tells you what Frugl Limited do with personal data - how we collect information, what we do with it and what controls you have. It applies to both our
website www.frugl.com and our mobile application which it refers to collectively as the ‘Service’. We are what the Data Protection Act 1998 calls the data
controller and you and other users of the Service are data subjects, about whom we process what the Act calls personal data.
When you use the Service, you allow us to collect and use personal data in accordance with this policy. No document like this remains the same for ever,
because laws and technology change, so we reserve the right to change it when we consider it appropriate (though always in compliance with the law).
Changes will be made by posting a revised policy on the Service. It was last updated on 27 April 2015.
Remember that Frugl is an online marketplace, and when you use the Service you are dealing with promoters of events and offers who will also need to
process information about you and who will have their own privacy policies. We are not responsible for what they do with your information.
1.) YOUR INFORMATION
1.1 What information will we collect and process?
This is the personal data about you that we may collect and process. It is an exhaustive list – anything not included is excluded.
Information that you provide by completing forms on the Service. This may include your name, email address, postal address and telephone number. You might
give us this information when you register as a user of the Service, subscribe to any service, upload or submit any material to the Service, request any
information or enter a competition or promotion.
Your password and log-in details.
If we provide you with the option and you log in via a social networking site, information obtained from your profile for that site.
Your preferences, which we may collect to help us provide you with offers that reflect your interests.
Details of any transactions you enter into through the Service;
Communications you send to us.
Information you choose to give us in response to surveys run on the Service for research purposes.
Details of your use of the Service, including resources you access and data you download or upload.
We may also collect and process information that does not directly identify you, including aggregate and de-personalised information, the type of phone or
operating system you use and, if you came to the website, the type of internet browser you use and the website from which you have come to the site.
You do not have to provide any of this information, but, if you choose not to we may not be able to provide you with the full range of our services.
We may collect your IP address or the unique identifier of your mobile device, which are automatically recognised by our servers. This information is only
used to help us give you an effective service and to collect broad demographic information for aggregate use. You cannot be identified solely from this
1.2 How will we use your information?
We will use the information you provide for these purposes, and no other purposes.
To build a profile of your preferences so we can give you relevant offers and services.
To process your orders and to meet your requests, which may mean we have to pass information to the promoter of an offer or event for which you have
ordered tickets or vouchers.
To administer your Frugl account.
To verify and carry out financial transactions in relation to payments you make through the Service.
To share with third parties necessary to process your transactions with us, such as credit card companies and banks.
To share with promotors for the purposes of redeeming the vouchers and tickets you purchase from the Service.
To protect against fraud and to reduce credit risk by exchanging information with other companies.
To contact you when we need to discuss your transactions on the Service.
To audit what data are downloaded of data from the Service.
To improve the Service.
To identify who is using the Service.
To carry out research into users' demographics and sales data.
If we offer the facility to share information with social networking sites, we will use your data for this purpose and you are deemed to have agreed to
this when you use the sharing facility.
We will disclose your information to the authorities when the law requires us to do so, and may disclose it if we believe it necessary to do so to prevent
safety of any person.
We will also use information you provide to us to contact you with information or offers regarding events, offers, products, services or surveys, but only
with your consent and in accordance with our direct marketing policy on which see section 6.
1.3 What information will we share with others?
Apart from disclosures covered above, we will share no personal information with third parties. The only information we may disclose will be aggregate
statistics about visitors to the Service, customers and sales which will include no personally identifiable information.
The previous paragraph does not apply to our agents or contractors. We rely on third parties to assist us in providing the Service, processing
transactions, providing support services and other tasks, and we may need to disclose personal information to them for those purposes. Our agents and
contractors will only use your information to the extent necessary to perform their functions.
If the Frugl business is sold to another business or otherwise re-organised, you agree that any personal information we hold about you may be transferred
to enable the Frugl business to continue to provide you with the Service.
2.) PAYMENT PROCESSING
Payments you make when using the Service are not handled by us but are made through our payment solutions provider. Your credit or debit card information
payment solutions provider operates a secure server to process payment details, encrypting your credit or debit card information and authorising payment:
we do not store your credit card number or security code on our servers, although this information may pass through our servers on the way to the payment
3.) MARKETING TO YOU
We will not send you unwanted marketing messages, but we do want to be able to provide you with information that you will find useful, and to give you the
choice to receive information you want.
We may send you information about events featured on the Service electronically if you have indicated that you do not object to being contacted for these
purposes. If you have provided us with an email address we may use it for this purpose. You will always have the option to opt-out of receiving further
communications of this nature by following the unsubscribe instructions on any messages sent to you.
If you consent by opting-in to receive such information and offers, we may also let carefully selected third parties send information which you may find
useful regarding their products and services directly to you. Again, you may tell us you no longer want to receive such information by following the
unsubscribe instructions on any communications sent to you.
You can also exercise this right at any time by contacting us using the contact details at the end of this policy.
4.) PUBLIC FORUMS
If we make public forums available to users, any information disclosed in these areas becomes public. Please exercise caution when using public forums and
do not disclose your personal information.
5.) EXTERNAL LINKS
We assume no responsibility for the privacy policies or the content of external sites to which we provide links.
6.) YOUR LOCATION DATA
To enable you to get the most out of our service and to allow us to provide you with tailored offers, we need to process information about your approximate
location, including latitude, longitude, and cell tower ID. These data will only be processed for as long as necessary for us to respond to your request
for tailored offers, after which the data will be deleted. These data may be passed to our agents or contractors to enable them to provide you with the
best offers to match your preferences.
You can choose not to allow us to process this information at the time you connect to the app, or any time after that either by changing the settings on
information, we will not have enough data to be able to provide you with the full benefit of our service.
We take steps to protect against the loss, misuse and alteration of personal information under our control, as required by the Data Protection Act. We
cannot guarantee that loss, misuse or alteration of information will never occur, but we use all reasonable efforts to prevent it.
Remember that submitting information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Service
whilst it is in transit over the internet. Any such submission is at your own risk.
8.) LOCATION OF STORAGE AND PROCESSING
Information submitted through the Service is stored on secure servers located in the United Kingdom and other European Economic Area countries and may be
transferred and processed outside the European Economic Area. By submitting information via the Service, you agree to this storing, processing and
9.) YOUR RIGHTS
The Data Protection Act 1998 gives you the right to receive a copy of all the personal information about you held by us and to request that we correct any
errors in it. We will supply a copy of this information on request, subject to a fee of £10.
You also have a right to prevent the use of your personal information for direct marketing purposes, described in section 4.
Cookies are pieces of information that a website transfers to your hard drive to store and which may track information about you.
When you visit the Service our Web server sends a cookie to your computer or mobile device (depending on how you access the site). These are small pieces
of information which are issued to your computer and stored on it when you visit a website. They store and sometimes track information about your use of
the site. Cookies identify a user's device, but they do not personally identify users. They are specific to the server that created them and cannot be
accessed by other servers, so cannot be used to track your movements around the internet.
Some of the cookies we use expire at the end of your web session. Others, known as persistent cookies, last longer and are used to remember you when you
have enough capacity for them. We may also use them to customise elements of the pages of the site or to collect statistical information about how you use
the site so that we can improve the site and learn which parts of the website are most popular to visitors.
Cookies used by our Service may be set by us or by third parties who are delivering services on our behalf, such as social networking sites.
Most web browsers automatically accept cookies but you can change your browser to reject them or to notify you each time a cookie is set. You can learn
more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block them in different types of
Please note that if you block or delete cookies used on the site you may not be able to take full advantage of the Service.
11.) CONTACTING US
email@example.com or write to us at:
1 St. Saviours Wharf
23 Mill Street
London SE1 2BE