Privacy Policy

Important information and who we are

Purpose of this privacy policy

This Privacy Policy describes the policies and procedures of FillyX Ltd. (“we”, “our” or “us”) on the collection, use, and disclosure of your information on https://fillyx.com (the “Site”) and the services, features, content or applications we offer (collectively with the Site, the “Services”). We receive information about you from various sources, including: (i) your use of the Services generally; and (ii) from third party websites and services.

This Privacy Policy covers the treatment of personally identifiable information (“Personal Data”) that is gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Data that our business partners share with us or that we share with our business partners.

When you use any of the Services, you are expressly consenting to the collection, transfer, application, manipulation, storage, disclosure, and other uses of your information as described in this Privacy Policy.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Controller

FillyX Ltd. is the controller and responsible for your Personal Data (collectively referred as “Diamond”, “we”, “our” or “us”). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:
FillyX Ltd.
Email address: userdataprivacy@fillyX.com
Postal address: Islamabad, Pakistan

Changes to the privacy policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted. It is important that the Personal Data we hold about you is accurate and current to provide you appropriate notices and the best service. Please keep us informed if your Personal Data changes during your relationship with us.

Third-party links

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third party websites, services, and applications (“Third Party Services”) that you access through the Service, or to individuals that we do not manage, control, or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What information do we collect?

In connection with certain aspects of the Services, we may request, collect, and display some of your Personal Data. Personal Data is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e., anonymous data). We collect the following types of information from our users.

Personal data

You can browse the Site without telling us who you are or revealing any Personal Data. If you do not provide Personal Data when requested, we may not be able to provide you with your requested Services.

When you use the Services, you may choose to register for an account and provide Personal Data, such as your name and email address (“Identity Data”). You acknowledge that this information may be personal to you, and you allow others, including us, to identify you and therefore your information may not be anonymous.

If you opt in to be eligible to win an award or receive a payment for any giveaway, contest, or task, we are required to collect additional Personal Data from you, such as your name, address, government identification number, and date and place of birth (“Identity Data”), in order to establish, confirm or authenticate your identity and to fulfill our legal responsibilities related to Know Your Customer (“KYC”) requirements.

User content

Some features of the Services allow you to provide content to the Services by means such as submitting written comments or transactions (“Profile and User Data”). All content submitted by you to the Services may be retained by us or others indefinitely, even after you terminate your use of our Services. We may continue to disclose such content to third parties in a manner that does not reveal Personal Data that you provide to us, as described in this Privacy Policy.

Transactions on FillyX

You may submit transactions, data, and other information to the FillyX Network using our Services (“Profile and User Data”). All information submitted to the Fillyx Network is accessible by the public and is stored by distributed and potentially anonymous parties across the globe. We do not retain any control over any transaction data that you submit using our Services to the Fillyx Network. You acknowledge that all information that you submit to the Fillyx Network may be stored by third parties indefinitely.

IP address information and other information collected automatically

We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information (“Technical Data”). This information is used for fighting security attacks, spam, and malware, and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).

Generally, the Services automatically collect usage information, such as which websites, links, and applications visitors were referred from, the number and frequency of visitors to the Site and to each page, and the geography of the visitors. We may use this data in aggregate form as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve our Services.

We may collect some device and browser specific information if you access the Services using a mobile device and/or web browser. Device information may include, but is not limited to, unique device identifiers, the device’s operating system, mobile carrier and network information, hardware model, location or GPS/geo-location, and how the device interacts with our Services. Browser information may include the type and version of your browser. We use this data in an aggregate form, and not in a way that could identify you personally.

Email communications

We may receive a receipt and read confirmation when you open an email from us. This confirmation may include the time which you opened the email, the browser you used, the IP address, the email service provider, other trackers, and the device used. We use this info to improve our customer service and to send our users more relevant emails.

Information collected using cookies

Cookies are pieces of data that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet.

Our cookies do not, by themselves, contain Personal Data, and we do not combine the general information collected through cookies with other Personal Data to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage the most attractive features of the Services.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how Third Party Services place cookies on your computer. For example, Third Party Services to which a link points may set cookies on your computer.

Information related to advertising and the use of web beacons

To support and enhance the Services, we may serve advertisements, and also allow third parties advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms.

Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on anonymized information inferred from information provided to us by a user, including Personal Data (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on your activity on Third Party Services. We do not provide Personal Data to any ad networks for use outside of the Services.

To increase the effectiveness of ad delivery, we may deliver a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized and aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site.

Aggregate data

We collect statistical information about how users, collectively, use the Services (“Aggregate Data”). Some of this information is derived from Personal Data. This statistical information is not Personal Data and cannot be tied back to you or directly or indirectly reveal your identity.

Information regarding your social networks

Occasionally, you can use our Services to interact with your accounts on other services, such as Facebook or Twitter. In addition to using your third-party account credentials to sign in to the Services, you can access posting and sharing tools on the Services, including a “share” button that allows you to post information to your social networks outside of the Services (“Share”). For example, after making a transaction on the Services, you can Share information about that transaction with your Facebook friends or Twitter followers. Please note that these tools may be operated by Third Party Services.

By using these tools, you acknowledge that some Third-Party Services account information may be transmitted into the Services, and that Third Party Services account information transmitted to our Services is covered by this Privacy Policy. Additionally, when you use one of these sharing tools, the Third-Party Service that operates the tool may be collecting information about your browser or online activity through its own tracking technologies and subject to its own privacy policy. Lastly, when you use these tools, some of your information from the Services (such as the transaction information you selected to Share) may be shared with the Third-Party Service and others. Therefore, we encourage you to read the privacy policies and other policies of the social networks you use in connection with the Services.

Special categories of personal data

We do not collect any Special Categories of Personal Data about you (this include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions or offenses.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct Interactions. You may give use your Personal Data by filling in forms or corresponding with us by post, phone, email, or otherwise. This includes Personal Data you provide when you
• Register for an account;
• Opt in to be eligible to win an award or receive a payment for any giveaway, contest, or task;
• Submit user submissions;
• Submit transaction data to the FillyX Network;
• Request marketing to be sent to you; or
• Give us feedback or contact us.
• Automated Technologies or Interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this Personal Data by using cookies and other similar technologies.
• Third Parties. We will receive Personal Data about you from various third parties as set out below:
• Analytics providers such as Google;
• Social Networks, such as Facebook and Twitter, as described above.

How is the information we collect used?

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you. Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of a business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Where we need to comply with a legal obligation. Comply with a legal obligation means using or processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

We use the information collected to (i) respond to your requests, (ii) provide customer service; (iii) personalize your experience; (iv) improve the Site; (v) give you information about your account or use; and (vi) provide you with a safe, efficient and customized experience. These activities our necessary for our legitimate interests as defined above. If you receive an award or payment from us, we also may use the information collected in order to establish, confirm, or authenticate your identity and to fulfill our legal responsibilities related to Know Your Customer ("KYC") requirements. These activities are required to identify you, perform a contract with you, and are necessary for our legitimate interest.

We may use your contact information to respond to your requests or send you information about our Services, but only when we feel such information is important. You may unsubscribe from these messages by clicking on the "Unsubscribe" link in our email communications or switching your email preferences in your account settings. Please note that, even if you unsubscribe, we reserve the right to contact you when we believe it is necessary to inform you of high importance notifications that may affect your rights.

We use Aggregate Information about our users and non-Personal Data to analyze Site and user behavior and prepare aggregated reports, which is necessary for our legitimate interests.

We use information from the Site to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Service, which is necessary for our legitimate interests.

We use your information to contact you about Site maintenance, provide the Services, comply with your stated communication preferences, provide you relevant educational material, provide other services requested by you as described at the time we collect the information from you, send you marketing communications, and contact you for other purposes authorized by law.

When you access the Site on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy. For example, we may use this information to provide you with location-based services, such as advertising, search results, and other personalized content.

How, and with whom, is my information disclosed?

The Services are designed to help you interact and share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.

Public information about your activity on the services

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site and all transactions and operations on the Fillyx Network.

Information concerning users’ use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored privately by us.

Please also remember that if you choose to provide Personal Data using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

IP address information

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our affiliates, partners, service providers, and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information you elect to share

You may access other Third-Party Services through the Services, for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third-Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Aggregate information

We may share Aggregate Information with our affiliates, partners, service providers, and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated, or otherwise non-Personal Data about you that they have independently developed or acquired.

Email communications with us

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your use of the Services. Communications relating to the Services will only be sent for purposes important to the Services, such as Service updates, notifications, customer service, and password recovery.

Information shared with our agents

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Data with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Data with our Agents.

Information disclosed pursuant to business transfers

We reserve the right to access, read, preserve, and disclose any information, including Personal Data, as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security, or technical issues, (iv) respond to user support requests, or (v) protect our rights, property, or safety, or that of our users and the public. This includes exchanging information with other companies and organizations for fraud protection, security attacks, and spam/malware prevention.

We may also share any information with law enforcement, governmental agencies, or authorized third-parties in response to a verified request relating to a criminal investigation, alleged illegal activity, or any other activity that may expose us, you, or any other user of the Services to legal liability. In this regard, we may share your information with third parties in response to a subpoena, document discovery process, other legal process, and/or as permitted by law. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, zip code, telephone number, government ID, email address, user ID history, IP address, fraud complaints, and anything else we may deem relevant to the investigation.

Information we share with ad networks

On the Site, we may work with third-parties to serve advertisements, provide us with data collection, reporting, ad response measurement, and site analytics, and assist with delivery of relevant marketing messages and advertisements.

These third-parties may view, edit, or set their own tracking technologies and/or cookies. The use of these technologies by these third-parties is subject to their own privacy policies and is not covered by this Privacy Policy. They might also obtain information about other applications that you have downloaded to your mobile device, the mobile websites you visit, and other information about you or your device in order to analyze and serve anonymous targeted advertising on the Site and elsewhere. For more information about third-party ad servers at our Site and your ability to opt-out of targeted advertising from such third-parties, please visit http://www.networkadvertising.org/choices/. The effect of an opt-out may be to stop targeted advertising, but it may still allow the collection of usage data for certain purposes (e.g., research, analytics, and internal online services operation purposes).

Information we share with companies in the mobile app industry

If you access the Site through a mobile device, we may also share your information with carriers, operating systems, and platforms.

Information we share with your consent

Except as set forth above, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information.

International transfers

If you are a resident of the European Economic Area (EEA), your Personal Data may be transferred outside the EEA. Our offices are in the United States and your data is stored there. Many of our external third parties are based outside the EEA, so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that your data is given the same protection it has in the EEA.

Is information about me secure?

We seek to protect Personal Data to ensure that it is kept private; however, we cannot guarantee the security of any Personal Data. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We maintain technical, physical, and administrative security measures to protect the security of your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise.

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

It is your responsibility to make sure that your Personal Data is accurate and that your password(s), private keys, and account registration information are secure and not shared with third-parties. We cannot assist in recovery of the loss of private keys.

How long will you use my personal data for?

Your information may be transferred to and processed in countries other than your country of residence. We ensure that such transfers comply with applicable data protection laws and implement appropriate safeguards.

What information of mine can i access?

Users can access and delete cookies through their web browser settings. However, if you choose to disable cookies, you may not be able to access functionality on our Site correctly or at all.

You may email userdata@fillyX.com at any time to obtain a copy of the information that we may have gathered and retained about you.

Registered members can review and change Personal Data at any time by accessing their accounts on the Site. You should promptly update your Personal Data if it changes or becomes inaccurate.

We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Service, and take other actions permitted by law. Likewise, if your account is terminated or suspended, we may maintain some information to prevent re-registration.

Notice to California residents

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.

If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Fillyx Ltd., Islamabad, Pakistan. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this notice applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

How we respond to do not track signals for California residents

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how our Site responds to “Do Not Track” browser settings. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

Children’s privacy

The Site is a general audience site and is not intended for anyone under the age of 18. We do not knowingly collect Personal Data via our websites, applications, services, or tools from users in this age group.

What choices do I have regarding my information?

You may choose not to access our Services if you do not consent to the collection and usage of your information as described in this policy.

You can always opt out of receiving marketing emails from us by following the instructions in those emails. If you opt out, we may still send you other communications, such as those about your account or any Services you have requested or received from us.

You may email userdataprivacy@FillyX.com and request that we delete all of your Personal Data. We will make such a deletion within fifteen (15) business days.

Legal rights for eea residents

EEA Residents have the following rights under data protection laws:

• Request access to your Personal Data (commonly known as “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
  • If you want to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims;
  • You have an objection to our use of your data but we need to verify whether you have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

This Privacy Policy and all data handling practices of FillyX comply with the laws of Pakistan, including any applicable data protection, privacy, and cybersecurity regulations. FillyX is committed to safeguarding user data and maintaining full transparency in accordance with Pakistan’s evolving digital governance and privacy standards.