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).
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal data must be:
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:
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.
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.|
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:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|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.|
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.
You agree that we have the right to share your personal information with:
We will disclose your personal information to third parties:
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 firstname.lastname@example.org.
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:
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.
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.|
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
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 email@example.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.
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.
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 firstname.lastname@example.org.