1. WHO ARE WE? UAB “Debesų verslas” also known as “Tellq” , Legal entity code 304249354, VAT Number LT100010926112, postal address Baltupio 14, Vilnius, Lithuania, email address info@tellq.io, the phone number +370 61436492, website address https://tellq.io/ 2. PERSONAL DATA WE COLLECT When you use our Software Services we collect personal data about you, described below. The term “Personal Data” means any data that enables a person or a company to be identified. Personal Data that you provide to us. We collect Personal Data that you provide to us when you buy our Services and register for a tellq.io account, such as your family name, first name, postal address, email address, telephone numbers. 3. SPECIFICATIONS OF PERSONAL DATA WE COLLECT We have divided different personal data that We process into distinct categories based on the purposes for which the data is processed and the categories of the data subjects (see below). Personal data of our employees which is processed: name and surname, personal identification number, date of birth, address, phone number, email address, qualifications, skills, information about income received from Tellq (salary, bonuses, etc.).
Personal data of employees of our clients and partners which is processed: name and surname, data regarding employer, personal and/or work email address and personal and/or work phone number, information about the competencies of partners’ employees. Personal data of job applicants which is processed: name and surname, date of birth, age, address, phone number, email address, data regarding employer, work experience, past employers and job titles, education, qualifications, skills, driving licence information, hobbies, additional information voluntarily provided by applicants in their CV, data obtained during the selection process (applicant evaluation). Personal data of information related to direct marketing activities which is processed: name and surname, phone number, email address, employer data including address of employer. 4. SPECIFICATIONS OF PERSONAL DATA WE DO NOT COLLECT We do not collect the sensitive personal data, such as: data related to your racial or ethnic origin, political, philosophical, religious or other convictions, membership in unions, health or sex life, information about criminal records.
5. WHY DO WE COLLECT YOUR PERSONAL DATA AND ON WHAT BASIS? We process your personal data to the extent it is necessary to achieve the purposes We have established. We process the personal data of our employees and of employees of our clients and partners for purposes of internal administration, on the basis of our legitimate interest. We may also process the personal data of clients’ (including potential clients) and partners’ employees for the purpose of entering into and performing agreements and in order to enter into and properly perform agreements/undertakings of Tellq, also on the basis of our legitimate interest. We process employees’ personal data for the purpose of entering into, performing and accounting for employment agreements, for purposes of properly performing our legal obligations as an employer, for the purpose of maintaining proper communication with employees, and for other purposes of internal administration, and the entry into and performance of car loan agreements with employees of Tellq. We process the personal data of job applicants in order to select the best-suited applicants for employment, and later, with your consent, for purposes of keeping a database of Tellq applicants.
We process the personal data of recommended potential applicants in order to suggest to potential applicants that they apply for open job positions at Tellq. We process this data on the basis of the consent of the person concerned. Note that when a recommendation provider recommends a potential applicant and provides Us with that person’s personal data, the recommendation provider is obliged to notify the potential applicant about such provision of data to Us and to obtain their consent for it. We process the personal data of recommendation providers for the purpose of giving rewards for successful recommendations, in order to meet our obligations. We process the personal data of persons who send queries via our website(s) or general email address for the purpose of administering the queries and providing responses to them. Persons who submit a query consent to the processing of their personal data in the manner set out in this Policy. We process the personal data of information recipients related to direct marketing activities in order to conduct direct marketing, including but not limited to sending newsletters, offering Tellq services by phone and extending invitations to participate in events that We organise. We process such data on the basis of your consent or our legitimate interest. You may at any time to revoke your consent or object to the use of your data for direct marketing purposes as detailed below in this Policy.
6. TO WHICH PARTIES DO WE TRANSFER YOUR PERSONAL DATA? We may only disclose your personal data when there is a lawful basis (for example, when that is required by law or an agreement that has been made or We have your specific consent). Such information shall be disclosed in keeping with the applicable laws and regulations of the Republic of Lithuania. We give assurance that We will not transfer your personal data to any third parties except where that is required in order to realise the above-specified purposes. To accomplish those purposes, we responsibly select the service providers who provide us with maintenance and administrative services, who supply and administer the software and systems we use (e.g., financial accounting software), and who provide other necessary services (data processors who process personal data according to our instructions). Note that Tellq may make use of data processors who operate and who may process your data in third countries (such as UK or USA). In such cases, Tellq will make every effort to ensure the protection of your personal data as stipulated by the applicable legislation. 7. PERSONAL DATA PROTECTION We take suitable technical and organisational measures to ensure the protection of your personal data from accidental or unlawful destruction, loss or modification, and from unauthorised disclosure or access.
8. FOR WHAT PERIOD OF TIME DO WE KEEP YOUR PERSONAL DATA? We store your personal data no longer than is required by the purposes for which the personal data is processed. We retain the personal data of our employees and the employees of our clients (including potential clients) and partners for 10 (ten) years, but always at least until the conclusion of the corresponding agreement with a client or partner. We keep the personal data of employees for 5 (five) years from the end of an employee’s employment ties with Tellq, but always at least as long as is required by the applicable legislation. We retain the personal data of recommended potential applicants and recommendation providers for 5 (five) months. We retain the personal data of persons who send queries via our website(s) or general email for 3 (three) years. We retain the personal data of information recipients related to direct marketing for 5 (five) years.
9. CUSTOMER’S RIGHTS You have the right to get acquainted with your personal data which Tellq possesses and to be informed about what personal data has been collected, for what purpose it is processed, and to whom it is provided. You can submit a request by email to info@tellq.io If in reviewing your personal data you determine that it is incomplete, incorrect or inaccurate and you wish to correct it or you wish for Us to discontinue processing of the personal data, you can submit a request by email to info@tellq.io If in reviewing your personal data you determine that it is being processed unlawfully or unfairly or if there are other legal grounds, you can submit a request by email to info@tellq.io To the extent provided by applicable laws You are entitled to request your personal data to be deleted from Tellq systems. You can submit a request by email to info@tellq.io. 10. Facebook Platform Terms 1. Introduction a. Our Platform is the set of APIs, SDKs, tools, plugins, code, technology, content, and services that enables others, including app developers and website operators,
to develop functionality, retrieve data from Facebook and any other Facebook Products, or provide data to us. b. To use Platform (including to Process any Platform Data), you agree to these Platform Terms (“Terms”), as well as all other applicable terms and policies. This may include the Facebook Terms of Service, the Instagram Terms of Use, the Facebook Commercial Terms, the Business Tools Terms, and any Facebook Product terms that are applicable. c. You must also comply with the applicable requirements in our Developer Policies and those made available on our Developer Site, including in our Documentation collectively, the “Developer Docs”) d. These Terms will start on the earlier of the date you accept them or otherwise start accessing or using Platform, and will continue until you stop accessing and using Platform, unless ended earlier as described below. If you are accepting these Terms or accessing or using Platform on behalf of an entity, you represent and warrant that you have the authority to bind such entity to these Terms and you agree on behalf of such entity to be bound by these Terms (and for clarity, all other references to “you” in these Terms refer to such entity). For clarity, these Terms updated and replaced the Facebook Platform Policy and the Instagram Platform Policy and any references in existing terms, policies, or agreements to the “Facebook Platform Policy,” “Instagram Platform Policy,” or “Platform Policy” shall now mean these Terms. e. If you fail to comply with these Terms or any other applicable terms or policies, we may suspend or terminate your App or account, as described below. f. Capitalized terms not otherwise defined herein (including in Section 12 (“Glossary”) have the meaning given in our other terms and policies, including our Terms of Service and our Facebook Commercial Terms. The term “including” means “including without limitation.” 2. Intellectual Property Rights
a. Our License to You. Subject to your compliance with these Terms and all other applicable terms and policies, we grant you a limited, non-exclusive, non-sublicensable (except to Service Providers as described below), non-transferable, non-assignable license to use, access, and integrate with Platform, but only to the extent permitted in these Terms and all other applicable terms and policies. You will not sell, transfer, or sublicense Platform to anyone. Except as expressly licensed herein, you will not use, access, integrate with, modify, translate, create derivative works of, reverse engineer, or otherwise exploit Platform or any aspect thereof. The Facebook Companies reserve all rights, title, and interest (including the right to enforce any such rights) not expressly granted in these Terms. b. Your License to Us i. Your Content: 1. You grant us a non-exclusive, transferable, sublicensable, royalty-free, worldwide license to: host, use, distribute, modify, run, copy, publicly perform or display, translate, and create derivative works of any information, data, and other content made available by you or on your behalf (including by your Service Providers or through your App) in connection with Platform (collectively, “Your Content”) for any business purpose in connection with operating, providing, or improving Platform or any other Facebook Product. This license remains in effect even if you stop using Platform. Without limitation, your license to us includes: the right to incorporate Your Content into other parts of Facebook Products, the right to attribute the source of Your Content using your name, trademarks, or logos; the right to use Your Content for promotional purposes, and the right to analyze Your Content (including to make sure you’re complying with these Terms and all other applicable terms and policies). 2. If you use the Facebook Business Tools to send us Business Tool
Data, our use of that data is governed by the Business Tools Terms rather than the foregoing license for Your Content. 3. If you owned Your Content before providing it to us, you will continue owning it after providing it to us, subject to any rights granted in these Terms or any other applicable terms or policies and any access you provide to others by sharing it via Platform. ii. Your App: 1. You grant us a non-exclusive, transferable, sublicensable, royalty-free, worldwide license to: host, use, distribute, modify, run, copy, publicly perform or display, translate, and create derivative works of your App for any business purpose in connection with operating, providing, or improving Platform. This license remains in effect even if you stop using Platform. Without limitation, the foregoing license includes the right to frame or link to your App, to place content (including ads) around your App, and to analyze your App (including to assess your compliance with these Terms and all other applicable terms and policies). 2. As between the parties, in connection with Platform, we won’t be subject to any terms or policies associated with your App or Your Content (even if we click or tap agreement). Those terms and policies are considered null and void and are rejected and excluded from these Terms. 3. Nothing in these Terms will be interpreted as a representation or agreement that we will not develop or have not developed apps, products, features, or services that are similar to your App or compete with your App. iii. Your Name, Trademarks, and Logos: You grant us a non-exclusive,
transferable, sublicensable, royalty-free, worldwide license to use your name, trademarks, and logos for distribution, marketing, and promotional purposes, in connection with your use of Facebook Products, in all formats and media. This license remains in effect for existing materials and instances even if you stop using Platform. c. Protecting the Rights of Others i. You will not provide or promote content in your App that infringes upon or otherwise violates the rights of any person or third party. ii. You will obtain (and represent and warrant that you own or have secured) all rights necessary from all applicable rights holders to (1) grant the licenses, rights, and permissions in these Terms (including those in Section 2.b (“Your License to Us”)); (2) display, distribute, and deliver all information, data, and other content in your App; and (3) otherwise operate your App. This includes satisfying all licensing, reporting, and payout obligations to third parties. iii. If your App contains content submitted or provided by your Users or other third parties, you must have an appropriate notice and takedown process and otherwise comply with all applicable laws and regulations to respond to notices of claimed infringement. Without limiting that compliance, in the United States, you must comply with all requirements of the Digital Millennium Copyright Act. 3. Data Use a. Prohibited Practices. You will not perform, or facilitate or support others in performing, any of the following prohibited practices (collectively, “Prohibited Practices”): i. Processing Platform Data to discriminate or encourage discrimination
against people based on personal attributes including race, ethnicity, color, national origin, religion, age, sex, sexual orientation, gender identity, family status, disability, medical or genetic condition, or any other categories prohibited by applicable law, regulation, or Facebook policy. ii. Processing Platform Data to make eligibility determinations about people, including for housing, employment, insurance, education opportunities, credit, government benefits, or immigration status. By eligibility determinations, we mean determining whether to provide, deny, or take away a particular benefit (for example, housing or scholarships) as well as determining the terms under which the benefit will be provided, denied, or taken away. iii. Processing Platform Data to perform, facilitate, or provide tools for surveillance. Surveillance includes the Processing of Platform Data about people, groups, or events for law enforcement or national security purposes. iv. Selling, licensing, or purchasing Platform Data. v. Placing Platform Data on, or otherwise making Platform Data available to, a search engine or directory without our prior express written consent. vi. Attempting to decode, circumvent, re-identify, de-anonymize, unscramble, unencrypt, or reverse hash, or reverse-engineer Platform Data that is provided to you. vii. Changing your App’s core functionality or data Processing so that Users would view it as an unfamiliar or different App, or materially changing the scope of Processing of previously collected Platform Data, unless in each case you first re-submit your App and receive our approval through App Review. viii. Processing friend lists from Facebook to establish social connections in
your App unless each person in that connection has granted you access to that information for that purpose. b. Additional Terms for Restricted Platform Data i. You will not request Restricted Platform Data unless it is necessary to meaningfully improve the quality of the applicable User's experience in the specific product or service for which the User shared the data. ii. It must be clear to the User why you are requesting their Restricted Platform Data in order to improve the quality of their experience. iii. For clarity, your Processing of Restricted Platform Data must comply with the applicable Developer Docs and other provisions of these Terms (including the Prohibited Practices). c. Sharing Platform Data. You may only share Platform Data in compliance with these Terms (including Sections 3.a (“Prohibited Practices”), 3.b (“Additional Terms for Restricted Platform Data”), 4 (“Privacy Policy”), and 5 (“Service Providers and Tech Providers”)), applicable law and regulations, and all other applicable terms and policies, and only in the following circumstances: i. With respect to Platform Data collected as a Tech Provider, solely as described below in Section 5.b (“Tech Providers”); ii. With respect to Platform Data not collected as a Tech Provider, 1. when required under applicable law or regulation (you must retain proof of the applicable legal or regulatory requirement or request and provide it to us if we ask for it); 2. with your Service Provider;
3. when a User expressly directs you to share the data with a third party (you must retain proof of the User’s express direction and provide it to us if we ask for it); or 4. solely with respect to Platform Data that is not Restricted Platform Data, with other third parties, so long as: a. you first contractually prohibit them from using the Platform Data in a way that would violate these Terms or any other applicable terms or policies (you must retain proof of the contractual prohibition and provide it to us if we ask for it); and b. you ensure that any such third parties comply with these Terms and all other applicable terms and policies as if they were in your place, and you are responsible for their acts and omissions, including their noncompliance. d. Retention, Deletion, and Accessibility of Platform Data i. Unless required to keep Platform Data under applicable law or regulation, you must (and must make reasonable efforts to ensure your Service Providers) do the following: 1. Make reasonable efforts to keep Platform Data up to date, including Platform Data that has been modified or deleted. You must update Platform Data promptly after receiving a request from us or the User to do so. You must give Users an easily accessible and clearly marked way to ask for their Platform Data to be modified or deleted.
2. Delete all Platform Data as soon as reasonably possible in the following cases: a. When retaining the Platform Data is no longer necessary for a legitimate business purpose that is consistent with these Terms and all other applicable terms and policies; b. When you stop operating the product or service through which the Platform Data was acquired; c. When we request you delete the Platform Data for the protection of Users (which we will determine at our sole discretion); d. When a User requests their Platform Data be deleted or no longer has an account with you (unless the Platform Data has been aggregated, obscured, or de-identified so that it cannot be associated with a particular User, browser, or device), or for Tech Providers, when a User or the Client requests their Platform Data be deleted or the Client no longer has an account with you; e. When required by applicable law or regulations; or f. As required under Section 7 (“Compliance Review Rights and Suspension and Termination of these Terms”). ii. If you are required to keep Platform Data under applicable law or regulation, you must retain proof of the applicable legal or regulatory requirement or request and provide it if we ask for it. iii. If you have received Platform Data in error, you must immediately
report this to us, delete that Platform Data, and provide proof of deletion if we ask for it. e. Exceptions to Restrictions. The above provisions of this section (Section 3.a-d) do not apply to certain Platform Data as described here. 4. Privacy Policy a. If you use Platform to Process Platform Data, you will provide and comply with a publicly available and easily accessible privacy policy. b. This policy must comply with applicable law and regulations and must accurately and clearly explain what data you are Processing, how you are Processing it, the purposes for which you are Processing it, and how Users may request deletion of that data. c. You may only Process Platform Data as clearly described in your privacy policy and in accordance with all applicable law and regulations, these Terms, and all other applicable terms and policies. d. Your privacy policy will not supersede, modify, or be inconsistent with these Terms or any other applicable terms or policies. e. You must retain all of your privacy policies in effect while using Platform and provide them to us if we ask for them. f. You will maintain publicly available links to your privacy policies in the privacy policy field in the settings of your App Dashboard, as well as in any App Store that allows you to do so, if applicable, and ensure the links remain current and up to date. 5. Service Providers and Tech Providers
a. Service Providers i. You will not use a Service Provider in connection with your use of Platform or Processing of Platform Data unless such Service Provider first agrees in writing to do the following: 1. Use Platform and Process Platform Data solely for you and at your direction in order to provide services you requested in a manner that is consistent with these Terms, all other applicable terms and policies, and your privacy policy, and for no other individual or entity and for no other purpose, including for the Service Provider’s own purposes; and 2. In the event the Service Provider engages another Service Provider (“Sub-Service Provider”) in order to provide the services requested, ensure the Service Provider requires the Sub-Service Provider in writing to comply with the above requirements. ii. You must ensure that any Service Provider and Sub-Service Provider complies with these Terms and all other applicable terms and policies as if they were in your place, and you are responsible for their acts and omissions, including their noncompliance. iii. When you cease using a Service Provider or Sub-Service Provider, you must ensure they immediately cease using Platform and Processing Platform Data and promptly delete all Platform Data in their possession or control. iv. Upon our request, you must provide a list of your Service Providers and Sub-Service Providers including up-to-date contact information for each, the types and volume of Platform Data shared, and proof of written
agreements with your Service Providers to demonstrate compliance with this Section. v. We may prohibit your use of any Service Provider or Sub-Service Provider in connection with your use of Platform or Processing of Platform Data if we believe that (1) they have violated these Terms or other applicable terms or policies or (2) they are negatively impacting Platform, other Facebook Products, Platform Data, or people who use Facebook Products, and will provide notice to you if we do. Promptly upon such notice, you must stop using that Service Provider or Sub-Service Provider in connection with your use of Platform or Processing of Platform Data. vi. We may require that your Service Providers or Sub-Service Providers agree to these Terms or other applicable terms or policies in order to access Facebook Products, Platform, or Platform Data. b. Tech Providers i. If you are a Tech Provider, you must comply with the other provisions of these Terms, as well as the provisions in this section with respect to your use of Platform and Processing of Platform Data as a Tech Provider. If the terms conflict, the terms that are more restrictive on you or more protective of us apply. ii. You, as a Tech Provider, understand and agree to the following: 1. You will only use Platform and Process Platform Data on behalf of and at the direction of your Client on whose behalf you access it to help such Client to use Platform or Process Platform Data in accordance with these Terms and all other applicable terms and policies (“Client’s Purpose”), and not for your own purposes or another Client’s or entity’s purposes (for example, you will not
Process Platform Data to build or augment user profiles for your own purposes or another Client’s purposes); 2. You will ensure that Platform Data you maintain on behalf of one Client is maintained separately from that of other Clients; 3. You will maintain an up-to-date list of your Clients and their contact information and provide it to us if we ask for it; 4. You will only share Platform Data in compliance with these Terms (including Sections 3a (“Prohibited Practices”), 3b (“Additional Terms for Restricted Platform Data”), and 5a (“Service Providers”)), applicable law and regulations, and all other applicable terms and policies, and only in the following circumstances: a. with your applicable Client, so long as you first contractually prohibit such Client from Processing Platform Data in a way that would violate these Terms or any other applicable terms or policies; b. to the extent required under applicable law or regulation (you must retain proof of the applicable legal or regulatory requirement or request and provide it to us if we ask for it); c. with your Service Provider solely to the extent necessary for your applicable Client’s Purpose; or d. with your Client’s service provider solely to the extent necessary for such Client’s Purpose and when such Client expressly directs you to share the data with such service provider (you must retain proof of the Client’s express direction and provide it to us if we ask for it);
5. We may require that your Clients agree to these Terms or other applicable terms or policies in order to access Facebook Products, Platform, or Platform Data through your App. 6. You will promptly terminate a Client’s use of our Facebook Products, Platform, or Platform Data through your App if we request it because we believe that the Client (a) has violated these Terms or other applicable terms or policies or (b) is negatively impacting Platform, other Facebook Products, Platform Data, or people who use Facebook Products. 6. Data Security a. Data Security Requirements i. You must always have in effect and maintain administrative, physical, and technical safeguards that do the following: 1. Meet or exceed industry standards given the sensitivity of the Platform Data; 2. Comply with applicable law and regulations, including data security and privacy laws, rules, and regulations; and 3. Are designed to prevent any unauthorized (including in violation of these Terms or any other applicable terms or policies) Processing (including, for the avoidance of doubt, access, destruction, loss, alteration, disclosure, distribution, or compromise) of Platform Data. ii. You must have a publicly available way for people to report security
vulnerabilities in your App to you, and you must promptly address identified deficiencies. iii. You must not solicit, collect, store, cache, proxy, or use Facebook or Instagram login credentials of other Users. iv. You must not transfer or share user IDs or your access token and secret key, except with a Service Provider who helps you build, run, or operate your App. b. Incident Reporting i. If any of the following incidents happen, you must promptly, and no later than 24 hours after you become aware of the incident, notify us and provide us with information we request regarding: 1. Any unauthorized (including in violation of these Terms or any other applicable terms or policies) Processing (including, for the avoidance of doubt, access, destruction, loss, alteration, disclosure, distribution or compromise) of Platform Data; or 2. Any incidents that are reasonably likely to compromise the security, confidentiality, or integrity of your IT Systems or your Service Provider’s or Sub-Service Provider’s IT Systems. ii. You must immediately begin remediation of the incident and reasonably cooperate with us, including by informing us in reasonable detail of the impact of the incident upon Platform Data and corrective actions being taken, and keeping us updated about your compliance with any notification or other requirements under applicable laws and regulations. 7. Compliance Review Rights and Suspension and Termination of these Terms
a. App Review. We may require that you submit your App for our review or approval (“App Review”). Whether or not your App (including its access to any Platform Data) is approved (which will be in our sole discretion), you will ensure that your App is compliant with these Terms and all other applicable terms and policies, and we may review your App for such compliance from time to time, in our sole discretion. You will cooperate with our reviews and provide any information we request therefor. We may verify information you provide to us during any such reviews or otherwise in your App dashboard, which you will update to keep it complete and accurate. b. Regular Monitoring. We, or third-party professionals working at our direction (including auditors, attorneys, consultants, and/or computer forensics analysts) (collectively, “Third-Party Auditors”), may conduct regular monitoring of your App and its access to Platform and Processing of Platform Data using technical and operational measures. c. Auditing Rights i. We or Third-Party Auditors may conduct an Audit, no more than once a calendar year unless there is a Necessary Condition, to ensure that your and your App’s Processing of Platform Data is and has been in compliance with these Terms and all other applicable terms and policies. ii. Audits will be conducted during normal business hours after providing you with at least 10 business days’ written notice (email will suffice), unless we determine in our sole discretion a Necessary Condition requires more immediate access. iii. You will cooperate with the Audits, including by (1) providing all necessary physical and remote access to your IT Systems and Records, and (2) providing information and assistance as reasonably requested (including
making your personnel who are knowledgeable about your or your App’s Processing of Platform Data available for our questioning). iv. You will also use commercially reasonable efforts to get permission and cooperation from your Service Providers for us to conduct such Audits with respect to their IT Systems, Records, and applicable personnel. v. You will remedy any non-compliance revealed by an Audit as soon as reasonably practicable (as we determine based on the facts and circumstances), after which we may conduct follow-up Audits to ensure proper remediation of the non-compliance. vi. If an Audit reveals any non-compliance by you or your Service Provider(s) then you will reimburse us for all of our reasonable costs and expenses associated with conducting the Audit and any related follow-up Audits. vii. After these Terms have ended, our Audit rights under this Section will survive until 1 year after the later of when you affirmatively demonstrate that you have stopped Processing all Platform Data and all embodiments thereof that are in your and your Service Providers’ possession or control have been deleted. For the avoidance of doubt, nothing in this Section limits any other rights or remedies we may have by law, in equity, or under these Terms or other applicable terms or policies. d. Certifications. From time to time, we may request (in writing or through your App dashboard, Platform, or any Facebook Product) information, certifications, and attestations relating to your use of Platform or Processing of Platform Data, which you will provide to us in the requested time frame and form. This may include certifying: (i) your compliance with these Terms and all other applicable terms and policies, and (ii) the purpose or use for the Platform Data you have requested or have access to, and that each such purpose or use complies with these
Terms and all other applicable terms and policies. All such certifications and attestations must be provided by an authorized representative of yours. e. Suspension and Termination i. We may take enforcement action against you and your App if we believe, in our sole discretion, that: 1. You have not timely responded to our requests related to monitoring or auditing; 2. You or your App has violated or may have violated these Terms or any other applicable terms or policies or is negatively impacting Platform, other Facebook Products, Platform Data, or people who use Facebook Products; 3. It is needed to comply with applicable laws or regulations or otherwise required or requested by a court order or governmental authority; or 4. It is needed to protect the Facebook Companies from legal or regulatory liability. ii. We may take enforcement action at any time, including while we investigate your App, with or without notice to you. Enforcement can be both automated and manual. It can include suspending or removing your App, removing your access and your App’s access to Platform, requiring that you stop Processing and delete Platform Data, terminating our agreements with you, or any other action that we consider to be appropriate, including terminating other agreements with you or your ability to use Facebook Products. iii. We may suspend or end your App’s access to any Platform APIs,
permissions, or features that your App has not used or accessed within a 90-day period with or without notice to you. 8. Notice After you agree to these Terms, any written notice, request, or communications from us to you may be provided via email or mail (for example, to the email address or mailing address in your App account with us) or via notifications within the Facebook Products (for example, in your account with us). You will keep your contact information current, including name, business name, and email. 9. Indemnification In addition to and without limiting the scope of the “Indemnification” Section in our Facebook Commercial Terms if anyone brings a claim, cause of action, or dispute against the Facebook Companies related to your use of Platform, your Processing of Platform Data, Your Content, or your App, name or logo, products or services, or actions in connection with Platform, you will indemnify and hold the Facebook Companies harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to any such claim, cause of action, or dispute. 10. International Transfers This section shall apply to the extent that your Processing of Platform Data includes personal data controlled by Facebook Ireland Limited (“Facebook Ireland Data”) and the transfer of such Facebook Ireland Data to a territory outside of the European Economic Area that does not have a positive adequacy decision from the European Commission under Article 25(6) of Directive 95/46/EC (each an “EEA Data Transfer”). In these cases you will comply with the following: a. if you are relying on the EU-U.S. Privacy Shield (the “Privacy Shield”) and are certified under Privacy Shield to receive categories of data which include the