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Privacy Policy and Cookies

At Reel Good Flies Ltd (“Reel Good Flies“, “we“, “us“), we process personal data about our customers and visitors on our websites (“you“). We make efforts to handle your personal data with care, keep it secure and comply with data protection laws.

Reel Good Flies is engaged in E-Commerce and lead generation online, with headquarters in Malta and subsidiaries in a number of other countries.

How this Policy Works

The purpose of this Policy is to explain when, why and how we process information which may relate to you (“personal data“). It also provides important information on your statutory rights. This Policy is not intended to override the terms of any contract you have with us, nor rights you might have under data protection laws.

1. Who is responsible for looking after your personal data?

Reel Good Flies Operations Ltd having its registered address Valley Towers, Suite 5 Valley Road, BIRKIRKARA BKR 9022, Malta, is principally responsible for looking after your personal data (your Data Controller). Data Controller means the company that determines the means and purposes of processing of personal data.

You should be aware that although we are principally responsible for looking after your personal data, information may be held in databases which can be accessed by other companies. When accessing your personal data, all companies will comply with the standards set out in this Policy.

2. What personal data do we process?

We may process the following personal data about you:

3. What do we use your personal data for and when do we process your personal data?

Reel Good Flies will collect information directly from you when you use our services or visit our websites.

We use your personal data to:

We will only process your personal data for the purposes set out in this Section 3 and where we are satisfied that:

4. Who do we share your personal data with?

We work with many third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data:

5. International Transfers

International Transfers mean that personal data is transferred to a country outside the European Union.

As set out in Section 4 above, we may allow access to your personal data to third parties who may be located outside the European Union.

We may also disclose your personal data if we receive a legal or regulatory request from a foreign law enforcement body outside the European Union.

We will always take steps to ensure that any international transfer of information is managed to protect your rights and interests. Any requests for information that we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.

You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us (see Section 8) if you wish further information.

6. Direct Marketing

We will use your personal data to send you direct marketing communications regarding products and services what we sell or promote in our site superflies.com.

In some cases our processing of your personal data for marketing purposes will be based on our legitimate interests (see Section 3 above). When required by law it will be based on your consent.

You always have a right to say no to further direct marketing, at any time. You can use the opt-out link that you find in all direct marketing communications, or by contacting us (see Section 8).

We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications that we believe may be of interest or relevance to you, based on the information we have about you.

7. How long do we keep your personal data?

We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 3 of this Policy.

In some circumstances we keep your personal data during a certain period to meet for example legal, tax or accounting requirements.

We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.

8. What are your rights?

You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below.

To exercise your rights you may contact us as by sending an email to [email protected]

Please note the following if you wish to exercise your rights:

Access

You can ask us to:

Rectification

You can ask us to rectify inaccurate personal data.

We may seek to verify the accuracy of the data before rectifying it.

Erasure

You can ask us to erase your personal data, but only where:

We are not required to comply with your request to erase your personal data  if the processing of your personal data is necessary:

There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.

Restriction

You can ask us to restrict (i.e. keep but not use) your personal data, but only where:

We can continue to use your personal data following a request for restriction, where:

Portability

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format,  or you can ask to have it ‘ported’ directly to another Data Controller, but in each case only where:

Objection

You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

International Transfers

You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area.

We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.

Supervisory Authority

You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

9. Cookie Policy – Appendix A

We use Cookies

To offer you a full range of functions when you visit our website, recognize your preferences, and make the use of our website more comfortable and convenient, we use “cookies.”

What are Cookies?

A cookie, pixel or similar technology is a small file or information saved on your computer or device when you visit the website. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Your options

By using our website, you agree to the use and storage of cookies on your computer or device.

You can generally view our website without cookies, but certain parts of the website may not work properly or navigating be slower.

If you do not wish cookies to be stored on your computer or device, you can deactivate the relevant option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser at any time.

More information on how to deactivate or delete cookies can be found here: https://www.aboutcookies.org/cookie-faq/. However, please keep in mind that if you do not accept any cookies this may restrict the functionality of our offerings.

Categories of cookies

We use cookies for different purposes and with different functions.

Some cookies are:

Technical necessity

Cookies that are technically:

Storage duration

Session cookies: Some cookies are only needed for the duration of your website session, so called “session cookies”. They will be erased or become invalid as soon as you leave our website or your current session expires. Session cookies are used, for example, to retain certain information during your session.

Permanent cookies: Some cookies are stored for a longer period. For example, it allows to recognize you when you access our website again at a later time and access saved settings. As a result, you can access webpages faster or with greater convenience, for example, that you do not need to set certain options again, such as your chosen language. Permanent cookies are automatically deleted after a predefined period.

Flow cookies: These cookies are used for communication between our internal servers within our company group. They are placed on your computer or device when you start navigating the website and deleted after the end of your navigation on the website. Flow cookies are given a unique identification number but does not allow us to draw any conclusions regarding the actual customer or user.

Cookie providers

Provider cookies: These are cookies are placed by us or the operator of our website, who is commissioned by us.

Third-party cookies: “Third-party cookies” are stored and used by other organisations or websites, for example, Web analytics tools. External providers may also use cookies to display advertising or to integrate content from social networks, such as social plugins. For further information on Web analytics tools and measurement of reach, please see below in this cookie policy.

Use of cookies for Web analytics and reach measurement

We use Google Analytics, a Web analytics service of Google Inc. (“Google”). Google Analytics uses cookies to identify the frequency of use of certain areas of our website and to identify preferences. The information regarding your use of this website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the website, compile reports on website activity for us, and perform further services associated with website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent third parties process these data on behalf of Google.

You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here

This add-on stores “opt-out” information on your device that serves to match up your deactivation of Google Analytics. Please note that this kind of “opt out” only leads to the deactivation of Google Analytics for the device and browser from which the opt out was activated. In addition, you may need to reactivate it if you delete cookies from your device.

Our most common cookies are:

Name of cookieCookie providerPurpose
Google AnalyticsGoogleThis Cookie is placed by Google. It enables our website to learn information about our users’ use of our site, such as the time of visit, the pages viewed, whether the user has visited before and the websites visited prior to visiting ours.
Facebook PixelFacebookThis Cookie is placed by Facebook. It enables our website to measure, optimize and build audiences for advertising campaigns served on Facebook.
HotjarHotjarThis Cookie is placed by Hotjar. It collects non-personal information, with the overall aim of providing you with a better website experience, diagnose technical problems and analyze trends.
AdWordsAdWordsAdWords is used to enable Google PPC (pay per click) campaigns.
Double ClickDouble ClickDouble Click is used for advertisers and to advertise on multiple ad servers.