Contents

Introduction
How do we collect information from you?
How We Use and Retain this Personal Information
Disclosure of your Personal Information
Security
International Data Transfers
Children
Your Rights
Cookie Usage
Removing or Disabling Cookies
Amendments
Ad Technology Providers
Contacting Us

Introduction

At ‘Titans Family’, we recognise that the privacy of your personal information is very important and we are committed to respecting and protecting your privacy.

This privacy policy explains how we “Titans Family” (titans- family.com and its subdomains) collects, uses and protects any information that you give when you use our services and under which conditions we may disclose it to others.

Should we ask you to provide certain information by which you can be identified when using our services, then you can be assured that it will only be used in accordance with this privacy policy for the purpose of providing our services to you.

Titans Family may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. By using our website and other services, you are agreeing to be bound by this policy and our terms of use which form part of this privacy policy.

Titans Family is the data controller and operator of the titans-family.com website and apps. If you have any questions regarding this policy or our practices, you can contact us by using our contact us page.

How do we collect information from you?

We collect, store and process your personal information from you when you; browse and use our website or apps as described below.

What Personal Information we collect

The following information is collected whilst using our services when filling out any form on our website and apps or corresponding with us via email. We only ask for information that is necessary for us to be able to provide our free pet classifieds service to you and to prevent any abuse of our site and to enforce our terms and conditions:

• Information you provide for the purpose of registering with us, such as your name, telephone number, address, email and whether or not you want to receive newsletters.
• Information you provide whilst creating or updating any pet listings, which can include your telephone number, postcode and any details you provide within the listing description.
• Information you provide when contacting our support team either via our “contact us” page or our “contact support” page.
• Information you provide when sending messages to sellers via the “Email Seller” option on any pet listing, or the “contact us” option on any user profile page. This information you provide is also forwarded directly to the advertiser via email so they can respond to you directly.
• Information you provide when reporting any pet listings to us.
• Any correspondence you have with our support team, either via the website or directly via email.
• Whilst providing our free classifieds service, either due to our own concern or if we receive a query or complaint regarding your account, we may ask for additional information to help resolve any account issues such as microchipping details; vaccination documents; pet licensing documentation; vet records; photo to verify your name and address, such as a photo of a utility bill header or driving license or other information. This information will usually be requested via email and is used to prevent abuse of website and prevent fraud. It is a requirement if you wish to continue using our services and we will only use this information for the purpose of verifying your account and adverts details. If you do not want us to process this information, please do not send it to us.

We automatically collect the following information when you use our services :

• When registering an account or placing an advert using our services we automatically collect your browser and device type and version, your ip address and geographical location.
• Whilst browsing and using our website we collect information about your computer, your visits to and your use of this website which can include your IP address, geographical location, browser device and type, referral source, length of visit, pages viewed and activity on each page.

Other Personal Information you send us :

If you send us other people’s personal information, you must first make sure you have their consent to send us this information and that they are aware that this personal information will be processed in accordance by this privacy policy.

How We Use and Retain this Personal Information

All personal data which you submit on our site or apps will be used for the purposes described in this privacy policy :

• To enable the use of our pet classifieds services.
• To provide and supply our free pet classifieds service to you including the publishing of your personal information you provide within your pet listings on our site and apps. The personal information published on pet listings includes your first name and last initial and your phone number. What information is published can be controlled by yourself and you can close your pet listing at any time.
• To verify the legitimacy of your adverts and account data.
• To send you important service (non marketing) emails regarding the status of your account or any advert you place.
• To give you a personalised experience on our website and apps.
• To enable us to deal with any queries or complaints, either by you or regarding you relating to the use of the website.
• To help detect and investigate any possible fraudulent activities; for security purposes; to monitor usage and activity on our website; or to enforce our terms and conditions.
• To comply with our regulations and any legal obligations.
• To enforce our Terms & Conditions.
• To Protect our rights, safety, privacy and/or that of our affiliates, you or others.
• To limit any damages that we may sustain.
• To send you newsletters if you have opted in to receiving them. However you can opt out of them at any time via your account page or by contacting us.

Where you have submitted your personal information for publication on our website and apps, we will publish and otherwise use that information in accordance with the license you grant to us. We will not, without your express consent provide your personal information to any third parties for the purpose of direct marketing.

We rely on the following legal basis for processing your personal data :

• We process your data so that we can provide our free classifieds service to you, which you have requested by registering, providing us with your personal and advert details and publishing your advert(s) on the Titans Family website and apps.
• We process your data for our legitimate interests to ensure our services are used appropriately and to help prevent any abuse of our website including fraud and to help enforce our terms and conditions. For example, to help us monitor the usage of our services and to prevent the use of multiple accounts.
• We have obtained your consent, for example you have opted in to receive newsletters from us; you have entered your personal data in to our website so we can provide our service to you and publish your information; you contact us with a support request; you send photos of your id or information to us to help provide our service to you.
• To comply with our legal obligations, there may be situations where we need to use your information to comply with regulatory obligations or to help in any investigations by local authorities including the police, HMRC, welfare organisations, trading standards and local councils. Also for the establishment, exercise or defence of any legal claims, where necessary.

We retain your personal information for as long as is necessary for us to provide our services to you and for the reasons set out in this privacy policy. We also have the need to retain your information, even when you have requested for your account to be closed. Personal information from closed accounts is retained in order to comply with legal obligations as set out in this privacy policy.

Disclosure of your Personal Information

We may disclose information about you to any of our employees whilst they are providing our service to you or to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

During the use of our service, when you contact an advertiser, any personal details you enter in your message to an advertiser will be passed on directly to the advertisers email address.

When registering and placing any adverts on our Titans Family service, certain details you enter will be published on the internet, including your first name and last initial which will be displayed on your public profile. Your advert details and telephone number(s) if you have entered them on your advert will also be published. The contact details on your advert will automatically be removed once you close your advert.

In addition, we may disclose your personal information :

• To the extent to which we are required to do so by law.
• In response to official requests for information from local authorities including the police, HMRC, welfare organisations, trading standards and local councils to help them in their investigations.
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
• In connection with any legal proceedings or prospective legal proceedings
• In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
• To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

Except as provided in this Privacy Policy, we will not provide your information to third parties.

Security

We are committed to ensuring that your information is secure. We protect your information using both technical and administrative security measures which help us reduce the risk of data loss, misuse or unauthorised access. Our website uses encryption such as SSL to ensure data sent to and from the website is secure. We store your data on our secure servers.

Whilst we do everything we can to protect your account and personal information, we cannot guarantee the integrity or security of any data you enter on our website.

You must make sure that you do everything possible to protect your account by logging out when appropriate; not giving other people access to your account and keeping your password secure by not giving it out to anyone. We advise that you use a unique password for the use of our website. We will never ask for your password (except when you login to the website or apps).

However, if you believe your account has been compromised, please contact us immediately.

International Data Transfers

We have a regionalised data centre strategy such that all European users’ data is stored within the EEA. However, European users data may in some cases be transferred outside the EEA (including to the United States) by sub-processors of us. We cannot in all cases provide prior information to the users of such transfer, but we warrant that all sub-processors of us have guaranteed that :

• they meet the high standards of EU data protection regulation;
• no matter where users’ data is located throughout the world it is protected to a standard which is no lower than that required by the EU data protection authorities; and
• they abide by the relevant Safe Harbour frameworks regarding correction, use, transfer and retention of data from the EEA.

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this Privacy Policy. You expressly agree to such transfers of personal information. If you do not, please do not enter any of your personal details on our website.

In addition, any personal information that you submit for publication on the website or our apps will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

Children

You must be 18 years of age to register on the Titans Family website and we do not knowingly collect anyones personal details under this age. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

Your Rights

Under the General Data Protection Regulation, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions, however, some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Access to personal data: We provide the tools online for you to login to your account at any time to view and access your personal data. You have a right to request a copy of the personal information that we hold about you. If you wish to make such a request, please use our contact us page and select the “Data Controller” option from the list. You should include details of what information you require, adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request.

Correction of personal data: We provide the tools online for you to login to your account at any time to view, update and change any information about yourself if it is incorrect or outdated.

Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent. For example to opt out of receiving newsletters, you can login to your account and edit your personal information and preferences. You can also limit what information we publish on our website by changing your settings on your account page, or contacting us to request your account is closed.

Right of erasure: You can contact us to request us to erase your personal data where there is no compelling reason for us to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right as we may have legitimate reasons to retain your data as described above.

Closing your account: If you wish for your Titans Family account to be closed, you can contact us via the contact us page. Please note that closing your account will remove any visible data from the internet such as old adverts and your profile page, and also prevent you from logging in. However, please note that this will not erase your data as we may have legitimate reasons to retain your data as described above.

Right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

Right to data portability: You have the right to have your parsonal data that we store and/or process sent to other data controllers and/or processors.

Right to complain to a supervisory authority: If you consider that our processing of your personal information infringes data protection laws, and you believe we haven’t resolved the issue, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. You may exercise any of your rights in relation to your personal data by written notice to us.

Cookie Usage

When visiting, browsing or interacting with our website, we or third parties may use cookies or other similar technologies.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

The Titans Family website uses cookies to provide certain functionality as below. By using our website and apps, you agree that we can put these types of cookies on your computer or device. If you would like to disable any of these cookies, please see the section below titled ‘Removing or Disabling Cookies’ for more details :

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Analytics Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Social Media Cookies

These cookies are used by social media services to enable you to share our content with your friends and networks. These cookies may track your browser across other sites and build a profile of your interests, which may impact the content and messages you see on other websites you visit.

Advertising Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Removing or Disabling Cookies

You can manage your cookie preferences on Titans Family at any time using our privacy centre.

You can also choose to disable or selectively turn off our cookies or third-party cookies in your browser settings, or by managing preferences in programs such as Norton Internet Security. However, this can affect how you are able to interact with our site as well as other websites. This could include the inability to login to services or programs, such as logging into your Titans Family account.

If you do wish to disable cookies in your internet browser, here is a link to instructions in some of the most popular browsers :

• Internet Explorer
• Firefox
• Chrome
• Safari
• Opera

We work with advertising partners like google doubleclick and third parties to serve advertisements based on your interests. You can change Google’s Ad Settings at google.com/settings/ads. For more information on third party advertising related cookies and how to opt out of them, please visit the youronlinechoices website at http://www.youronlinechoices.eu

We also use Google Analytics who use first-party cookies (such as the Google Analytics cookie) to track user interaction with our website. You are able to opt out of this tracking here https://tools.google.com/dlpage/gaoptout

By using our service you consent to the use of the cookies and other technologies described above.

Ad Technology Providers

We use Google Admanager to display personalised ads to visitors of our website. The following Ad technology providers (including Google and other ad networks, bidders and vendors) may use data about our users, for example to show them personalised ads or to report on conversions.

Amendments

We may update this privacy policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

Contacting Us

If you would like to contact us regarding anything in this privacy policy or about anything related to how we collect or store your personal details, please get in touch with us :

• by post, to Mihai-Voda Village, 21 Garoafei Street
  Bolintin-Deal Commune, Giurgiu 087016
  ROU;
• by using our contact us page and selecting the “Data Controller” option from the list.