Updated 02.02.2022
This is the Privacy Policy of Colchester Services Ltd. (hereinafter referred to as "Colchester Services," "we," "us" or "our"). Our Privacy Policy explains how we collect, use, share and protect personal information as well as your related choices regarding use, access, and correction. We process personal data in a manner that is in accordance with the The Data Protection Act, 2021 (the "DPA") (in the British Virgin Islands ("BVI"). We may update this policy from time to time by publishing a new version on our website.
Responsible for data processing
Colchester Services Ltd. is responsible for the processing of your personal data with respect to the use of our website, purchase of services and/or products and the conclusion of Fozeus Franchise agreements (as defined hereafter) as shown in this Privacy Policy.
Contact details:
Colchester Services Ltd.
Trident Chambers
P.O. Box 146
Road Town,
Tortola
British Virgin Islands
To exercise your rights or for any questions regarding the use, collection, or processing of your personal information, please contact our Data Protection Officer at privacy@fozeus.fr
What kind of information do we collect?
We collect the following information you provide us with directly during the order process or registration process:
If you register with us as an Franchisee (e.g., as an individual or business entity that enters into an Franchisee Agreement with us for the promotion and sale of Colchester Services services and/or products and/or opportunities, hereinafter “Franchisee”) we will process the following additional personal data from you:
How do we use this information?
Your personal data will be processed by us only for the following purposes:
Execute our agreement with you
Processing payment
After you place an order on our website you will need to make payment for the services or products you have ordered. To process your payment, you may have to provide financial information such as credit card numbers, expiration dates and security codes. This information is not processed or stored by our service, and it is only sent directly from you to a third-party payment processor over an encrypted connection. Your payment will be processed by Mercuryo in accordance with their privacy policies. Please see Mercuryo's privacy policy for information about how they handle your data.
Account
If you want to use our services or order a product from us, we ask you to register a personal account. We process your username, password, and email address to register your account. We also store this information so that you can log in easily every time. We display this information in your account so that you can adjust this information yourself. We also use your email address for support, for example if you want to create a new password, we will send you an e-mail with which you can reset your password. If you access certain parts of our website with a password, you are responsible for the confidentiality of this password. We ask you not to share your password with others.
Validation, verification, and automated decision-making
If you have signed up as an Franchisee, we may ask you to validate your identity and address online as part of the “Know Your Customer” (“KYC”) procedure. The images that you make of your passport, driving license or national identity card or other identification documents specific for certain countries as requested and the profile you create are processed for the purpose of validation. The data necessary for validation is abstracted, the images are compared using a combination of “facial biometric system” and where applicable manually by real people. It is only possible to make use of online validation if you give your explicit consent. Colchester Services engages third party service providers for identity verification purposes. For that purpose, the personal data needed for the check (surname, first name, date of birth, address, and copies of your passport, driving license, national identity card and other identification documents) is passed on to the relevant third party. Colchester Services itself does not store, hold, process, or access identity verification information. Colchester Services reserves the right to reject activation of an franchisee account if the result of identity verification is negative and the right to carry out a regular check on the validity of your identity. Your identity verification will be processed by GetID in accordance with their privacy policies. Please see GetID’s privacy policy for information about how they handle your data.
Web office
As an Franchisee, you will have access to the Fozeus Franchise web office. In this web office, you will have an overview of the services and products that you have ordered. For this purpose, you will see the following data: your profile information including first name, last name, address, email, phone number, language, date of birth, wallet address, passwords, transactions, subscription packages, downloads, promotions, and tickets ordered, order date, payment status.
You can also obtain a team overview in the web office. Here, you will be given information on the Franchisees that you have acquired in your downline. For this purpose, you will see the following data: username, place of residence and country, number of Franchisees, number volume points acquired by your team members, merchants, career progression rank and position of the Franchisee.
This information is only used for the calculation and traceability of your royalty claims.
Marketing
We may use your information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. We may use email and other communication channels to send you direct messages with personalised advertisements and special offers, such as postal mail, mobile push notifications or social channels (e.g., Messenger or WhatsApp, Telegram).
We do this only if you have explicitly given your consent to us to do so. You may unsubscribe from our advertisements, offers and from e-mails to which you have subscribed at any time by clicking on the unsubscribe link in the e-mail. If you have opted to receive personalised advertisements and offers through mobile push notifications, you can unsubscribe by changing your smartphone settings (for mobile push notifications). Visit the website of your social network provider for more information on how to unsubscribe from receiving personalised advertisements and offers through social channels (e.g., Messenger or WhatsApp, Telegram). You may always contact us to unsubscribe from receiving messages containing advertisements and offers.
Log file information
We collect and store information through the use of “cookies” and other automated means whenever you visit our website. This information may include information such as your computer's Internet Protocol address, browser type, browser version, your login attempts, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics. This enables us to improve our website and deliver a better service to you. We collect your IP address to track technical issues and errors so we can improve our website. We use your IP address and log activities to be able to avoid or eliminate fraudulent use of your account. This way we can see if there is an irregular amount of login attempts on your account to allow us to detect fraud. In such an instance we may request you to verify your identity using your Account Information. We store your IP address and your activities on our website for this purpose in our logs. You may always contact us if you wish to delete this information and/or personal data from our files. Find out more about the cookies we use in our “Cookie Policy”.
Communications and support
We use your contact details to communicate with you about our services and in order to reply to questions or to handle complaints about our services and products via e-mail, telephone, chat, messaging apps or other communication methods.
Social media
We are also active on social media platforms such as Facebook, Twitter, LinkedIn, YouTube, and Instagram. From time to time, we may promote our events, celebrate your achievements, organize contests and other promotions. If you contact us via social media, we process your data in order to reply to questions you may ask via social media, to contact you for congratulatory purposes or when you participate in a contest or promotion on our social media page(s). If you participate in a contest or promotion, we ask for your name (including your social media handles), address and / or e-mail address. We need this information to announce and inform the prize winner(s). We only collect this information with your consent. You will find more details on each contest or promotional activity. For congratulatory purposes, such as celebrating your achievements or for sending out birthday wishes to you, we may ask for your name, a picture of you, your day of birth and your rank. We only collect and publish this information on our social media accounts with your consent. We may use your personal data for purposes other than those described in this Privacy Policy. We will inform you about those purposes when you register for the service, event, contest, or promotion.
From our social media pages and campaigns, we receive visitor statistics. Although Fozeus Franchise and our social media service provider are responsible for those visitor statistics, the respective social media service provider is your primary point of contact and handles requests to exercise your rights and any complaints you may have. Where necessary, we assist, the respective social media service provider in responding to your requests or complaints. For more information on the personal data that we receive from social media network providers and how to change your settings, please check the websites and privacy policies of the social media network providers.
How is this information shared?
We may disclose your data with our parent company and our service providers insofar as reasonably necessary for the performance of the agreement you have concluded with us. Our parent company and all such service providers are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements, an oath or legal obligation. We may send your personal information to:
Change of control
If we sell or otherwise transfer part or the whole of Colchester Services or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information may be among the items sold or transferred. The buyer or transferee will have to honour the commitments we have.
Legal requests and preventing harm
We may access, preserve, and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. We may also access, preserve, and share information when we have a good faith belief it is necessary to: detect, prevent, and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
Safety and security
Colchester Services has taken appropriate technical and organizational measures to ensure that the regulations and requirements relating to data protection are observed and upheld both by ourselves and by our external service providers. We use the latest technologies to protect your information against loss or unlawful processing. We use safeguards to help keep the information collected through the Service secure; requesting a unique password to verify your identity before granting you access to your account, tracking of user log-in attempts, encryption of sending personal data via our website (SSL) and regularly updating our systems are examples of these measures. If you think that your data is not properly secured or if you have indications that your data is being misused, please send us an email. However, Colchester Services cannot ensure the security of any information you transmit to Colchester Services or guarantee that information on the website may not be accessed, disclosed, altered, or destroyed. We request you to do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Colchester Services, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.
International transfer
In principle, your personal data will not be transferred to and maintained on computers located outside the European Economic Area (“EEA”). However, in the case of some of the non-European service providers that we engage, data processing outside the EEA cannot be excluded.
In order to comply with EU legislation, we carefully consider whether an adequate level of protection can be provided. These service providers are only permitted to use the information insofar as reasonably necessary for the performance of the agreement you have concluded with us. Where necessary, we conclude data transfer agreements with these service providers based on standard contractual clauses established by the European Commission. These service providers may be obliged to provide access to your data based on their applicable laws and regulations. For more information about safeguards for international transfers, please contact us using the contact details provided in this Privacy Policy.
Retention period
In accordance with the British Virgin Islands law, Сolchester Services does not retain your personal data any longer than is reasonably necessary for attaining the purposes for which they were collected outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer.
Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
Inspection and correction
You can easily access most of your data (including the data provided by you) and rectify/correct such data though your registered account. If you have created an account on our website as a customer, you can delete your account by sending us an email to remove your account.
If you have created an account on our website as an Franchisee, you can send us an email to deactivate your account. Your position within your team will remain visible, but we will anonymize your personal information, in which case it is no longer considered personal information.
If you wish, we can send your personal data to you so that you can transfer it to another party. You can make a request to that effect by sending an email to us. Most likely, in such case we will no longer be able to continue our service as we can no longer guarantee the safeguard of your personal data.
Remember, you can always object to the processing of your personal data and stop using our services.
Third-party applications, websites, and services
We are not responsible for the practices employed by any applications, websites or services linked to or from our website, including the information or content contained within them. Please remember that when you use a link to go from our Service to another application, website or service, our Privacy Policy does not apply to those third-party applications, websites, or services. Your browsing activity and interaction on any third-party application, website, or service, including those that have a link on our website, are subject to that third party's own rules and policies.
Children's privacy
We do not intent to address to children (under 13 in the US, under 16 for EU residents, or other age as required by local law) ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your Children has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under the age of 16 (or the applicable age in their territory) without verification of parental consent, we take steps to remove that information from our servers.
Changes to this privacy policy
We may modify or update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.