Privacy Policy

Last updated on February 2019

Fenomen recognizes that your privacy is very important and we take it seriously. This Privacy Policy (“Privacy Policy”) describes our policies and procedures on the collection, use, disclosure, and sharing of your personal information or personal data when you use the Platform. This Privacy Policy applies to activities by Fenomen and its affiliates and subsidiaries (collectively Fenomen, platform or “us”). Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service. This Statement of Privacy applies to Fenomen site including but not limited to mobile application and widgets and governs data collection and usage. By using the Fenomen and the Service therein, you consent to the data practices described in this statement.

INFORMATION COLLECTION

We collect information directly from individuals, from third parties, and automatically through the Platform.

Account and Profile Information.

We collect and store the information you provide to us when you signup and later configure your profile:

  • Your username, password and e-mail address when you register for a Fenomen account.
  • Profile information that you provide for your user profile (e.g., first and last name, picture, phone number). This information allows us to help you or others be "found" on Fenomen.
  • Your name, photo and profile description will be available for viewing to users of the Platform.

Content.

We collect and store the information and content that you post to the Platform, including your posts, photos and comments. Your Content, date and time stamps, and all associated mentions, likes and comments are publicly viewable on the Platform, along with your name. This also may be indexed by search engines and be republished elsewhere on the Internet in accordance with our Terms of Service. For more information about what you can change, see the below section on MODIFYING YOUR INFORMATION.

Communications.

When you communicate with us (via email, phone, through the Platform, or otherwise), we may maintain a record of your communication.

Integrated Service Provider and Linked Networks.

You can elect to sign in or sign up to the Platform through a linked network (i.e.Facebook), and you can connect your existing account with certain third party networks like Facebook (each a “Linked Network”). If you elect to sign up through or connect a Linked Network, we receive certain profile and account information about you from the Linked Network. These Linked Networks may also appear in your profile, so that people can find you on these Linked Networks. The specific information provided to us by Linked Networks is determined by these third parties and may vary by network. In all cases, the permissions page for the Linked Network will describe the information being shared. You should consult their respective privacy policies for information about their practices. You may elect to use information from the Linked Network to populate your profile on the Platform and help you find and follow your contacts on the Platform.

Automatically Collected Information About Your Activity.

We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of the Platform. We also collect and may store information that your computer or mobile device provides to us in connection with your use of the Platform such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs. We also receive information when you view content on or otherwise interact with the Platform, even if you have not created an account. For more information, see the “Cookies, Pixels and Tracking” section below Policy.

Cookies, Pixels and Tracking.

We and our third party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on the Platform and across third party sites or online services. We may combine this information with other information we collect about users. Below, we provide a brief summary these activities.

Cookies. These are small files with a unique identifier that are transferred to your browser through our websites. They allow us to remember users who are logged in, to understand how users navigate through and use the Platform, and to display personalized content and targeted ads (including on third party sites and applications).

Pixels, web beacons, clear GIFs. These are tiny graphics with a unique identifier, similar in function to cookies, which we use to track the online movements of users of the Platform and the web pages of users of our Ad Services, and to personalize content. We also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications.

Analytics Tools. We use internal and third party analytics tools, including Google Analytics, Facebook Analytics, Firebase, Fabric.io and Rakam.io. The third party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.

Engagement.

We collect browsing information – such as IP address and location, date and time stamp, user agent, Fenomen cookie ID (if applicable), URL, unique advertising or content identifiers (if applicable) and time zone, and other information about user activities on the Platform. We may also receive information about you from third parties, such as other users, partners (including ad partners), or our affiliated companies.

HOW WE USE YOUR INFORMATION

We do not sell your personal data – such as your name and contact information – to third parties to use for their own marketing purposes. We use the information we collect for the following purposes:

Provide our Services. To provide you the services we offer on the Platform, communicate with you about your use of the Platform, respond to your inquiries, provide troubleshooting, and for other customer service purposes.

Personalization. To tailor the content and information that we may send or display to you in the Platform, to suggest followers and content, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Platform.

Discovery. To make it easy for you to find your friends and meet people you might be interested in the Platform.

Advertising. To display interest-based advertising to you in the Platform, to improve our advertising and measurement systems so we can show you relevant ads, and to measure the effectiveness and reach of ads and services.

Marketing and Promotions. For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third party products and services.

Analytics. To gather metrics to better understand how users access and use the Platform; to evaluate and improve the Platform, including the Ad Services and personalization, and to develop new products and services.

Comply with Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes.

Prevent Misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

HOW WE SHARE YOUR INFORMATION

We share information as set forth below, and where individuals have otherwise consented:

Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service and support providers, as well as those who assist us in providing the Ad Services.

Affiliates. The information collected about you may be accessed by or shared with subsidiaries and affiliates of Fenomen, whose use and disclosure of your personal information is subject to this Privacy Policy.

Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.

Legally Required. We may disclose your information if we are required to do so by law.

Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of Fenomen, its users, or others.

Your Content and Activity. Your Content, including your name, profile picture, profile information, and certain associated activity information is available to other users of the Platform and may be viewed publicly. Public viewing includes availability to non-registered visitors and can occur when users share Your Content across other sites or services. In addition, Your Content may be indexed by search engines. See the section below about MODIFYING YOUR INFORMATION for information about how you may change how certain information is shared or viewed by others.

Metrics. We may share with users of our advertisers or publishers aggregate statistics, metrics and other reports about the performance of their ads or content in the Platform such as the number of unique user views, demographics about the users who saw their ads or content, conversion rates, and date and time information. We do not share IP addresses or personal information. We may also allow our advertisers or publishers to use Pixels on the Platform in order to collect information about the performance of their ads or content.

Anonymized and Aggregated Data. We may share aggregated or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

HOW WE STORE AND PROTECT YOUR INFORMATION

How we store your information.

Your information collected through the Service may be stored and processed in other countries which Fenomen, its Affiliates or Service Providers maintain facilities. Fenomen, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. By registering for and using the Service you consent to the transfer of information to any other country in which Fenomen, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

How We Protect Your Information.

We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, Fenomen cannot ensure the security of any information you transmit to the Platform or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Fenomen, at all times. Your privacy settings may also be affected by changes the social media services you connect to Fenomen make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

MODIFYING YOUR INFORMATION

You may update or correct your account information at any time by logging in to your account. You may also make a number of other adjustments to settings or the display of information about you. You may, of course, decline to submit information through the Platform, in which case we may not be able to provide certain services to you. You may also control the types of notifications and communications we send, limit the information shared within the Platform about you, and otherwise amend certain privacy settings. Here is some further information about some of your choices:

Your Content. You may delete the videos that you post at any time. Any videos you have posted may remain on the Platform.

Emails and Communications. When you join the Platform by signing up for an account or creating a profile, as part of the service, may receive emails from us regarding to updates or relevant content for you. You can manage your email in your account profile settings. If you remove your email from your account you will no longer receive emails from us.

Third parties may comment on your postings within the Platform.

Followers. You can block the ability of another Fenomen user to follow you. You can change whether or not you follow other users. When you block a user he will no longer will be able see content you have posted such as your profile information, posts or comments.

PROTECTION OF PERSONAL INFORMATION

Fenomen takes precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. In case of suspicious account activity or a breach in security, Fenomen may notify its users about the condition and the risks.

Fenomen uses Secure Sockets Layer (SSL) encryption on all web pages where personal information is collected.

THIRD PARTY AD NETWORKS

For information about and to opt out of interest-based ads from many ad networks, go to:

U.S.: www.aboutads.info Internet Advertising Bureau

Canada: www.youradchoices.ca

European Union: www.youronlinechoices.eu/

LINKS TO OTHER WEBSITES

The Fenomen Platform may contain links to third party sites or online services. We are not responsible for the practices of such third parties, whose information practices are subject to their own policies and procedures, not to this Privacy Policy.

TRANSFERRING YOUR DATA

Fenomen is headquartered in the Turkey, and has operations, entities and service providers in the Turkey and throughout the world. we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

CHILDREN’S PRIVACY

The Services are only for people 13 years old and over. By using the Services, you confirm that you are over the relevant age specified herein. If we learn that someone under the relevant age specified above is using the Services, we will terminate that user’s account. If you are over the age of 14 but under the age of 19, you declare that you have the consent of your parent or legal guardian to receive the Services or to register an account for the Services.

CHANGES TO PRIVACY POLICY

If we change our privacy policies and procedures, we will post those changes on this page. We reserve the right to make changes to this privacy policy without advance notice. However, if we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes, such as via prominent notice in the Platform or to your email address of record.

If you have any questions about our practices or this Privacy Policy, please contact us at [email protected]