Fair Custodian Privacy Policy
Privacy is at the core of everything we do at Fair Custodian. We fully assess every decision we make in terms of how it will affect your privacy and we will always support a data minimalisation approach.
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Fair Custodian Privacy Policy

Effective date: November 09, 2018

Last update: September 19th, 2019

Fair Custodian Ltd ("us", "we", or "our") operates the https://faircustodian.com website (hereinafter referred to as the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. Our Privacy Policy for Fair Custodian Ltd is managed with the help of Privacy Policies.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you. We hold this data for as long as you have an account. Upon requesting deletion, your data will be deleted within 30 days. If you are inactive for 12 months, we will delete all data associated with you after notifying you of our intention.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address
  • Cookies and Usage Data
  • Email content & metadata

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. You can learn more how to manage cookies in the Browser Cookies Guide.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

Fair Custodian Ltd uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Fair Custodian Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Your Rights

You have the right to find out about what information we hold about you. You can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days.

To make a request for information please contact us here and a member of our team will be in touch.

If your personal data is incorrect then you have the right to rectify this information and ensure that it is accurate and up to date. If your data is incorrect then please contact us at the email address above and a member of the team will rectify this on your behalf.

You have the right ‘to be forgotten’ and to have your personal identifiable information permanently deleted from our systems. Again, if you would like to exercise this right then please contact us at here.

There will be no charge made for reasonable electronic access to your information, your right to rectification or for your right to be forgotten from our systems.

Data Retention

At Fair Custodian we have procedures in place to regularly review every 12 months what personal data we hold.

If you have not interacted with us or accessed our services during this or the subsequent period then we will delete your personal data from our systems, but will send you an email first informing you of our intention to do so.

Of course, you have the right to forgotten at any point and can find out more about this in the ‘Your Rights’ section above.

Disclosure Of Data

Legal Requirements

Fair Custodian Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Fair Custodian Ltd
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Privacy Badger. It is a free browser extension provided by the Electronic Frontier Foundation (EFF) which learns to block invisible trackers on websites. It is available for Chrome, Firefox and Opera browser. Alternatively there is Google's own opt-out extension.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Matomo

Matomo is a web analytics platform. We host our own installation of it which means the data we collect with it is not shared with 3rd parties and, most of all, ensures user privacy protection. Our Matomo configuration respects all “Do Not Track” requests, which is the recommended way to opt-out of Matomo tracking (and many other tracking elements across the web). Matomo stores anonymised IP addresses, country, operating system, web browser and screen size along with the pages visited.

HaveIbeenpwnd

When checking for breach updates, we share your email address to haveIbeenpwnd.com. This allows us to inform you if your email address has been included in a breach. The email is processed by HaveIbeenpwnd.com but the email address is not stored to retained.

For more information on the privacy practices about HaveIBeenPwned, please see their privacy policy.

Websand

Websand is an email marketing platform that we use to send email marketing to you. Websand acts as our data processor, and is used to help us understand how people respond to the email marketing messages we send. You can opt-out of the email marketing messages at anytime by clicking on the unsubscribe link an email you’ve received or by contacting us at here.

For more information on Websand and to review the Websand privacy policy in full, please visit Websand's privacy policy.

AWS

We hold our data with Amazon Web Services (AWS) who are contracted by us for the provision of technical services. We remain responsible at all times for the security of your information.

If you want to know more about how we interact with AWS you can view their Privacy Notice, amongst their other policies here.

Sendgrid

We use Sendgrid to process the email we receive, this helps us to manage the processing of inbound email messages as well as send you service messages.

You can view more information about SendGrid and their policies here.

Authy

If you decide to turn on two-factor authentication for your account, this process is handled by Authy. The mobile phone number you provide is transferred and stored by Authy, not by us.

You can view more information about Authy and their policies here.

Stripe

We use Stripe to handle payments. Any card details you provide as part of a purchase are held and processed by Stripe. You can view more information about Stripe and their policies here.

Gmail

Notwithstanding anything else in this Privacy Policy, if you provide the App access to the following types of your Google data, the App's use of that data will be subject to these additional restrictions:

  • The App will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
  • The App will not use this Gmail data for serving advertisements.
  • The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App's internal operations and even then only when the data have been aggregated and anonymized.

You can read more about Gmail's privacy policy here.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions or complaints about this Privacy Policy, please contact us by email: privacy@faircustodian.com.