FIDE PRIVACY POLICY


LAST REVISION: July 27 2022


This Privacy Policy (“Privacy Policy”) becomes effective immediately for users of the Mobile Applications, as defined below. This Privacy Policy is applicable to all those who use or visit the Mobile Applications (“you”). The mobile application “FAN App” , available on the Google Play Store and the Apple App Store, (the “Mobile Applications”) are owned and operated by the entity responsible for your personal information namely FIDE (“FIDE/we”).


FIDE is committed to respecting the privacy rights of all the visitors and users of the Mobile Applications. This Privacy Policy describes and sets forth how FIDE will collect, process, use, disclose and transfer your personal information as a data controller through the Mobile Applications. This Privacy Policy also covers and sets forth how to contact FIDE if you have any questions about the privacy of your information, use our services or interact with our Mobile Applications.


YOUR INFORMATION IS PROCESSED IN UNITED KINGDOM AND IN THE EUROPEAN ECONOMIC AREA (“EEA”), AND MAY BE PROCESSED ELSEWHERE DEPENDING ON THE LOCATION OF AFFILIATES, BUSINESS PARTNERS, AND OTHER ENTITIES WHO ARE PERMITTED TO ACCESS SUCH INFORMATION UNDER THE TERMS OF THIS DATA PROTECTION POLICY (LOCATIONS OUTSIDE THE EEA MAY INCLUDE COUNTRIES WHICH MAY NOT ASSURE AN ADEQUATE LEVEL OF DATA PROTECTION ACCORDING TO APPLICABLE LAWS IN THE EEA AND UK). IF FIFA PROCESSES YOUR PERSONAL INFORMATION OUTSIDE THE UNITED KINGDOM OR EEA, ALL REASONABLE STEPS WILL BE TAKEN TO ENSURE THAT YOUR PERSONAL INFORMATION IS TREATED AS SAFELY AND SECURELY AS IT WOULD BE WITHIN THE EEA AND UNTED KINGDOM AND UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”).


Please read this Privacy Policy carefully to understand FIDE's practices regarding your information and how FIDE will treat it. By visiting or using the Mobile Applications, you acknowledge that you are expressly accepting and consenting to the practices and policies outlined in this Privacy Policy. If you object to this Privacy Policy after it becomes effective for you, you may no longer use the Mobile Application.


  1. Terms of Use


    Use of the FIDE Mobile Applications is subject to our Terms of Use provided on https://doc.fide.com/docs/app/Terms_of_Use.pdf.


  2. Definition of Personal Information:

    "Personal Information" means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


  3. Updates


    FIDE may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check this section for the latest version of this Privacy Policy. If we make material changes to this Privacy Policy, we will seek to inform you by posting a notification on the Mobile Applications or via email if you have provided FIDE with your email address ("Notice of Change").

    If you continue to access and/or use any of the Mobile Application after the effective date of such changes, then such access and/or use will be deemed an acceptance of and an agreement to follow and be bound by the terms as changed. The revised Privacy Policy supersedes all previous notices or statements regarding the Mobile Applications. For this reason, FIDE encourages you to review this Privacy Policy any time you access or use the Mobile Applications, and FIDE recommends that you print out a copy for your records.


  4. Third Party Applications and Website

    FIDE may link you to other applications and websites This Privacy Policy applies only to information that you provide to FIDE while visiting or using the Mobile Application and does not apply to any information that you provide to them or that FIDE has received, obtained or may obtain through third parties, offline or through other means, or any third parties that may obtain information about you from the Mobile Application. If you enter or choose to leave FIDE's Mobile Applications via links to other non-FIDE websites or mobile applications, your visits and actions on those websites and apps are not covered by this Privacy Policy. It is important that you understand this and check their respective privacy policies and terms of use. If you are directed to FIDE website (“Website”), you will be bound by the Privacy Policy applicable to and provided on the Website.


  5. What information does FIDE Collect And When And Why We Use It


    This section covers-



    1. General Information Collected


      Legal basis for collection of Personal Information:


      FIDE will collect and use of your personal data under lawful basis only, such as performance of a contract with you, with valid consent, compliance with a legal obligation or FIDE’s legitimate interest.

      Accordingly, FIDE may use your personal data for the following purposes:


      • to provide and receive feedback in order to improve the FIDE Mobile Application;

      • to provide and feature FIDE content, such as leagues/match videos;

      • to enable you to enjoy and easily navigate the FIDE Mobile Application;

      • to ensure appropriate customer care;

      • to provide you with services you request;

      • to manage your account in the FIDE Mobile Application;

      • to communicate with you in general;

      • to respond to your questions and comments;

      • to prevent potentially prohibited or illegal activities;

      • as otherwise described to you at the point of collection of the personal data.


        Type of Personal Information FIDE collects:


        The personal Information FIDE collects form you when you use FIDE’s Mobile Application may include but is not limited to the following categories of personal data:


        email address, last name, first name, IP address, Mobile Number.


        We may anonymize personal information and share it in an aggregated form with third parties, advertisers and/or business partners in order to analyze the Mobile Applications, improve the Mobile Applications and user experience, or for other similar purposes. The use and disclosure of such anonymous information is not subject to any restrictions under this Privacy Policy.


  6. Personal Information Retention:


    FIDE will process and store your Personal Information securely, as per our Retention Policy. After respective Retention Period, your Personal Information will be deleted, unless required by law.


    Does FIDE Collect Any Information About Minor Users?


    FIDE does not knowingly solicit or collect information from anyone below the age of majority in your respective countries (“Age of Majority”). If you are the parent or guardian of a child below the Age of Majority, and have authorized your child to use a mobile device, FIDE urges Parents express Consent for sharing any any Personal Information of the Minor while on the Mobile Application. There are no computer applications on the Mobile Applications which allow for the determination of your age. If FIDE discovers that personal information of a child below Age of Majority has been collected without parental or guardian consent, FIDE will take reasonable steps to delete this information as well as account. All information volunteered to FIDE will be treated the same as information given by anyone above the Age of Majority. FIDE recommends that the Internet browsing behavior of any child should be carefully supervised by a responsible adult at all times.

    1. How FIDE Collect Information:


      Your information is collected from FIDE's Mobile Applications, and through any of your other activities with FIDE Mobile Application. The Personal Information that FIDE collects depends on the nature of your activities.


    2. How FIDE Shares Your Information with Third Parties:


      FIDE may share your Personal Information to third parties when:


      • You specifically acknowledge and agree that FIDE may disclose your Personal Information to the third parties contributing to the delivery of services requested by yourself:

      • FIDE needs to share your Personal Information to provide a product or service you have requested; or

      • FIDE provides your Personal Information to companies who work on behalf of FIDE under data processing agreements providing for the required safeguards for your Personal Information in accordance with applicable data protection laws;

      • If FIDE believes it is necessary, at its sole discretion, to investigate, prevent, or take action regarding illegal activities, suspected fraud, emergency situations involving potential threats to the safety of any person, violations of Terms of Use and this Privacy Policy, or as otherwise required by law;


        FIDE may also disclose your Personal Information:


        1. In response to judicial or governmental subpoenas, warrants or orders served on FIDE;


        2. To protect FIDE's rights or property, to enforce the provisions of this Privacy Policy and/or any other FIDE terms and conditions or agreements, and/or to prevent harm to yourself or to another;


        3. In the event of a corporate sale, merger, re-organization, sale of assets, or dissolution of FIDE; or


        4. A petition for relief is filed under bankruptcy laws for or against FIDE or if FIDE becomes subject to an order of appointment of a trustee or receiver.


        FIDE reserves the right to release and/or use all information contained within FIDE's databases, access logs or other records concerning you, including your Personal Information, if you violate this Privacy Policy, the Terms of Use, and any FIDE terms and conditions, or other rules, policies, notices, agreements or guidelines, or if you intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity, including but not limited to hacking, even without a warrant or other court order, and to release such information in response to court and governmental orders, discovery requests and as otherwise required by law and/or to initiate FIDE's own legal proceedings. FIDE cooperates with law enforcement agencies in identifying those who may be using the Mobile Applications (or any part

        thereof) for illegal activities. FIDE also reserves the right to report any suspected illegal activity to law enforcement individuals or to entities for investigation or prosecution.o


  7. FIDE’s Use of De-Identified Information:


    FIDE may take your Personal Information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, there are no restrictions under this Privacy Policy upon the right of FIDE to aggregate or de-personalize your Personal Information, and FIDE may use and/or share with third parties the resulting non-personally identifiable information in any manner in FIDE's sole discretion.


  8. YOUR RIGHTS - LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY:


    1. You may have certain legal rights regarding your personal information depending upon the country you are in or how we interact with you. You can learn more about this in this section.


    2. Subject to the terms of this Privacy Policy we guarantee that you have following key rights wherever you are:


      1. To access your personal information. We will tell you what personal information we hold about you and can provide you with a copy of this;

      2. To seek rectification of that personal information. Where the personal information we hold about you is inaccurate we will rectify this, upon your request. Note that this right may be limited in terms of the scope of detail that we will or can rectify;

      3. To lodge a complaint to us. We will receive and handle your complaints in accordance with best practice and depending upon where you are and whether we are subject to it, any applicable law.

      4. If you are resident in the European Union or otherwise benefit from rights as a data subject under the EU General Data Protection Regulation ("GDPR"), you will have certain additional rights in relation to our handling of your personal information.

      5. To erase personal information;

      6. To restrict the processing of your personal information;

      7. To transfer your personal information;

      8. To object to the processing of personal information;

      9. To object to how we use your personal information for direct marketing purposes;

      10. To obtain a copy of personal information safeguards used for transfers outside your jurisdiction; and

      11. To lodge a complaint with your local supervisory authority.


        A further explanation of these general key rights and the GDPR specific rights is outlined in the sections below.

        1. You may have other rights depending upon the country you are in. You may therefore have rights to lodge a complaint to a local privacy authority, however whether you lodge a complaint and who you lodge it with is solely your responsibility.

        2. If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to refuse to provide this additional information if your request is manifestly unfounded or excessive.

        3. You can exercise your rights by contacting us at office@fide.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

        4. We may not always be able to address your request fully, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

    3. Right to access personal information

      a. You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

    4. Right to rectify or erase personal information

      1. You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.


      2. You can also request that we erase your personal information in limited circumstances where:

        • it is no longer needed for the purposes for which it was collected; or

      3. you have withdrawn your consent (where the data processing was based on consent); or

      4. following a successful exercise of the right to object (see right to object in section 12.13 below); or

      5. it has been processed unlawfully; or

      6. to comply with a legal obligation to which FIDE is subject.

      7. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

        • for compliance with a legal obligation; or

        • for the establishment, exercise or defence of legal claims.


    5. Right to restrict the processing of your personal information

      1. You can ask us to restrict your personal information, but only where:

        • its accuracy is contested, to allow us to verify its accuracy; or

        • the processing is unlawful, but you do not want it erased; or

        • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

      2. you have exercised the right to object, and verification of overriding grounds is pending.

      3. We can continue to use your personal information following a request for restriction, where:

        • we have your consent; or

        • to establish, exercise or defend legal claims; or

        • to protect the rights of another natural or legal person.

    6. Right to transfer your personal information

      1. You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

      2. the processing is based on your consent or on the performance of a contract with you; and

      3. the processing is carried out by automated means.

    7. Right to object to the processing of your personal information

      1. You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

      2. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

      3. Right to object to how we use your personal information for direct marketing purposes

      4. You can request that we change the manner in which we contact you for marketing purposes.

      5. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

    8. Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

      1. You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.

    9. Right to lodge a complaint with your local supervisory authority

      1. You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.

      2. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.


      Links or Usage of Third-Party Websites/App Stores


      The Mobile Applications may contain links to third-party websites. FIDE has no control over the privacy practices or the content of such third-party websites. Neither FIDE, nor any of its officers, directors, partners, employees, agents, representatives, vendors or suppliers are responsible for the content, privacy policies, products, services, reliability, viewpoint or accuracy of information on any such websites. FIDE does not control and is not responsible for the collection of personal information by third party websites, including websites owned or controlled by FIDE's preferred financial partners, advertisers, vendors and/or websites not controlled by FIDE.


      The app stores (e.g., App Store or Google Play) may collect certain information in connection with your use of the Mobile Application, including Personal Information, geo-locational information, payment information, and other usage-based data. FIDE has no control over the collection of such information by

      any third-party app store, and any such collection or use will be subject to such third-party app store's applicable privacy policy.


  9. Governing Law/Jurisdiction


    The Mobile Applications are controlled and operated from FIDE’s offices in Switzerland. All disputes are governed by the terms set forth in FIDE’s Terms of Use. Sharing of Personal Information shall be subject to the relevant Data Privacy Laws to which you are subject to.


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  10. OPT-OUT OF FIDE COMMUNICATIONS


    1. If you would like to find out more about the legal bases upon which we process personal information please contact us at office@fide.com.

    2. You may choose to opt-out of receiving electronic communications from us. To opt-out of electronic communications from FIDE, please contact FIDE at office@fide.com to request that you be unsubscribed from any of FIDE's marketing emails. You should provide your name and email address(es) to us, so that FIDE can do its best to ensure that you stop receiving such communications from us.


  11. CONTACT US


    1. Questions, comments, requests or issues arising from this Privacy Policy are welcomed and should be addressed to office@fide.com.

    2. If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at office@fide.com. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

    3. To contact your data protection supervisory authority: In some countries, you may have a right to lodge a complaint with your local data protection supervisory authority. We ask that you please attempt to resolve any issues with us before your local supervisory authority.


  12. Updating/deleting Your information


You may review, correct, update, change or request that FIDE deletes your Personal Information at any time by accessing your account on the FIDE Mobile Application. FIDE will ensure the deletion in case there are no legal reasons obliging FIDE to keep your Personal Information.