Introduction

FLLWco (owned by GiggedIn Pty Ltd ABN: 33 158 416 490) ("FLLWco", "we" or "us") provides software that helps Artists, creators, individuals and businesses (our “Client” or "Clients") run campaigns using the FLLWco Fan Gate (A widget pop up that can be deployed on Client’s websites, “Fan Gate”) to allows Fans (i.e. anyone that visits the FLLWco website or the website of Clients utilising FLLWco’s services including Fan Gates - “Fan” or “Fans”) to easily Follow Clients on Spotify, Follow Clients on Twitch, Subscribe to the Client’s YouTube Channel, and/or provide personal information for the purposes of participating in these campaigns or competitions.

Security & Privacy is an important part of our platform. This Privacy Policy governs the manner in which FLLWco collects, uses, maintains and discloses information collected from Fans or “Fans” of the https://fllw.co website ("Site" or “Website”) and Fan Gate. This privacy policy applies to the Site and all products or services offered by FLLWco.

In order to ensure confidentiality and lawful processing of its, Visitors, Clients and Fans personal data, FLLWco in its capacity of a data controller and of a processor, conducts its activities in strict compliance with the requirements set in the Australia Privacy Act 1988, Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of this data (GDPR) and the California Consumer Privacy Act (CCPA).

This Privacy Policy applies to all Clients, Fans and Visitors of our Site and Services.

What Information We Collect and How We Use It

We may collect the following types of information about you on our Website and/or from a FLLWco Fan Gate.

Clients and Visitors of our Site

We may collect your personal data in a variety of ways, including, but not limited to, when you visit our Site, register on the Site, subscribe to our newsletter, fill out a form, participate in a Client campaign or in connection with other activities, services, features or resources we make available. Registration and Contact Information: As appropriate and depending on the Services you would like to use, Clients and Visitors may be asked to provide us with full name, username, email, address, credit card, phone number or billing information.

Payment Information: When you purchase the Services, we will also collect transaction information, which may include your credit card information, billing and mailing address, and other payment-related information.

Technical, Usage and Location Information: We automatically collect information on how you interact with the Site, such as the IP address from which you access the Site, date and time, information about your browser, operating system and computer or device, pages viewed and items clicked. We may also collect location information, including location information automatically provided by your computer or device. We use cookies and similar technologies to collect some of this information to enable your login to our Site.

Third Party Platforms. We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites, music streaming services, and/or video streaming services. This may include information such as Facebook Likes, friends, profile information gathered from social networking sites, music listening history, who you follow and/or subscribe to, who is following and/or subscribed to you, and the amount of followers and/or subscribers or the fact that you viewed or interacted with our content. Other Information. We may collect other information from you that is not specifically listed here. We may use any such information in accordance with this Privacy Policy or as otherwise permitted by you.

FLLWco Fans

Clients that use FLLWco to run campaigns ("Campaign") may require Fans to supply certain information as part of a Campaign. FLLWco processes this data in accordance with our Privacy Policy.

FLLWco is a consent based marketing platform, this means that in order for us to process data on behalf of Fans they must provide it via explicit consent first. This might be as simple as filling out a form or by connecting their Facebook, YouTube, Twitch or any other social networking site or streaming service to their FLLWco account.

FLLWco does not collect retain or share end user information including IP addresses, unique user identifiers, or personally identifiable information gathered on sites or apps not owned by FLLWco, except for the limited purpose of determining conversion rates & detecting fraud, in which case all personally identifiable information remains anonymous until you explicitly consent by entering a campaign.

FLLWco does not track or provide any personal information to Clients that run Campaigns until you explicitly participate in their campaign. This means that you do not expose any personal information to other clients of FLLWco for which you did not participate in their campaign.

IP Addresses: IP addresses are collected Anonymously for reporting and usage purposes. When you consent to a specific campaign your IP address is linked to the associated record and allows campaign owners to filter records that share an IP address. Your IP address is never shared publicly within the app and always remains hidden.

Name, Email & Form Fields: By default each Campaign may collect basic login information from Fans that includes their full name and email address. By entering campaigns you are accepting that campaign owners i.e. Clients will have access to the information you provide.

Some Campaigns may also require additional custom fields which may include include Date of Birth (for Age Verification) and/or other identifiable fields that the user can choose to fill out and/or free form text for the purposes of campaign giveaways or competitions.

Social and Streaming Logins: FLLWco allows Fans to connect social accounts and streaming services to your profile. Clients that have social logins enabled on their Campaigns will be able to see basic information related to accounts that you connect. This includes but is not limited to your name, email address, social profile URL's, associated profile photos as well as details outlined in the Third Party Platforms section stated earlier.

FLLWco will never use or post to these accounts without your permission and will always require your participation with a Fan Gate to execute any specific actions

FLLWco will only ever use information that you have made public or specifically allowed us to access when you accept permissions

FLLWco does not know or store any passwords associated with your social accounts If you wish to remove the link between FLLWco and any social network or streaming service, you can either remove the FLLWco Competitions app inside that specific social network.

Persistent Logins: FLLWco is a distributed platform, which means that if a Fan has previously logged into our widget they will continue to stay logged in via third party Cookies across other Campaigns owned by other Clients until they specifically log out. This is designed to make it easy for Fans to enter more than one campaign without having to re-enter their details again.

Cookies

Our Site uses both first and third party Cookies to enhance User experience. A User's web browser places a cookie on their hard drive for record-keeping purposes and sometimes to track information about them. Fans may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. If they do so, please note that some parts of the Site and Campaigns may cease to function.

FLLWco Campaigns can use Cookies to track information about Fans in order to serve them content. This includes but is not limited to:

Clients sessions that are logged into FLLWco

Fans sessions that are logged into campaigns (either on FLLWco or widgets via Fan Gates)

Tracking referring Fans

Tracking browser behaviours to show statistics on campaigns such as impressions, clicks and successful Follows and/or Subscribes and/or successful competition or giveaway entries

Device Fingerprinting

Device fingerprinting is a process by which a fingerprint of a device is captured when visiting a website.

FLLWco uses 3rd party services to gather a number of data points from a FLLWco Fans computer, such as operating system version, browser version, screen resolution, plug-ins & language. This unique ID is then transmitted when FLLWco Fans consent by providing their details when entering a campaign.

The information collected via Device Fingerprinting is used to identify patterns of fraudulent behaviour by FLLWco Fans that violate our Terms of Service. This includes trying to cheat by creating multiple accounts, referring your own devices or accounts into a Campaign or attempting to redeem a Reward that is limited to one per person.

FLLWco does not use this information to track or identify Fans on sites or apps not owned by FLLWco or for any other purpose than to detect fraud & protect the integrity of Campaigns.

How We Use Collected Information

FLLWco may collect and use User's personal information for the following purposes:

FLLWco Clients

To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

To write or display content such as case studies or customer testimonials on our Site;

To improve FLLWco to ensure that content is presented in the most effective manner for you and for your Device;

To allow you to participate in interactive features of our service, when you choose to do so;

To send periodic emails: We may use the email address to send User information and updates pertaining to their subscription. It may also be used to respond to their inquiries, questions, and/or other requests.

FLLWco Fans

FLLWco does not own or use any identifiable data provided by Fans for any reason other than to:

Ensure that your specific request is carried out and assigned to the correct campaign that you provided consent for by participating

Identify and detect fraudulent behaviour or Fans that are violating our Terms of Service

Provide support to Clients regarding specific Campaign User queries

Analyze anonymized statistics or usage to help improve the FLLWco platform and services

Sharing Information With Third Parties

We do not access, sell, trade, or rent any Fans personal identification information to others. Once you provide access to specific data it belongs to the Client running that specific Campaign and only that Client. Please review the Terms & Conditions and Privacy Policy of the Campaign Owner to understand how they may use your data once it leaves FLLWco.

Clients and Visitors of our Site

FLLWco may use third party service providers to help us operate our business or administer activities on our behalf, such as sending out newsletters or collecting Website analytics. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

FLLWco engages certain onward subprocessors that may process personal data submitted to FLLWco's services. Some of these subprocessors are listed below, and may be updated by FLLWco at any time:

Amazon Web Services

Google Analytics

Mixpanel

Groove HQ

Mailgun

Stripe

Third Party Websites

Fans may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.

Legal Disclosures

In certain limited circumstances, we may also have to disclose your personal data to public authorities and other third parties, if the disclosure is in response to lawful requests made by such public authorities, including to conform with national security or law enforcement requirements. Your personal information may also be disclosed to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

FLLWco may also share personal data with third parties to prevent, investigate or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the Services, or as otherwise required by law.

Information Security

We use appropriate technical and organizational security measures to protect any personal information we process about visitors to our Website against unauthorized access, disclosure, alteration, and destruction. However, please note that no Internet transmission can ever be guaranteed 100% secure, and so we encourage you to take care when disclosing personal information online and to use readily available tools, such as Internet firewalls, secure e-mail and similar technologies to protect yourself online.

Sensitive and private data exchange between the Site and its Fans happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

FLLWco uses Stripe to process credit card payments and no credit card details are stored on our servers. Stripe has been audited by a PCI-certified auditor, and is certified to PCI Service Provider Level 1. This is the most stringent level of certification available.

In case of an unauthorized security intrusion that materially affects you or data related to any campaigns, FLLWco will notify you as soon as possible and will within reasonable time report the action we took in response.

EU and EEA residents

The servers where FLLWco stores all personal data are located in the US. If you are located in a country member of either the EU or the EEA, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield and the Swiss-US Privacy Shield, we may ask for your express consent to provide such data to us or allow us to collect such data.

International Transfer of Personal Data

All personal data we process is stored directly, without any subsequent transfers, on US-based servers, which we loan from a third-party datacenter that is certified and adheres to the EU – U.S Privacy Shield Framework.

o additionally guarantee to our Clients and their European Fans (data subjects) the legality of our processing services and the international transfers of the personal data, FLLWco is undertaking GDPR compliant contractual commitments, binding us, as a data processor, to protect the data privacy and to ensure the most adequate level of data security.

Please note that the country where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create an account with us and are bound by FLLWco's Terms of Service & Privacy Policy policy to data transfers, irrespective of which country you live in. If you later wish to withdraw your consent, you can request to have your FLLWco account deleted.

Data Retention Periods

FLLWco will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Campaign data, FLLWco’s Clients have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. When a User’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.

If a Customer or User account has been suspended for a Terms of Service violation, FLLWco will retain the infor