PRIVACY POLICY
This Privacy Policy governs the manner in which Family Space Limited collects, uses, maintains and discloses the information collected from the “Users” of FamTree application. This Privacy Policy applies to the application and all its products and services offered by Family Space Limited and its affiliates.

1. GENERAL
a. This document is an electronic record pursuant to Information Technology Act, 2000 and rules there under as applicable and amended by Information Technology Act, 2000. This document is published in accordance with the provisions of Rule 4(i) of the Information Technology Rules, 2011 (Body corporate to provide policy for privacy and disclosure of information.) that require publishing the rules and regulations, privacy policy and terms of use for access or usage of “Website/Application of Family Space Limited”.

b. The Domain name FamTree and the application of the same name(“platform”), is owned and operated by Family Space Limited,
a company, having its registered office at Gladstonos, 116, M.Kyprianou House, 3 & 4 floor, 3032 Limassol, Cyprus, where such expression shall, unless repugnant to the context thereof, be deemed to include its representatives, administrators, employees, directors, officers, agents and their successors and assigns.

c. The purpose of this Privacy Policy (“Policy”) wherever the context so requires;
i. The term ‘You’ & ‘User’ shall mean any legal person or entity accessing or using the services provided on this Website, who is competent to enter into binding contracts, as per the provisions of the Indian Contract Act, 1872. The terms ‘We’, ‘Us’ & ‘Our’ shall mean the Website and/or our entity, as the context so requires.
ii. The term party and parties shall be respectively be used to refer to the User and our entity, individually and collectively, as the context so requires.
iii. The term personal data means any personally identifiable information in
relation to the User/s.
d. The use of Platform/visiting the homepage of the Website and or/using any of the services provided on the platform shall be deemed to signify the User’s acceptance of this Policy and the terms of use and the User expressly agrees to be bound by the same.

2. COLLECTION OF PERSONAL AND OTHER INFORMATION
a. User expressly agrees and acknowledges that we collect and store the User’s personal information including but not limited to the username, passwords, email address, name, address, age, date of birth, sex, nationality, browsing history, images or other information. The User is aware that the information collected by Us/Platform will be used to provide service and features targeted at the User, that are most likely to meet the User’s needs, and also to customise and improve the platform.

b. User is aware that the platform is an online platform that enables its User to utilize the platform to establish connection between family members to serve their mutual interests, as be decided by the Users.

c. User expressly agrees and acknowledges that the information collected by Us/Platform may be made available to other users for the purpose of fulfilling the requirements of the User. User expressly agrees that by utilizing our services through the use of the platform, the User gives express consent for making such information collected by Us available to other Users.

e. The User is aware that the Platform may automatically track certain information about the User based upon the User’s IP address and the User’s behaviour on the Platform, and the User expressly consents to the same. The User is aware that this information is used to do internal research on user demographics, interests, and behaviour, to enable the Platform to better understand, and cater to the interests of its users. The User is expressly made aware that such information may include the URL that the User visited prior to accessing the Platform, the URL which the User subsequently visits (whether or not these URLs form a part of the Platform), the User’s computer & web browser information, the User’s IP address, etc.

f. If the User chooses to avail services from the Platform, the User consents to allowing the Platform to collect information about the User’s behaviour.

g. The User is aware that any and all information pertaining to the User collected by the Us, whether or not directly provided by the User to the Platform, including but not limited to personal correspondence such as emails or letters, feedback from other users or third parties regarding the User’s activities or postings on the Platform, etc., may be collected and compiled by Us and the User hereby expressly consents to the same.

3. COOKIES
The Platform may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them and that cookies are useful for enabling the browser to remember information specific to a given user, including but not limited to a User’s login identification, password, etc. The User hereby expressly consent to the same.

4. SHARING OF PERSONAL INFORMATION TO THIRD PARTIES
a. We may use service companies on our behalf to perform certain services for you, we may share the User’s personal information with other corporate entities/affiliates or government service providers for the purpose of fulfilling the obligation of our services or for enhancing the quality of our services.

b. The User is aware that the Platform may disclose personal information if required to do so by law or if the Platform in good faith believes that such disclosure is reasonably necessary to respond to court orders, or other legal processes as required by law.

5. PROTECTION OF YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our platform.

6. USERS CONSENT
By using the Platform and/ or by providing information to Us through the Platform, the User consents to the collection and use of the information disclosed by the User on the Platform in accordance with this Policy, including but not limited to the User’s consent the Platform sharing the User’s information, as per Clause 4 of this Policy.

7. Grievance Officer
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Name: Natalia Shkirtil
e-mail: support@family.space
Please provide your address, telephone number, and e-mail address while sending the notice to us.

8. JURISDICTION
The Parties expressly agree that the Terms, Policy and any other agreements entered into between the Parties are governed by the laws, rules and regulations of India, and that the Courts of Cyprus, shall have exclusive jurisdiction over any disputes arising between the Parties.

9. WARRANTY
The contents of this platform were prepared with the greatest possible diligence. However, Family Space Limited does not guarantee or endorse the content, accuracy or completeness of the information, text, graphics, hyperlinks, products and other items contained herein or on any other server.

10. CHANGES TO PRIVACY POLICY
The Platform is subject to periodic update and revision. We reserve the right to delete or modify information on this Site without prior notice. The User acknowledges and agrees that it is the responsibility of the User to review this privacy policy periodically and become aware of modifications.

11. USERS FROM THE EUROPEAN UNION
In accordance with the European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, which is applicable since 25 May 2018 (the “GDPR”), any legal entity which processes personal data as part of its activities established in the EU, regardless of where the data is processed, or when offering services to individuals in the European Union, is required to comply with the provisions of the GDPR.
For this reason, the provisions of this section of the Privacy Policy apply in respect of the use of the Platform under the provisions of the GDPR and the Cyprus national legislation as to the protection of personal data.
This Privacy Policy refers only to the contents of our website, the services and information contained on the Platform. In case you access any other website, you should read their Privacy Policy.
The personal data collected as provided under paragraph 2 of this Privacy Policy are collected in line with the lawful basis afforded by the GDPR. The personal data are collected directly from each user whilst using our services through the Platform. Personal data are being collected when a user:
- Registers and uploads personal data through the Platform; and/or
- Voluntarily completes a customer survey or provides feedback through the Platform or any other method of communication with us; and/or
- Uses or views the Platform via the Cookies; and/or
- If any other user uploads and/or provides information about another user through the Platform.

a) Lawful Basis for data processing
The personal data being processed through the Platform are processed for the purposes set out in this Privacy Policy, as described above. The legal basis for processing personal data will depend on the personal information concerned and the specific reasons these are collected. However, as a general rule, these are collected and processed only where:
i) It is necessary to provide the services pursuant to the agreement between you and us when requesting our services through the Platform;
ii) It is necessary to comply with legal requirements, if applicable;
iii) It is necessary for our legitimate interests and not overridden by your fundamental rights and freedoms;
iv) You have expressly given your consent to the processing of your personal data for one or more specific purposes.
v) In some cases the personal data being collected relate to special category data including but not limited to: sex, nationality, community, religion, ethnic group. In such cases we will only process your data where you have provided them voluntarily and we won’t process them unless we have your explicit consent.

If we are to collect and process your personal data on the basis of our legitimate interests, this interest will normally be the proper operation of the Platform and the services provided through the Platform, the management of our contractual relationships with the users and the communication of our services to the users, such as improving the Platform’s operations, security of information, availability and access to the services offered through the Platform. It is also possible that we use your personal data for marketing purposes of our existing or new services offered through the Platform. Your data will not be shared with third parties for the provision of any services other than those provided by our affiliated entities as disclosed in this Privacy Policy.

b) Data Storage
Personal data collected and/or otherwise processed through the Platform are securely stored on the Amazon Cloud, in AWS AP-SOUTH-1 (Mumbai) region. Whilst the cloud is situated outside Europe, the processing is carried out in accordance with the GDPR, as the Standard Contractual Clauses between controllers and processors are in place as approved by the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021. In addition, the necessary measures in relation to the safety and security of the processing of personal data through the Platform, such as access control and encryption of data are also in place.
- Access to the application is validated using cellphone-bound OTP delivered as a text (SMS) message with short-term expiration;
- Audit logs are stored to allow detailed activity analysis;
- Access to customer's data is protected using AWS IAM policies with granular access control;
- Full separation between Development, Test, Staging and Production environments with well-defined release process.
- Overall architecture follows AWS secure best practices (Well-Architected framework)

c) Data Retention
We will only retain your personal data as long as we have a lawful reason to do so and/or for as long as we need them to provide our services and/or to protect our and/or others’ interests. For example:
- Where you have registered and/or uploaded your personal data on the Platform, we will retain these for as long as you do not erase or delete them;
- If data concerning you have been registered or uploaded by any third party on your behalf, we may not be able to remove them unless removed by the person who has uploaded such information concerning you;
- If needed, we may retain information for our compliance with certain legal obligations.

d) Marketing
We may also send you information about our additional products and services that we think you might like, as well as other information in the form of alerts or newsletters or other types of communication. If you have agreed to receive such marketing communication, you will have done so expressly and unambiguously. In any case, you may always easily opt out if you so wish at any later date by
contacting us at info@family.space or via the Platform at Contact Us.

e) Transfer of Personal Data to third countries
In connection with the provision of our services through the Platform, we transfer personal data to countries outside the EEA, including countries that may not provide the same level of data protection as the EU. We take appropriate steps to ensure that recipients of data are bound by provisions of confidentiality and have implemented the necessary technical and organizational measures for the protection of personal data in line with the provisions of this Privacy Policy. It is also possible that we may transfer your data to a third country if you have given your consent.
In case no adequacy decision is available for the processing of the personal data, the data are transferred subject to appropriate safeguards on the condition that enforceable data subject rights and effective legal remedies for data subjects are available, by standard data protection clauses adopted by the European Commission.

f) Rights afforded to Users under the GDPR
Under the GDPR, you have the following rights:
- Right to obtain access to the personal data being processed about you;
- Right to require that we cease processing your personal data;
- Right to require us not to send you marketing communications;
- Right to require us to erase your personal data;
- Right to restrict processing of your personal data;
- Right to rectify the personal data we are processing for your;
- Right to request that we transfer your personal data to another organization or directly to you.
We have one month according to the GDPR to respond to your request. We may also charge a small fee depending on the request and in accordance with the GDPR. If you would like to exercise any of the rights afforded to you by the GDPR, please contact us at: info@family.space or via the Platform at Contact Us.


Should you feel dissatisfied from us, you may report to the Grievance Officer as noted above. You also have the right to report any complaint you may have or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Office of the Data Commissioner of the Republic of Cyprus at commissioner@dataprotection.gov.cy You may also see additional information on their website at www.dataprotection.gov.cy