Fishagora Privacy Policy
Date last updated: 08-01-2022
When it comes to your personal data, safety and transparency take top priority here at Fishagora. To help
you understand what information we collect about you, how we use it and what rights you have, we’ve
prepared this detailed Privacy Policy.
1. General
This Privacy Policy applies to the online platform Fishagora (“Website”) and to the associated app (“App”)
(the Website and the App are jointly referred to as the “Platform”) intended for United States users.
The Platform is operated by Fishagora LLC., a company registered in Connecticut, with business location
at 201 West High St B16, East Hampton, CT 06424. The operator is further referred to as “We”, “Us” or
“Fishagora”. More details about how to get in contact with us can be found at the end of this Privacy Policy
under No. 7.
We take your privacy extremely seriously. All personal data will be collected, stored and used by us in
accordance with the European Union General Data Protection Regulation No. 2016/679 (“GDPR”) and/or
other applicable statutory regulations.
If you are a California resident, please see our
The services offered by us via the Website and/or App can function only if we collect, store, transfer, delete
and/or otherwise use (“collect and use”) specific data relating to you (“personal data” or “data”). Personal
data means all information relating to an identified or identifiable natural person such as your name, date of
birth, address, or email address.
This Privacy Policy describes what type of data we collect from you and for what purposes we collect and
use it when you use the services offered by Us on the Platform. This Privacy Policy also contains important
information on the protection of your data, especially the statutory rights you have in connection with it.
Certain services on our Platform are offered by third-party suppliers. When you use these services, the data
protection regulations that govern third-party suppliers will then apply in addition to this data protection
statement. Prior to your use of such services, the third-party suppliers may require you to provide
permission under the data protection law.
Under applicable data protection laws, Fishagora is obligated to inform you about data processing and
Fishagora fulfills this obligation within this Privacy Policy. This Privacy Policy and any parts of it are not
meant as contractual clauses and do not form part of the general terms and conditions (“GTC”) as a
contract that is concluded with registered users. Under applicable data protection laws, Fishagora can
process data that is necessary for the fulfillment of a contract with you or necessary for taking steps at your
request prior to entering into a contract (Art. 6 (1) (b) GDPR). References to the GTC should always be
understood as information on data processing (Art. 13 and 14 GDPR) and never as clauses that form part of
the GTC. By using the Platform and our services, you enter into a legally binding contract between you and
Fishagora, the conditions of which are described in the GTC.
2. Why and how do we collect and use your personal data?
2.1. To enable you to use the Platform, allow us to provide our services and perform our GTC
We collect and use your personal data to allow you to use our Platform, to provide our services and to
fulfill a contract (GTC) with you and above all, to carry out commercial transactions via the Platform, to
use the electronic payment system or to leave reviews and communicate with other members. To use these
services, you need a Fishagora account. For this purpose, you must register as a member on the Website or
App.
Most of your personal data is required to fulfill a contract (GTC) with you. If you do not provide us with
this personal data, we will not be able to enter into and fulfill a contract (GTC) with you. A portion of your
data is required to fulfill our legal obligations when you become a member of our Platform. If you do not
provide us with this personal data, we will not be able to comply with legal requirements or provide our
services.
This data is also used for improvement of the Platform in order to enhance user experience for our
members (see 2.2.12).
We collect and use your personal data for these purposes until your Fishagora account is deactivated or
inactive for five (5) years.
2.1.1. To enable registration on the Platform
2.1.2. To authenticate your identity via Google, Facebook or using an Apple ID
2.1.3. To enable you to set up your profile information
2.1.4. To show other members relevant information regarding your activity on the Platform
2.1.5. To enable you to list your items
2.1.6. To enable notifications on the Platform for you
2.1.7. To enable you to communicate with other members
2.1.8. To enable you to leave reviews for other members on the Platform
2.1.9. To receive reviews from other members
2.1.10. To enable you to post in the forum and discuss with our community
2.1.11. To send you important communication regarding the Platform
2.1.12. To send you offers via the Platform’s messaging system
2.1.13. To provide you with customer support service
2.1.14. To resolve any purchase-related disputes between members
2.1.15. To temporarily retain your deactivated account
2.2. To improve your experience when using the Platform
We collect and use your personal data in order to improve your experience when using the Platform by
enabling you to personalize your feed and search results, providing you relevant suggestions and storing
your previous searches, sending you notifications and otherwise making the use of Platform more pleasant.
Specific applicable legal basis for the collection and use of your data is described in each section below.
2.2.1. To enable your preferences regarding your feed and search results
2.2.2. To personalize your feed and search results
2.2.3. To prioritize high value items for sale by reputable sellers
2.2.4. To recommend relevant items to you
2.2.5. To improve search results on the Platform
2.2.6. To save your recent searches
2.2.7. To help you draw more attention to your listings
2.2.8. To suggest a price upon creation of an item listing
2.2.9. To enable notifications about your favorite items
2.2.10. To notify sellers when you favorite their items
2.2.11. To allow you to follow other members
2.2.12. To improve our Platform
2.2.13. To conduct surveys
2.2.14. To conduct interviews
2.2.15. To enable you to share your user journey
2.2.16. To enable automatic content translation
2.3. To ensure the security of your account and the Platform
Fishagora strives to ensure that our member accounts and the Platform itself are secure and protected from
cyber-attacks, unauthorized access and other similar risks.
2.3.1. To track visits to the Platform for security purposes
2.3.2. To help you avoid using a compromised password
2.3.3. To allow you to reset your password
2.3.4. To verify your account in case of suspicious activity related to your account
2.3.5. To conduct phone number and two-step verifications
2.3.6. To carry out payment source security checks
2.3.7. To carry out PayPal account security checks
2.3.8. To ensure listing compliance with our Authenticity Policy
2.3.9. To carry out account ownership checks
2.3.10. To allow you to report inappropriate behavior or content
2.3.11. To report suicidal posts
2.4. To supervise compliance with and enforce GTC
Fishagora actively supervises compliance with and enforces GTC for the purpose of ensuring the security
of your account and that of the Platform.
2.4.1. To calculate the trust score
2.4.2. To enforce spam filtering
2.4.3. To moderate your activity on the Platform
2.4.4. To issue and enforce warnings
2.4.5. To delete or hide items that violate Fishagora GTC
2.4.6. To detect and lock compromised accounts
2.4.7. To suspend members
2.4.8. To enforce bans
2.4.9. To enforce IP blocks
2.5. To enable your payment for items
Payments made on the Platform are carried out via payment service providers that offer payment
processing and escrow services.
Most of your personal data is required to fulfill a contract (GTC) with you. If you do not provide us with
this personal data, we will not be able to enter into and fulfill a contract (GTC) with you (Art. 6 (1) (b) of
the GDPR). Part of your data is required to fulfill our or our payment service providers’ legal obligations
when you are a member of our Platform (Art. 6 (1) (c) of the GDPR). If you do not provide us with this
personal data, we or our payment service providers will not be able to comply with legal requirements nor
will we be able to provide our services.
This data is also used for improvement of the Platform in order to make it a better experience for our
members (see 2.2.12).
2.5.1. To allow you to make a purchase or add a payment card for payment purposes
2.5.2. To allow you to add a bank account for withdrawal purposes
2.5.3. To enable you to pay and receive payments on our Platform
2.5.4. To implement Know Your Customer (KYC) checks on our Platform
2.5.5. To issue refunds
If you purchase an item and it is never shipped, arrives damaged or is not as described and you issue a
claim, we collect and use the data used to make a purchase (see 2.5.3 and 2.5.4) for the purpose of issuing a
refund.
Legal basis for the collection and use of data is the fulfillment of a contract (GTC) to which you are party
(Art. 6 (1) (b) of the GDPR).
Personal data is required to fulfill a contract (GTC) with you. If you do not provide us with this personal
data, we will not be able to enter into and fulfill a contract (GTC) with you.
Transaction data is kept for 13 months from the day of transaction.
2.5.6. To keep financial records
2.6. To enable shipment of items purchased on the Platform
Fishagora strives to make the shipping of items purchased on the Platform as smooth and convenient as
possible by offering shipping methods on the Platform.
Most of your personal data is required to fulfill a contract (GTC) with you. If you do not provide us with
this personal data, we will not be able to enter into and fulfill a contract (GTC) with you.
This data is also used for improvement of the Platform in order to make it a better experience for our
members (see 2.2.12).
2.6.1. To enable you to ship or receive items
2.6.2. To track your parcel
2.7. To carry out marketing activities
Fishagora seeks to involve our members in marketing campaigns that benefit our members. At the same
time, we wish to present you with marketing material that is both relevant and engaging.
2.7.1. To send you marketing emails
2.7.2. To personalize marketing messages
2.7.3. To contact you for publicity and/or earning opportunities
2.7.4. To conduct advertisement campaigns involving you
2.7.5. To enable us to post your content on our social media accounts
2.7.6. To allow you to see personalized advertisements
Information is collected for this purpose by advertising service partners and is not stored by Fishagora.
2.7.7. To evaluate efficiency of promotional campaigns
2.7.8. To manage our social media profiles
2.7.9. To enable you to participate in Fishagora’s referrals program
2.8. For legal purposes
2.8.1. To handle your requests related to personal data
2.8.2. To provide information to law enforcement and other state institutions
2.8.3. To defend our rights against chargebacks
2.8.4. To defend the rights and interests of Fishagora
3. Personal data recipients
Fishagora transfers or shares personal data with service providers only insofar as necessary and allowed in
accordance with applicable laws. Service providers to which your personal data is transferred or with
whom it is shared for specific purposes are described under 2 above. In addition, we appoint the following
service providers who, as a result, receive personal data as data recipients.
We perform ongoing technical maintenance and upgrades to the Platform to protect the security and
confidentiality of personal data we process and to perform certain business-related functions that help make
our services available and functional. For this reason, we transfer your profile data to service providers who
provide cloud and hosting services, IT security, maintenance and technical services, and communications
services.
The following service providers are established outside the European Economic Area, which may result in
your data being transferred outside the European Economic Area. In these cases the personal data is
protected by the service providers entering into the EU standard contractual clauses for the transfer of data
as approved by the European Commission:
1. Amazon Web Services, Inc. (USA);
2. Google LLC (USA);
3. Apple Inc. (USA);
4. Microsoft Corporation (USA);
5. Slack Technologies, Inc. (USA);
6. BlackLine Systems, Inc. (USA);
7. Chronicle, LLC (USA);
8. True Partners Consulting, LLC (USA);
9. Arcaris, Inc. (USA);
10. Havas Edge, Inc. (USA).
We transfer personal data to attorneys, attorney assistants, notaries, bailiffs, auditors, accountants,
bookkeepers, debt collectors, consultants, translation agencies, IT service providers, insurance companies,
and archiving services that provide services to Fishagora.
Additionally, we share data within the Fishagora group. Data processed within the Fishagora group is
transferred to Fishagora, UAB (Lithuania) insofar as necessary for the management of Fishagora group.
Fishagora is legally obligated to provide personal and/or usage data to investigative, criminal prosecution
or supervisory authorities if and to the extent required to prevent risk to the public and for the prosecution
of criminal acts.
Fishagora may share your data with third parties when transferring rights and obligations pertaining to the
contractual relationship between you and Fishagora to such third parties in accordance with the GTC. in
particular in the event of the transfer of a business sector, a merger by way of the creation of a new
company, a merger by way of absorption, a de-merger or any changes in control affecting Fishagora.
4. Use of cookies
Fishagora uses cookies and similar technologies on the Platform. You can find out more by visiting our
Cookie Policy.
5. Right of amendment
As our services are constantly evolving, we reserve the right to change this Privacy Policy at any time
subject to the applicable regulations. Any changes will be published promptly on this page. You should,
nevertheless, check this page regularly for any updates.
6. Your statutory rights regarding your
personal data
If you are a California resident, please see our California policy regarding the rights you have under
California law and how to exercise them.
Subject to conditions, limitations, and exceptions established by statutory data protection provisions, you
have the right at any time:
ï‚· to be informed of the data we collect and use and to request access or demand a copy of the data
concerned (right to access). You can access any data you actively provided us on the Platform
(2.1, 2.5 and 2.6) at any time through your Fishagora account;
ï‚· to demand the correction of inaccurate data and, subject to the nature of the collection and use, the
completion of incomplete data (right to rectification). You can also amend any of the data that you
have actively provided us on the Platform (2.1, 2.5 and 2.6) at any time through your Fishagora
account (except sent messages and any forum posts or reviews);
ï‚· subject to just cause, to demand the deletion of your data (right to deletion);
ï‚· to demand that the collection and use of your data be restricted, provided the legal criteria are met
(right to restrict processing);
ï‚· subject to the legal criteria being met, to receive the data you have provided in a structured,
current and machine-readable form and to transfer this data to another data controller or, when
technically feasible, to have it transferred by Fishagora (right to data portability);
ï‚· to object to the collection and use of data – only where the collection and use is based on a task
carried out in the public interest or in the exercise of a vested official authority (Art. 6 (1)(e) of
GDPR) or legitimate interest (Art. 6 (1)(f) of GDPR), including profiling, based on the same data
collection and use grounds as explained in other sections of this statement (right to object). You
also have the right to object to the collection of your personal data for direct marketing purposes at
any time;
ï‚· to revoke any permission, you have granted us at any time. Such revocation will not affect the
legality of collection and use carried out prior to the revocation and is based on the permission
granted. You can revoke your permission to receive our newsletter by changing your Fishagora
account settings to block the receipt of any further Marketing Emails. Alternatively, you can click
"Unsubscribe" at the end of the Marketing Email;
ï‚· not to receive discriminatory treatment while exercising your rights.
To exercise any of the rights specified in this section, you can contact Fishagora and submit your request
using the contact information (7 below).
7. Our contact details
If you have any questions regarding the collection and use of your data as part of your use of the Platform,
or regarding your rights, please contact our data protection officer at fishagorallc@gmail.com
Fishagora data protection officer:
Fishagora LLC
201 West High St
East Hampton, CT 06424
USA
California Policy
This Privacy Policy applies to the online platform Fishagora.com (“Fishagora”) and to the associated app
(“App”) (jointly "Platform") operated by Fishagora, Inc. (“Us”, “We” or “Fishagora”). We are committed
to maintaining your confidence and trust as it relates to the privacy of your information. This privacy policy
is for our members, users and website visitors who are California residents (this "California Privacy
Policy") and supplements the information contained in Our Privacy Policy.
I. Overview of this California Privacy Policy
What is this California Privacy Policy? The California Consumer Privacy Act of 2018 ("CCPA") and other
privacy laws in California give California consumers certain privacy rights related to their personal
information. These rights are in addition to any privacy rights set forth in the Fishagora Privacy Policy.
This California Privacy Policy describes the rights that California consumers may have under the CCPA.
What is "personal information"? For the purposes of this California Privacy Policy, "personal information"
is defined as information that identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular California consumer or
California household. Personal information does not include:
1. Publicly available information from government records.
2. De-identified or aggregated information.
What are "California consumers"? A "California consumer" is a natural person who resides in California.
For the purposes of this California Privacy Policy, a California consumer does not include persons to the
extent they are (i) acting as an employee, owner, director, officer or contractor of a company, partnership,
sole proprietorship, nonprofit or government agency that is doing business with Fishagora or (ii) acting as a
job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of
Fishagora.
II. How we collect, use, and share personal information
Fishagora may collect personal information from you in different ways and for different purposes. It is
important to note that the types of personal information we collect will depend on your interaction with Us,
including the types of products or services you use.
This section contains the categories of personal information that we may have collected in the last 12
months and for each category of personal information, the categories of third parties with whom personal
information is shared or sold for a business purpose:
1. Identifiers such as a name, postal address, unique personal identifier, online identifier, email address,
account name, or other similar identifiers
2. Demographic information, including characteristics that may be protected by law such as gender or age
3. Commercial information, including purchasing history and shipping history
4. Internet or other electronic network activity information, such as the data we receive when you interact
with our Website
5. Audio, electronic, visual, or similar information, such as photographs or voice recordings
6. Geolocation data, such as information we receive about your device location (e.g., based on your IP
address)
We obtain the categories of personal information listed above from the following categories of sources:
1. From you directly (e.g., when you register as a member on the Platform, if you enter your Google
or Facebook log-in details, when you list items on the Platform, when you communicate with
other members, and if you send us query, request or complaint)
2. Information we generate about you in the course of our relationship with you
3. Directly and indirectly from your activity on the Platform (e.g., Platform usage information
collected automatically)
4. From third-parties suppliers that interact with us in connection with the services they provide.
5. From our affiliated businesses
We may use your personal information for the following purposes:
1. To enable you to use the Platform, allow us to provide our services and perform our terms and
conditions of use ("GTC"). We collect and use your personal data to allow you to use our
Platform, to provide our services and to fulfill a contract (GTC) with you and especially to
undertake commercial transactions via the Platform, to use the electronic payment system or to
leave reviews and communicate with other members.
2. To improve your experience when using the Platform. We collect and use your personal
information in order to improve your experience when using the Platform by enabling you to
personalize your feed and search results, providing you relevant suggestions and keeping your
previous searches, sending you notifications and otherwise making the use of the Platform more
pleasant.
3. To ensure the security of your account and the Platform. Fishagora strives to ensure that the
accounts of our members and the Platform itself would be secure and protected from cyber-
attacks, unauthorized access and other related risks.
4. To supervise compliance with and enforce our GTC. Fishagora actively supervises compliance
with and enforces the GTC for the purpose of ensuring the security of your account and the
Platform.
5. To enable your payments for items. We collect and use your personal information in order to for
example, allow you to make a purchase and add a bank card for payment purposes or to add a
bank account for withdrawal purposes.
6. To enable shipment of items purchased on the Platform. We collect and use your personal
information in order to enable you to ship or receive items.
7. To carry out marketing activities or track your parcel. We collect and use your personal
information in order to engage in marketing activities such as sending you marketing emails or to
enable us to post your content on our social media accounts.
8. For legal purposes. We may collect and use your personal information in order to comply with
applicable law.
Sale of Personal Information to Third Parties
We may have sold the following categories of personal information about you to third parties in the prior
twelve (12) months: Internet or other electronic network activity information such as consumer online
activity, for example, browser type, IP address, device ID, advertising identifiers and cookie numbers, to
online advertising service and analytics providers.
We do not knowingly sell the personal information of minors under the age of 16.
III. CCPA rights for California consumers
The CCPA provides California consumers with certain rights regarding their personal information. This
Section explains those rights. If you are a California consumer and would like to exercise any of those
rights, please see below (How to Submit a Request) below for more information on how to submit a
request.
IV. Contact us; exercise your rights
If you have any questions or concerns regarding this California Privacy Policy or our privacy practices,
please contact Us using one of the methods provided below:
By email at: fishagorallc@gmail.com
By mail to: Fishagora : 201 West High St, East Hampton CT 06424 USA
V. Changes to the notice
If we update this California Privacy Policy, we will notify you by posting a new Policy on this page and
will identify the date of update.