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Privacy & Safety

1. Please read carefully

3Group Feste cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how 3Group Feste Ltd., together with its affiliated companies worldwide (“3Group Feste”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all 3Group Feste users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all 3Group Feste services, including our websites (including www.3groupfeste.com and any of its subdomains, the “Website”), web applications (“3Group Feste Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us here.

2. What ‘Personal Information’ do we collect?

2.1. User information:


To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources.

 

Here are the types of Personal Information we collect about you:

Information you provide us. When you register for our Services, sign up for any 3Group Feste events, subscribe to our blog(s) or newsletter(s), purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., 3Group Feste’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).

Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.

Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers, fraud detection and prevention providers, for example, to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information), and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

2.2. Users of users ‘Personal Information’


We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section ‎6 below).

3. Why do we collect such ‘Personal Information’

We use your Personal Information for the following purposes:

- To provide and operate the Services;
- To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences, and difficulties;
- To provide our Users with ongoing customer assistance and technical support;
- To contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);
- To update, expand, and analyze our records to identify new customers;
- To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
- To analyze our performance and marketing activities;
- To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
- To provide you with professional assistance;
- To enhance our data security and fraud prevention capabilities; and
- To comply with any applicable laws and regulations.

We may use techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (i) still have a human being involved in the process (and so are not fully automated); or (ii) use machine learning in ways that don’t have significant privacy implications (for example, reordering how applications might appear when you visit the 3Group Feste App Market). We may also use machine learning to help us monitor, identify, and suspend accounts sending spam, or engaging in other abusive or fraudulent activity.

We use your Personal Information for the purposes set out in Section 3 where:

- Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g., to provide you with a website builder, to provide you with our customer assistance and technical support);
- Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
- Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of 3Group Feste by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.

4. How we share your ‘Personal Information’

We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:

4.1. Third Party Service Providers:


3Group Feste has partnered with a number of selected service providers, whose services and solutions complement, facilitate, and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization, and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).

3Group Feste may share the following categories of Personal Information with Third Party Service Providers for a business purpose:

- Identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
- Commercial Personal Information, for example, Personal Information regarding products or services purchased, obtained, or considered.


4.2. Law Enforcement, Legal Requests and Duties:


3Group Feste may disclose or otherwise allow access to any categories of your Personal Information described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant, or court order, or in compliance with applicable laws if we have a good faith belief that the law requires us to do so, with or without notice to you.

4.3. Protecting Rights and Safety:


3Group Feste may share any categories of your Personal Information described in this Privacy Policy if we believe in good faith that this will help protect the rights, property, or personal safety of 3Group Feste, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.

4.4. 3Group Feste Subsidiaries and Affiliated Companies:


We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with 3Group Feste Inc., our US-based subsidiary, in the course of facilitating and providing you (and your Users-of-Users) with our Services. Sharing Personal Information by 3Group Feste subsidiaries and affiliated companies in the European Union, the United Kingdom, and Switzerland with 3Group Feste’s subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses.

4.5. In connection with a change in corporate control:


In addition, should 3Group Feste or any of its affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.

4.6. Upon Your Further Direction:


The 3Group Feste Services enable you, through different techniques, to engage and procure various third party services, products, and tools for enhancing your web or mobile sites, including, without limitation, applications and widgets offered to you by third parties through the 3Group Feste Website (including the 3Group Feste App Market), eCommerce payment providers, third party designers who may assist you with your website, etc. (collectively, “Third Party Services”). If you choose to engage with such Third Party Services, they may have access to and process Personal Information of your Users-of-Users collected through your web or mobile sites.

Please note that in the examples listed above in this Section 4.7, 3Group Feste merely acts as an intermediary platform allowing you to procure the services of such Third Party Services (including, but not limited to, Third Party Developers, Third Party Apps, and Social Media Features) with which you are interacting directly, and at your discretion. In this respect, 3Group Feste acts as a service provider to you, disclosing information to the Third Party Services on your behalf. 3Group Feste will share your Users-of-Users’ Personal Information with Third Parties Services only upon your direction or with your permission and is not, and shall not be, in any way responsible for such Third Party Services processing of such Personal Information, or liable with respect thereto.

3Group Feste does not control and is not responsible for the actions or policies of any Third Party Service, and your use of any Third Party Service is at your own risk. We encourage you to review any privacy policy accompanying a Third Party Service and ask such Third Party Service for any clarifications you may need before deciding to install and/or use their services.

5. Where do we Store/Process your ‘Personal Information’?

3Group Feste processes data about individuals across the world and may transfer your Personal Information outside of your country. Your security, privacy, and confidentiality are our top priority, and that's why 3Group Feste conducts a vetting process that includes an assessment of the privacy laws in those countries to validate they have strong data protection laws.

5.1.

User's personal information is controlled by 3Group Feste in Israel, which the European Commission considers as a country offering an adequate level of protection for the Personal Information of E.U. Member State residents.

5.2.

If you are in Europe, the U.K., or Switzerland, when we transfer your Personal Information to a location outside of Europe, we will make sure that:

- There is a level of protection deemed adequate by the European Commission, or
- The relevant Standard Contractual Clauses are in place (i.e., the applicable module of the Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (E.U.) 2016/679 of the European Parliament and of the Council from June 4, 2021, as available here, and the ICO’s International Data Transfer Addendum to the E.U. Commission Standard Contractual Clauses version B1.0, in force from 21 March 2022, as it is revised under Section ‎‎18 of its Mandatory Clauses), or
- We comply with Data Privacy Framework as applicable to data transfers to the United States and specified in clause 5.4 below, or
- We use another legally recognized transfer mechanism in the applicable jurisdiction.

5.4 Data Privacy Framework:


3Group Feste and its covered entities DeviantArt, Inc., InkFrog, Inc, Modalyst, Inc, and SpeedTab, Inc, comply with Data Privacy Framework (“DPF”) that embeds the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce, European Commission, UK Government, and Swiss Federal Administration regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland to the United States. 3Group Feste has certified to the U.S. International Trade Administration (ITA), within the U.S. Department of Commerce that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. 3Group Feste’s commitment to subject the personal information described in this Policy to the Data Privacy Framework is subject to the enforcement and investigative powers of the United States Federal Trade Commission.

To learn more about the Data Privacy Framework Program visit [https://www.dataprivacyframework.gov](https://www.dataprivacyframework.gov), and to view our certification, please click (https://www.example.com).

3Group Feste may share personal information with third parties under certain circumstances described in this Policy, subject to obligations under the Data Privacy Framework Principles extend to third parties acting as agents who help us run our business and provide services, and 3Group Feste remains liable should a third party acting as our agent process personal information subject to this Policy in a manner inconsistent with this Policy, except where 3Group Feste is not responsible for the event giving rise to the damage.

3Group Feste commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

3Group Feste has further committed to refer unresolved  Data Privacy Framework complaints to an alternative dispute resolution provider located in the United States. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider TRUSTe at [https://feedback-form.truste.com/watchdog/request](https://feedback-form.truste.com/watchdog/request) for more information or to file a complaint.  The services are provided at no cost to you.

If you have such an unresolved complaint, under the recourse mechanism you may contact the applicable  EU Data Protection Authorities (free of charge). 3Group Feste commits to cooperate with the DPAs and comply with the advice given by such authorities.

If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may - under certain conditions described on the Data Privacy Framework website - invoke binding arbitration when other dispute resolution procedures have been exhausted. For more information on this option, please see Annex I of the Data Privacy Framework Principles.

 

6. Users-of-users’ ‘Personal Information’

3Group Feste may collect, store, and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their email contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with 3Group Feste, on the User’s behalf.

For such purposes, 3Group Feste serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.

The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.

The Processing of the Users-of-users’ Personal Information shall take place within the territory of the European Union, Israel, or a third country, territory, or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection, and such processing and transfer will be in accordance with the Data Processing Addendum – Users (“DPA"). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission shall be conducted under an approved transfer mechanism, as detailed in the DPA.

You are responsible for the security, integrity, and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions, and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.

3Group Feste cannot provide legal advice to Users or their Users-of-Users, however, we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.

For more information on how Users-of-Users Personal Information may be handled by 3Group Feste (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12, and 13.

If you are a visitor, user, or customer of any of our Users, please read the following: 3Group Feste has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user, or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by 3Group Feste on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If 3Group Feste is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.

3Group Feste may collect and process Personal Information regarding the users of our users.

We do this solely on our users’ behalf and at their direction.

Our users are solely responsible for their users-of-users' information, including for its legality, security, and integrity.

3Group Feste has no direct relationship with any of its users’ users. If you are a user-of-user, please contact the 3Group Feste site owner directly.

7. Use of cookies and other third-party technologies

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.

You can learn more about how we use cookies and similar technologies and how you can exercise control over them in our Cookie Policy.

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application; however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

8. Communications from 3Group Feste

8.1. Promotional messages

3Group Feste may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls, and similar forms of communication from 3Group Feste or our partners (acting on 3Group Feste’s behalf) through such means.

If you do not wish to receive such promotional messages or calls, you may notify 3Group Feste at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

8.2. Service and billing messages

3Group Feste may also contact you with important information regarding our Services or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.

It is important that you are always able to receive such messages. For this reason, you are unable to opt-out of receiving such Service and Billing Messages unless you are no longer a 3Group Feste User (which can be done by deactivating your account).

9. Your rights in relation to your ‘Personal Information’

3Group Feste believes that it is imperative that all 3Group Feste users have control over their Personal Information. Therefore, depending on the way you use the 3Group Feste Services, you may have the right to request access to, receive a copy of, update, amend or delete, port certain Personal Information to another service, restrict, or object to certain uses of your Personal Information (for example, for direct marketing purposes). Further, when we rely on your consent for processing of your Personal Information (for instance, for direct marketing), you can withdraw your consent at any time, and such withdrawal will take effect from thereon.

3Group Feste will not charge you more if you exercise any of these rights and will continue to provide you with the same level of service.

If you are a 3Group Feste user, you can access and correct a lot of your Personal Information directly through your account, or via online forms 3Group Feste makes available to you (as detailed below). 

Before fulfilling your request, we may ask you for additional information to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

If you are a 3Group Feste User and you wish to receive a copy, access, and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please follow the instructions provided in these Help Center articles: “Retrieving Your 3Group Feste Account Data” or "Permanently Deleting Your 3Group Feste Account.” We will make reasonable efforts to honor your request promptly (unless we require further information from you to fulfill your request), subject to legal and other permissible considerations.

Please note that permanently deleting your 3Group Feste account erases all of your Personal Information from 3Group Feste's databases. After completing this process, you can no longer use any of your 3Group Feste Services, your account and all its data will be removed permanently, and 3Group Feste will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account, and support agents will not be able to locate the deleted account.

10. Questions and complaints

If you have any questions or concerns about our collection, use, or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.

Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.

You can file a complaint with your local supervisory authority for data protection at any time; however, we recommend that you contact us first so we can try to resolve it.

11. Data retention

We may retain your Personal Information (as well as your Users-of-Users’ Personal Information) for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.

We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements, and/or protect our legitimate interests.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements.

12. Security

3Group Feste has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic, and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry-standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

Regardless of the measures and efforts taken by 3Group Feste, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information, or any other information you upload, publish, or otherwise share with 3Group Feste or anyone else. We encourage you to set strong passwords for your User Account and User Website and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.

Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private” or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.

13. Third-party websites

Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third-party websites and services.

15. Public forums and user content

Our Services offer publicly accessible blogs, communities, and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities, or forums, feel free to contact us here. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third-party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must log in to such application or contact its provider if you want to remove the Personal Information you posted on that platform.

In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.

If you upload any user content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.

We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.

16. Updates and interpretation

We may update this Privacy Policy as required by applicable law and to reflect changes to our Personal Information collection, usage, and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you (using one of the notification methods set forth in Section 15.3 of the Terms of Use) prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent, and/or take any other measures. We encourage you to periodically review this page for the latest information on our privacy practices. Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you and your Users-of-Users, with respect to our Website, 3Group Feste Apps, Mobile Apps, and other Services.

Any heading, caption, or section title contained herein, and any explanation or summary under the right “#ItsThatEasy” column, is provided only for convenience and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.

This Privacy Policy was written in English and may be translated into other languages for your convenience. You may access and view other language versions by changing your 3Group Feste Website language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.

17. Contacting us

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Sections 9 or 10 please refer to those sections or contact the Data Protection Officer team here. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.

You may also contact us by mail at:

italiasefesta@gmail.com

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