Privacy

Frooition Privacy Policy May 2018

We are committed to protecting and respecting your privacy.

Everyone has rights with regard to the way in which their personal data is handled. During the course of our activities we will collect, store and process personal data about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of UK data protection laws, the data controller is Froo.com Limited of Unit E, Silverend Business Park, Brettell Lane, Brierley Hill, West Midlands, DY5 3LG (collectively referred to as “Froo.com”, "we", "us" or "our" in this privacy notice).

Data protection principles

When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal data must be:

• processed lawfully, fairly and in a transparent manner,
• processed for specified, explicit and legitimate purposes,
• adequate, relevant and limited to what is necessary,
• accurate and kept up-to-date,
• kept for no longer than is necessary, and
• processed in a manner than ensures appropriate security.

Information you give to us

You may give us information (such as your name, address, email address, phone number, eBay user ID, company name, PayPal address, bank card details) by:

• creating a Frooition account on our website,
• filling in a ‘Contact us’ form on our website and Frooition landing pages,
• participating in discussions on social media outlets,
• having your attendee badge scanned at our events,
• entering a competition, promotion or survey organised by us, or
• corresponding with us by phone, email, letters or otherwise.

We may use the information you give to us for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

Purposes for which we will use the information you give to us	Legal Basis
To receive information about our services and details of pricing.	It will be necessary for our legitimate business interests, namely to ensure the user is fully aware of the services we offer and the cost of those services.
To create a Frooition account, process payments for services and applications downloaded and to ensure compatibility of services with the users device or computer.	It will be necessary for the performance of a contract between you and us and it will be necessary for our legitimate business interests, namely to ensure full operation and use of the services downloaded.
To notify you of any new services or updates available.	It will be necessary for our legitimate business interests, namely to ensure all services remain up to date and fully operational and to ensure that you are fully informed of new services available.
To assist us in responding to whatever query or interest you have expressed.	It will be necessary for the performance of a contract between you and us and it will be necessary for our legitimate business interests, namely satisfying your concerns and ensuring we provide a complete service.
To combine your information with other user’s information and review it in any aggregated form.	It will be necessary for our legitimate business interests, namely to understand the types of individuals who use the website, what particular types of questions are raised and what particular types of interest are expressed.
To provide you with text notifications to update you about your account with us.	We will only do this if you give us your consent by some specific, informed and unambiguous method.
Any other purpose that we notify to you, but are not expressly listed in this table.	We will only do this if you give us your consent by some specific, informed and unambiguous method.

As stated in the table above, it is a legal obligation for you to provide us with certain information. If you do not provide us with that information, we may not be able to provide our services to you.

It is also a contractual requirement for you to provide us with certain information. If you do not provide us with that information, we may not be able to perform the contract.

All other information you give us is given entirely as your discretion. If you do not provide that information, then we will be unable to provide a comprehensive service.

Information we collect about you from other sources

When you visit our website, we may collect information about you (such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser plug-in type and versions, time zone setting, operating system and platform).

When you visit our website, using a mobile device, we may collect information about you (such as country code, language, device name, operating system name and version).

We may collect information about you (such as your eBay store name and URL, email address, eBay default site and listing history) either directly from you or via the permissions granted to us by you in your eBay account.

We may use the information we collect about you for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

Purposes for which we will use the information you give to us	Legal Basis
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.	It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website.
To obtain further information about you, any organisation you represent, with a view to us recommending and providing suitable services.	It will be necessary for our legitimate business interests to ensure we are fully aware of all issues relating to the services you require to ensure the correct Service is recommended and provided.

Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can change the settings on your internet browser to restrict the amount of information that we can collect when you visit our website. If you do not allow us to collect this information, then we may be unable to offer you the best experience possible when accessing and using our website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies.They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie	Purpose
Analytical	To allow us to recognise and count the number of visitors and to see how many visitors move around website when using it. This helps us to improve the way our website works.
Visit History	To allow us to establish the last time you visited.
Login Session	To maintain an open session with the Frooition Software account.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after 365 days.

Disclosure of your information

You agree that we have the right to share your personal information with:

• Amazon Web Services Virtual Private Cloud and other online cloud providers. We utilize cloud service Amazon Web Services (and other online cloud providers) for data storage within a Virtual Private Cloud, your personal data will be transferred to this Virtual Private Cloud for the purposes of providing you our services generated by the secure Frooition software;
• Salesforce, Campaign Monitor and other database and email management providers;
• Selected third parties including
  1. verified business partners and sub-contractors to the extent we reasonably consider that it is in your best interests for us to do so, or it is necessary for our legitimate business interests; and
  2. analytics and search engine providers that assist us in the improvement and optimisation of our site.

We will disclose your personal information to third parties:

• in order to securely host our software and internal files;
• to manage our databases and email marketing campaigns;
• in the event that we enter into negotiations to sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• if Froo.com or substantially all of its assets are acquired by a third party, in which case personal data held by it about you will be one of the assets transferred to the third party;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract between you or us, or our website terms of use, or to protect the rights, property, or safety of Froo.com, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
• if you request us to do so and if you give us your consent by some specific, informed and unambiguous method.

Identifying you as a customer

If you are a business client, we may identify you as a client of the firm in our marketing material or in legal directories, although we will never publicly disclose any confidential information about your legal matters without having obtained your prior consent. If you do not agree to us identifying you as a customer of the firm, please notify us by writing to the address at the top of this policy, or by emailing us at privacypolicy@froo.com.

Where we store your personal data

All information you provide to us is stored on our secure data centres in the US and EU.

We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:

• Credit cards. We do not store any credit card details.
• Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
• Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
• Equipment. Our internal policies require that individual monitors do not show confidential information to passers-by and that users lock or log-off from their computer when it is unattended.
• Firewalls.
• Transferring data to the US. We only transfer data to storage providers in the US which are able to provide appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available.

Some of the data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by personnel operating outside the United Kingdom who work for us, our group companies or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long we will store your personal data

The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

Legal basis	Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us.	We will use/store your data for as long as it is necessary for the performance of the contract between you and us.
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject.	We will use/store your data for as long as it is necessary for us to comply with our legal obligations.
Where we use/store your data because it is necessary for our legitimate business interests.	We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data).
Where we use/store your data because you have given us your specific, informed and unambiguous consent.	We will use/store your data until you ask us to stop.

Your rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

• You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
• You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
• You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
• You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
• You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
• Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
• Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
• You have the right to object to us using/storing your information for direct marketing purposes.

If you wish to exercise any of your legal rights, please contact us by writing to the address at the top of this policy, or by emailing us at privacypolicy@froo.com.

You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

Changes to our policy

Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.

Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to us by writing to the address at the top of this policy, or by emailing us at privacypolicy@froo.com.