacting us at support@berealfan.com.

Exercising Your Rights

When exercising your rights, we may request verification of your identity. Please specify the right you wish to exercise and provide reasons if applicable, as this will facilitate prompt and efficient processing of your request.

Statutory Regulator

If you are dissatisfied with our data processing, you have the right to lodge a complaint with your local data and privacy regulator. For UK residents, the Information Commissioner’s Office. If you are resident in the European Union, details of your local regulator are published by the European Data Protection Board.

9. Contact Information

Berealfan is operated by BRF Technology. We are a limited company registered in Cyprus, with registered office address at 25 Voukourestiou Street, Neptune House, 1st Floor, Suite 11, CY – 3045, Limassol, Cyprus.

If you have any queries regarding this Policy, wish to exercise any of your rights set out above, or believe the Policy has not been followed, please contact us by emailing at support@berealfan.com. If email is not an option, please write to us at the following address: 25 Voukourestiou Street, Neptune House, 1st Floor, Suite 11, CY – 3045, Limassol, Cyprus.