Privacy Policy

[email protected]

1. The Introduction.

1.1 This Privacy Policy (hereinafter the “Policy”) governs the terms and conditions of the processing of your personal data (hereinafter shall also be referred to as the “data” ) when you visit or use https://fbpilot.online/ (hereinafter the “Website”). In this Policy you can find the information about the following:

What data are collected from you when you use the Website and the Services;
The purposes and legal bases for the processing of your data;
The period for which your data will be stored;
The recipients of your data;
Your rights under applicable data protection legislation;
Contact details of the supervisory authorities to which you can address your complaints with regard to the processing of your data;
Other information with regard to the processing of your data.

2. Contact information.

2.1 In case of any questions/requests/issues in respect of this Policy, you can address them to e-mail address [email protected]

3. What data we collect.

3.1 Automatically collected data (hereinafter the “automatically collected data”). When you use the Website, the following data are collected from you by automated means:

3.1.1. By Google Services. When you use the Website, the following data are collected from you by Google Services:

The data collected by Google Analytics:
- The total time you spend on the Website;
- The time you spend on each page and in what order those pages were visited;
- What internal links were clicked (based on the URL of the next pageview);
- Your IP address and user agent string;
- Initial page inspection that analytics.js performs when creating a new tracker object is used to determine your geographic location, what browser and operating system are being used, your devices screen size, whether flash or java is installed, and the referring site. The information collected by Google Analytics is generated to Googles server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on follow this link: https://tools.google.com/dlpage/gaoptout?hl=en.
The data collected by Google reCAPTCHA. In case of Google reCAPTCHA, Google collects the data about your input in order to distinguish whether an input is made by a human or by a robot or with the use of any other form of automated means.
The data collected by Google Tag Manager. Google Tag Manager is a tool made by Google that allows us to integrate and manage tags (snippets of code) into the Website. Google Tag Manager collects the following data:
- Aggregated data about tag firing.

If you want to find out more about how Google processes your data, please, follow Googles Privacy Policy https://policies.google.com/privacy.

3.1.2 By Cloudflare. We use the Services provided by Cloudflare. These Services collect the following data:

Your IP address;
System configuration information;
Other information about traffic to and from the Website. If you want to find out more about how Cloudflare processes your data, please, follow Cloudflares Privacy Policy https://www.cloudflare.com/privacypolicy/.

3.2 Account data (hereinafter the “account data”). When you create and use the Account on the Website, you provide us with the following data:

When you create the Account:
- Your username;
- Your e-mail address;
- Your password (which will be stored in hashed form);
- If you have chosen to sign up with the use of social media account, we collect the data about your social media account.
When you use the Account:
- Information about Facebook accounts submitted by you;
- Information about posts which you publish via the Services.
The status of your Subscription:
- The information about your Subscription plan;
The information voluntarily provided by you. You may voluntarily submit in the Account the following data:
- Your first and last name.

3.3 The information about your payments (hereinafter the “payment data”). When you make payments for the Services (for example, when buying the Subscription) you provide us with the following data:

The information about your payments.

3.4 Contact data (hereinafter the “contact data”). When you contact us via the interface of the Website or via available contact details, you hereby provide us with the following data:

You e-mail address;
Your name;
The subject of your message;
Your message(s) including all the personal data contained in it/them.

3.5 Your consent to receive the Company`s newsletter. We collect data on whether have you consented to receive the newsletter from the Company. You will always have a possibility to unsubscribe from the newsletter (withdraw your consent) either by sending a request to the Company or by clicking a proper tab on the interface of the newsletter message.

4. For what purposes and under what legal bases we collect your data?

4.1. Administer and protect the Website. We use automatically collected data for the following purposes and under the following legal basis:

4.1.1. Purposes:

To protect the Website from cyberattacks, DDoS attacks, and other possible threats;
To protect the Website from any illegal, unlawful activity, fraud, and abuse;
To provide you with the Website tailored for your device, language, and opted preferences;
To diagnose any problems with the Website and the Server which makes the Website available;
To load balance to the Server which makes the Website available.

4.1.2. Legal basis:

Article 6(1)(f) of the GDPR: the processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. The abovementioned purposes are the legitimate interests of the Company.

4.2 Research and analysis. We use your automatically collected data, account data, and contact data for the following purposes and under the following legal basis:

4.2.1. Purposes:

To create statistics to improve the quality of the Website;
To research and analyse how the Website is used by its audience;
To test new features on the Website.

4.2.2. Legal basis:

Article 6(1)(f) of the GDPR: the processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. The abovementioned purposes are the legitimate interests of the Company.

4.3. To create your Account and provide you with the Companys Services. We use your account data for the following purposes and under the following legal basis:

4.3.1. Purposes:

To create your Account on the Website and provide you with the trial period to test our Services;
If you pay for the Subscription: to provide you with the Companys Services.

4.3.2. Legal basis:

Article 6(1)(b) of the GDPR: the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. Without your account data, the Company would not be able to exercise a contract with you.

4.4. To process your payments for the Companys Services. We use your payment data for the following purposes and under the following legal basis:

4.4.1 Purposes:

To process your payments for the Companys Services.

4.4.2 Legal basis:

Article 6(1)(b) of the GDPR: the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. Without your payment data, the Company would not be able to process your payments.

4.5 To contact you. We may use your contact data to contact you or answer your questions, messages, or inquires.

4.5.1. Legal bases:

4.5.1.1 If we communicate with you in respect of provision to you the Services:

Article 6(1)(b) of the GDPR – the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

4.5.1.2 If you ask general questions about the Company, Website, or our Services:

Article 6(1)(f) of the GDPR: the processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. Communication with those individuals who voluntarily communicate with the Company is the legitimate interest of the Company.

4.5.1.3 If you communicate with us in order to exercise your data subjects right(s) or your request contains another legal issue:

Article 6(1)(с) of the GDPR: the processing is necessary for compliance with a legal obligation to which the Company is subject.

4.6 To send you the Company`s newsletter.

4.6.1 Legal basis:

Article 6(1)(a) of the GDPR: your consent to the processing of your data for this purpose.

4.7 To comply with applicable law. The Company may use your data for compliance with applicable legislation.

4.7.1 Legal basis:

Article 6(1)(с) of the GDPR: the processing is necessary for compliance with a legal obligation to which the Company is subject.

4.8 To establish, exercise and defence of legal claims. We may store your data for an additional time period until the expiry of the period of limitation.

4.8.1 Legal basis:

Article 6(1)(f) of the GDPR: the processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. The establishment, exercise and defence of legal claims are the legitimate interests of the Company.

5. The period for which your data will be stored.

5.1 For automatically collected data:

5.1.1 Of the individuals who do not have an Account on the Website: up to 26 (twenty-six) months starting from the date of your last visit to the Website;

5.1.2 Of the individuals who have an Account on the Website: as long as you have an Account on the Website and for an additional six years starting from the date of the erasure of your Account as allowed by Article 7(1) of Limitation of Legal Proceedings act (law(I)2012) of the Republic of Cyprus.

5.2. For account data and payment data: as long as you have the Account on the Website and for an additional six years starting from the date of the erasure of your Account as allowed by Article 7(1) of Limitation of Legal Proceedings act (law(I)2012) of the Republic of Cyprus.

5.3. For contact data:

5.3.1. Of the individuals who do not have an Account on the Website: as long as required by the purpose of the communication;

5.3.2. Of the individuals who have an Account on the Website: as long as you have an Account on the Website and for an additional six years starting from the date of the erasure of your Account as allowed by Article 7(1) of Limitation of Legal Proceedings act (law(I)2012) of the Republic of Cyprus.

5.4. For your consent to receive the Companys newsletter: unless you revoke your consent to receive the Companys newsletter.

6. Recipients of your data.

6.1 Our employees, affiliates, contractors, and sub-contractors. The Website and the Services are maintained and operated by a large staff. Thus, your data may be disclosed to this category of recipients. All these transfers are secured by proper contractual arrangements which oblige these recipients to process your data in strict compliance with this Policy and within the terms of confidentiality and professional secrecy regime.

6.2 The hosting provider that owns the server which makes the Website available. The Website and the Services are placed on the server which is operated by the third party. From this follows, that your data will be shared to this hosting provider in encrypted form: which means that only authorized employees of the Company will have access to your data; because only they possess decryption keys.

6.3 Public authorities of our jurisdiction. In case of a legal obligation to disclose your data to public authorities of our jurisdiction (the term “public authorities” may include, without limitation, court, police, financial investigation unit), the Company will perform this disclosure.

6.4 Payment services providers, financial institutions, banks. When making payments for our Servies, your transaction will be processed by third-party payment services provider, bank, or financial institution. Thus, your data will be shared with them.

6.5 Google and Cloudflare. As mentioned above, the Company uses the services provided by Google LLC, Amphitheatre Parkway, Mountain View, CA 94043, USA and Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA.

7. Transfer of the data from EU to the U.S. under EU-U.S. Privacy Shield Framework.

7.1 Google LLC. and Cloudflare, Inc. are certified under EU-U.S. Privacy Shield Framework. The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce and the European Commission and Swiss Administration to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce. For more information on the Privacy Shields, please visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov/welcome.

8. Your rights.

8.1 In accordance with the GDPR, you have a number of rights which you can exercise either by contacting us via e-mail address [email protected] or by sending a request to our registered address. We will exercise your request within 1 (one) month starting from the date of your request (or, in case of the delay, you will be informed about the reason for this delay).

8.2. Please note that:

Your rights can be restricted by applicable law. In this case, you will be notified about the legal basis for the restriction.
We may request additional proof of your identity prior to the implementation of any right specified herein.

8.3. Your rights are the following:

8.3.1. The right to withdraw consent. If you have given consent to the processing of your personal data in accordance with Article 6(1)(a) of the GDPR, you have the right to withdraw this consent at any time. Please note that the withdrawal of consent shall not affect the lawfulness of the processing based on consent before its withdrawal.

8.3.2. The right of access. You have the right to obtain from us the confirmation as to whether or not your personal data are being processed by us. In a plain language, you have the right to ask us whether we process your personal data. In case if we indeed process your personal data, you also have the right to receive a copy of your personal data processed by the Company.

8.3.3. The right to rectification. You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. In a plain language, you have the right to have inaccurate or no longer relevant data concerning you corrected. If your personal data are incomplete, you have the right to have these data completed by providing a supplementary statement.

8.3.4. The right to erasure (“the right to be forgotten”). You have the right to have your personal data deleted in case where one of the following applies:

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
you have withdrawn your consent to the processing of your personal data;
you have objected the processing in accordance with your right to object to the processing and there are no overriding legitimate grounds for the processing or you object to the processing of your personal data for direct marketing purposes;
your personal data have been processed unlawfully;
your personal data must be erased in accordance with a legal obligation to which the Company is subject.

Please note that the right to erasure is not applicable in the following circumstances:

your personal data must be retained by the Company in accordance with a legal obligation to which the Company is subject;
we retain your personal data for the purposes of the establishment, exercise or defence of legal claims;
in other cases when applicable legislation provides.

8.3.5. The right to object to the processing. You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data if this the processing is based on the following legal basis: Article 6(1)(f) of the GDPR (the processing which is necessary for the purposes of the legitimate interests pursued by the Company or by a third party). The Company shall no longer process your personal data unless i) the Company demonstrates compelling legitimate grounds for the processing of your personal data which override your interests, rights and freedoms; or ii) the processing is necessary for the establishment, exercise or defence of legal claims. If your personal data are processed for direct marketing purposes, you have the right to object, at any time, to the processing of your personal data for such purposes.

8.3.6. The right to the restriction of the processing. You have the right to the restriction of the processing. This means that your personal data will be temporally moved to another processing system (in a plain language, they will be “frozen” for a period of the restriction). The right to the restriction of the processing applies in the following cases:

accuracy of the personal data is contested by you. In this case, the restriction will be applied for a period enabling us to verify the accuracy of your personal data;
the processing is unlawful and you oppose the erasure (in accordance with your right to erasure) of your personal data and request the restriction of the processing instead;
we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
you object to the processing in accordance with your right to object to the processing pending the verification whether our legitimate grounds override those of you.

8.3.7. The right to data portability. You have the right to receive your personal data, which was provided by you to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller (another company, organisation etc.). This right applies to your personal data which:

were collected under the contract in accordance with Article 6(1)(b) of the GDPR or in accordance with your consent under Article 6(1)(a) of the GDPR;
were collected using automated means of the processing.

9. The right to lodge a complaint with the supervisory authority.

9.1 You can always contact us for any issue with regard to the processing of your personal data, including complaints.

10. Third-party Websites.

10.1 The Website may contain links to the websites, services or resources which are owned and operated by third parties (hereinafter “external resources”). You follow these links/hyperlinks to the external resources at your own risk. We bear no liability for the content of any external resources and bear no responsibility for anything that can happen as a result of your visit to external resources. We recommend you to visit “Privacy Policy” or “Data Policy” or another privacy document on any of these external resources before submitting any personal data to the latter.

11. Changes to this Policy.

11.1 We may change, amend, or correct this Policy for various reasons. In case of any changes, amendments, or corrections we will post the revised Policy on the Website and notify you about the changes by e-mail notification (if we have your contact data). You continued use of the Website shall be considered as a fact that you have read and understood the revised Policy.

12. Cookie Policy.

12.1 The Website uses cookies. A cookie is a small file which the Website places on your electronic device whenever you visit and use the Website. Here you can find the list of cookies used by the Website and the reasons for their use.

12.2. Cookies which are used by the Website.

12.2.1. Security and essential cookies. Security cookies are used in order to protect the Website from fraud, abuse, and cyberattacks; essential cookies are essential for the functioning of the Website: without these cookies the Website will not work. These cookies cannot be disabled by the Website`s interface and are always on.

Name of the cookie	Type	Expiration time	Purpose of use
__cfduid	Security cookie	1 month	This cookie is a security feature deployed by us in order to protect this Website. The __cfduid cookie does not allow cross-site tracking. It also does not allow visitors to follow from website to website by merging various __cfduid identifiers into a profile. Rather, __cfduid cookie is placed on the visitor’s web browser after the visitor has met certain security requirements. The __cfduid is a one-way hash of certain values and cannot be used to personally identify the individual.
XSRF-TOKEN	Security cookie	Session	The XSRF-TOKEN provides protection from Cross-site request forgery (CSRF) attacks. This cookie is session related and is deleted when the browser is closed.
cookies_settings	Essential cookie	1 month	This cookie remembers your cookie preferences on the Website.
fb_poster_session	Essential cookie	2 month	This cookie allows you to log-in and use the webpage https://fbpilot.online/. If this cookie is disabled, this webpage will not be available.

12.2.2. Analytics cookies are used to distinguish you from other visitors of the Website. We use this information to create statistics to improve the quality of our Website. You can always disable these cookies via our cookie consent tool.

Name of the cookie	Type	Expiration time	Purpose of use
__ga	Analytics cookies	2 years	These Google Analytics cookies are used to collect information about how visitors use the Website. We use this information in order to improve and enhance our Website.
_gid	2 hours
_gat_gtag_UA_143857234_1	1 minute
_gat	1 minute