date: July 24th, 2018
Class Media B.V. ("us", "we", or "our")
operates the "Message from Santa" mobile application and
website (the "Service").
page informs you of our policies regarding the collection, use, and
disclosure of personal data when you use our Service and the choices
you have associated with that data.
use your data to provide and improve the Service. By using the
Service, you agree to the collection and use of information in
accordance with this policy.
means the "Message from Santa" service operated by First
Class Media B.V., consisting of a mobile app and website.
means the "Message from Santa" mobile application operated
by First Class Media B.V.
means the “Message from Santa” website on
by First Class Media B.V.
Data means data about a living individual who can be identified from
those data (or from those and other information either in our
possession or likely to come into our possession).
Data is data collected automatically either generated by the use of
the Service or from the Service infrastructure itself (for example,
the duration of a page visit).
are small pieces of data stored on your device (computer or mobile
Controller means the natural or legal person who (either alone or
jointly or in common with other persons) determines the purposes for
which and the manner in which any personal information are, or are to
Controller of your Personal Data.
Processor (or Service Provider) means any natural or legal person who
processes the data on behalf of the Data Controller.
may use the services of various Service Providers in order to process
your data more effectively.
Subject is any living individual who is using our Service and is the
subject of Personal Data.
Collection and Use
collect several different types of information for various purposes
to provide and improve our Service to you:
using our Service, we may ask you to provide us with certain
personally identifiable information that can be used to contact or
identify you ("Personal Data"). Personally identifiable
information may include, but is not limited to:
and Usage Data
order to provide certain interactive and personalized features, such
as audio and video messages, we may ask you provide additional
information which may include, but is not limited to:
may also collect information that your browser sends whenever you
visit our Service or when you access the Service by or through a
mobile device ("Usage Data").
Usage Data may include information such as your computer's Internet
Protocol address (e.g. IP address), browser type, browser version,
the pages of our Service that you visit, the time and date of your
visit, the time spent on those pages, unique device identifiers and
other diagnostic data.
you access the Service by or through a mobile device, this Usage Data
may include information such as the type of mobile device you use,
your mobile device unique ID, the IP address of your mobile device,
your mobile operating system, the type of mobile Internet browser you
use, unique device identifiers and other diagnostic data.
& Cookies Data
on our Service and hold certain information.
are files with small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website
and stored on your device. Tracking technologies also used are
beacons, tags, and scripts to collect and track information and to
improve and analyze our Service.
can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may
not be able to use some portions of our Service.
of Cookies we use:
We use Session Cookies to operate our Service.
We use Preference Cookies to remember your preferences and various
We use Security Cookies for security purposes.
Advertising Cookies are used to serve you with advertisements that
may be relevant to you and your interests.
only use the collected data for the following purposes:
provide and maintain our Service
notify you about changes to our Service
allow you to participate in interactive features of our Service when
you choose to do so
provide customer support
gather analysis or valuable information so that we can improve our
monitor the usage of our Service
detect, prevent and address technical issues
provide you with news, special offers and general information about
our services unless you have opted not to receive such information
Basis for Processing Personal Data Under General Data Protection
you are from the European Economic Area (EEA), our legal basis for
collecting and using the personal information described in this
specific context in which we collect it.
may process your Personal Data because:
need to perform a contract with you
have given us permission to do so
processing is in our legitimate interests and it's not overridden by
payment processing purposes
comply with the law
will retain your Personal Data only for as long as is necessary for
your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to
comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when
this data is used to strengthen the security or to improve the
functionality of our Service, or we are legally obligated to retain
this data for longer time periods.
information, including Personal Data, may be transferred to — and
maintained on — computers located outside of your state, province,
country or other governmental jurisdiction where the data protection
laws may differ than those from your jurisdiction.
you are located outside The Netherlands and choose to provide
information to us, please note that we may transfer the data,
including Personal Data, to the Netherlands and process it there.
information represents your agreement to that transfer.
will take all steps reasonably necessary to ensure that your data is
transfer of your Personal Data will take place to an organization or
a country unless there are adequate controls in place including the
security of your data and other personal information.
we are involved in a merger, acquisition or asset sale, your Personal
Data may be transferred. We will provide notice before your Personal
Data is transferred and becomes subject to a different Privacy
for Law Enforcement
certain circumstances, we may be required to disclose your Personal
Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).
may disclose your Personal Data in the good faith belief that such
action is necessary to:
comply with a legal obligation
protect and defend the rights or property of First Class Media B.V.
prevent or investigate possible wrongdoing in connection with the
protect the personal safety of users of the Service or the public
protect against legal liability
security of your data is important to us, but remember that no method
of transmission over the Internet, or method of electronic storage is
100% secure. While we strive to use commercially acceptable means to
protect your Personal Data, we cannot guarantee its absolute
Not Track" Signals Under California Online Privacy Protection
support Do Not Track ("DNT"). Do Not Track is a preference
you can set in your web browser or mobile device to inform websites
that you do not want to be tracked.
can enable or disable Do Not Track by visiting the Preferences or
Settings page of your web browser or mobile device.
Data Protection Rights Under The General Data Protection Regulation
you are a resident of the European Economic Area (EEA), you have
certain data protection rights. We aim to take reasonable steps to
allow you to correct, amend, delete, or limit the use of your
you wish to be informed what Personal Data we hold about you and if
you want it to be removed from our systems, please contact us.
certain circumstances, you have the following data protection rights:
right to access, update or to delete the information we have on you.
Whenever made possible, you can access, update or request deletion
of your Personal Data directly within your account settings section.
If you are unable to perform these actions yourself, please contact
us to assist you.
right of rectification.
You have the right to have your information rectified if that
information is inaccurate or incomplete.
right to object.
You have the right to object to our processing of your Personal
right of restriction.
You have the right to request that we restrict the processing of
your personal information.
right to data portability.
You have the right to be provided with a copy of the information we
have on you in a structured, machine-readable and commonly used
right to withdraw consent.
You also have the right to withdraw your consent at any time where
we relied on your consent to process your personal information.
note that we may ask you to verify your identity before we can
respond to such requests.
have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information,
please contact your local data protection authority in the European
Economic Area (EEA).
may employ third party companies and individuals to facilitate our
Service ("Service Providers"), to provide the Service on
our behalf, to perform Service-related services or to assist us in
analyzing how our Service is used.
third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for
any other purpose:
Technologies Finland Oy.
to Other Sites or Apps
Service may contain links to other sites or apps that are not
operated by us. If you click on a third party link, you will be
directed to that third party's site or app. We strongly advise you to
control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Service does not address anyone under the age of 13 in the United
States or under the age of 16 in other countries ("Children").
We do not knowingly collect personally identifiable information from
Children. If you are a parent or guardian and you are aware that your
child has provided us with Personal Data, please contact us. If we
become aware that we have collected Personal Data from children
without verification of parental consent, we take steps to remove
that information from our servers.
of any changes by presenting you the new policy for review, when you
sign in to the Website or App.
using the support button in the App or on the Website, or by sending
an e-mail to firstname.lastname@example.org.
company collecting data “First Class Media B.V.” is a limited
liability company, having office at Bosscheweg 107, Boxtel, the
Netherlands. The company is registered
in the Dutch Business Register #71694374, D-U-N-S #492665793.