Data Processing Terms
Draft — not yet reviewed by a lawyer
These terms apply if you have a Fambero page. They cover the personal data of your fans, which you control and we process on your behalf.
Why this exists
When somebody becomes a fan of your page, you can see their name and email address. Under data protection law that makes you the controller of that data and Fambero your processor. That relationship has to be written down. This is that document, and you accept it when you create a page.
What we process, and why
| Subject matter | Fan relationships on your page |
|---|---|
| Duration | While you have a page, plus the deletion grace period |
| Purpose | Showing you your fans, and delivering what you send them through Fambero |
| Data | Name, email address, the date they became a fan, and how they arrived |
| People | Fans of your page |
What we undertake
- Process fan data only on your instructions, and to run the service
- Keep it confidential, and bind our staff to the same
- Apply appropriate technical and organisational security measures
- Use sub-processors only under equivalent terms, and tell you before adding one
- Help you answer requests from your fans about their data
- Tell you without undue delay if there is a breach affecting your fans
- Delete or return the data when you close your page
- Give you what you need to demonstrate we are doing this
What you undertake
- Have a lawful basis for contacting your fans, and stay within what they signed up for
- Not sell, rent or pass on their details
- Not add them to unrelated lists, on Fambero or anywhere else
- Answer their requests about their data, with our help
- Keep your own account secure
Your fans agreed to follow you. The clearest test of whether a use is acceptable is whether they would recognise it as the thing they signed up for.
Where the data is
Fambero runs in the European Union. Where a sub-processor operates outside the EU, we rely on an adequacy decision or standard contractual clauses.
Sub-processors
Our hosting, email and payment providers. The current list is available on request from [email protected].