THE WEBSITE

Thank you for visiting www.frolo.com (“the Website”). Please read the following information carefully as the following terms and conditions will apply to your use of the Website. The Website is operated by Frolo Limited, trading as Frolo, a company registered in England and Wales under company registration number 11559309 having its registered office address situated at Huckletree West Mediaworks, 191 Wood Ln, London, England, W12 7FP.

You can contact us by email at support@frolo.co.uk

USE OF THE WEBSITE

These Website Terms of Use together with the Privacy Policy set out the terms and conditions of you using the Website. By accessing or using the Website, you are accepting the Terms of Use and that you agree to be bound by and comply with them.   However, if you do not or cannot accept the Website Terms of Use you must stop using the Website immediately. The Terms of Use may change from time to time but by browsing the Website you are accepting the terms of use which are in use at that time. You are responsible for ensuring that anyone else who accesses our website through your internet connection is aware of these Terms of Use and the policies referred to above and that they comply with them.

GOVERNING LAW

The Website is made available free of charge.  The Website is designed for use within the UK and Ireland and by accessing the Website you are agreeing that the laws of England and Wales will be applicable to any disputes which may arise. The courts of England and Wales will have exclusive jurisdiction over any claim arising from or related to, a visit to the Website although we retain the right to being proceedings against you for breach of these conditions in your country of residence or any other relevant country.

The Website is designed for use within the UK and Ireland only.  If you choose to access information on the Website from outside of the UK or Ireland, it is your responsibility to comply with the applicable local, national or international laws and any use of the Website outside of the UK or Ireland is entirely at your own risk.

NO RELIANCE ON INFORMATION

Although we have taken all reasonable care to ensure that the information provided on the Website is accurate, we make no representation or warranties of any kind, express or implied, about the accuracy timeliness or completeness of any such information.

Although we make reasonable efforts to update the information on the Website, we make no representations, warranties or guarantees, whether express or implied, that the content on the Website is accurate, complete or up-to-date.

We neither warrant nor represent that your use of the Website will not infringe the rights of third parties.

The content on the Website (including (without limitation) any information provided via any ‘web-chat’ facility) is provided for general information only.  Nothing contained on the Website constitutes legal, investment, tax or other advice and is not to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making an investment decision.

LIMITATION OF OUR LIABILITY

Nothing in these Terms of Use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law. If you are a consumer user nothing in these Terms of Use affects any statutory right or remedy that you may be entitled to.

To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to the Website or any content on it, whether express or implied We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• use of, or inability to use, the Website; or
• use of or reliance on any content displayed on the Website (including (without limitation) any information provided via any ‘web-chat’ facility).

If you are a business user, please note that in particular, we will not be liable for:

• loss of profits, sales, business, or revenue;
• business interruption;
• loss of anticipated savings;
• loss of business opportunity, goodwill or reputation; or
• any indirect or consequential loss or damage.

If you are a consumer user, please note that we only provide the Website for domestic and private use. You agree not to use the Website for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the Website or to your downloading of any content on it, or on any website linked to it.

We do not guarantee that the Website will be secure or free from bugs or viruses.   You are responsible for configuring your information technology, computer programmes and platform in order to access the Website. You should use your own virus protection software.

YOU AGREE THAT YOU WILL NOT USE THE WEBSITE TO DO THE FOLLOWING ACTIVITIES

You may only use our website for lawful purposes and in compliance with all applicable laws, including without limitation data protection and privacy laws, laws relating to copyright of content and laws relating to unsolicited commercial electronic messages.

You must not:

1. commit or encourage any criminal offence including fraud;
2. send via any of the forms provided on the Website any material which is offensive, or which may be abusive, indecent or in breach of confidence, copyright, privacy or any other rights
3. hack into any aspect of the Website
4. circumvent, or attempt to seek to circumvent, any of the security safeguards of the Website
5. permit any third party to do any of the above.

You must not misuse the Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful or repetitive requests designed to interrupt, destroy or limit the functionality of any computer software or hardware or to diminish the quality of, interfere with the performance of or impair the functionality of the Website. You must not attempt to gain unauthorised access to the Website, the server on which the Website is stored or any server, computer or database connected to the Website.

We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Website will cease immediately.

CHANGES TO THE WEBSITE

We reserve the right to update the Website at any time.  Please note that any of the content on the Website may be out of date at any given time, and we are under no obligation to update it.

We do not guarantee that the Website, or any content on it, will always be available or be uninterrupted. Access to the Website is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of the Website without notice. We will not be liable to you if for any reason the Website is unavailable at any time or for any period.

We do not guarantee that the Website, or any content on it, will be free from errors or omissions.

INTELLECTUAL PROPERTY RIGHTS

We are the owner or the licensee of all intellectual property rights in the Website, and in the material published on it.  Those works are protected by copyright laws and treaties around the world.  All such rights are reserved.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

You may use the Website for your personal use and information and you may make a copy of the pages of the Website but only for your personal non-commercial use, provided that you keep all copyright and other proprietary notices intact. You must not use any part of the content on the Website for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of the Website in breach of these terms of use, your right to use the Website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

LINKS TO AND FROM THIRD PARTY WEBSITES

Links on the Website and other websites may lead to third party websites. The content, accuracy and function of such websites is outside of our control and we cannot accept any responsibility for the same and nor do we endorse the contents of such third party websites. In particular, any dealings that you have with such third party website operators shall be on the terms and conditions (if any) of that website operator, as these terms and conditions of use are limited to the Website. Frolo.com contains some affiliate links. If you purchase something on a third party website having clicked through a link on the Frolo site we may receive a small revenue share.

You may create a link to the Website from another website, but only if you comply with the following conditions:

1. you may only link to the homepage of our website. You must not create a link to any other page of the Website, nor frame any page of the Website;
2. you may only link to other Website from a website which you own; and
3. you must not suggest that we have any association with you or that we approve or endorse your website or any of your products or services unless we expressly agree that you can do so.

We reserve the right to require you to remove any link to the Website at any time and without giving you prior notice.

Privacy policy

Thank you for visiting www.frolo.co.uk (“the Website"). The Website is operated by Frolo Limited, trading as “Frolo”, a company registered in England and Wales under company registration number 11559309 having its registered office address situated at West Mediaworks, 191 Wood Ln, London, England, W12 7FP. References in this Privacy Policy to "we", "us", "our" and "ourselves" are references to Frolo Limited. References to “you” or “your” are references to any person reading this Privacy Policy.

We take the privacy of our Website users seriously and we are committed to protecting your privacy in compliance with data protection laws. This Privacy Policy explains what personal data (see below for details of what this means) is collected about you via the Website and what we do with that information.

We encourage all of our customers to familiarise themselves with this Privacy Policy to understand our views and practices regarding your personal data collected via the Website and how we will treat it.

We reserve the right in our sole discretion to amend this Privacy Policy from time to time.  In this event, we will post the revised policy on the Website.   We encourage you to periodically re-read this Privacy Policy so that you are aware of any updates and remain informed as to how we are using, disclosing and processing your personal data.  We may, where necessary, notify users of any modified version of this Privacy Policy that might materially affect the way we use, disclose or otherwise process users’ personal data or otherwise affect their privacy rights. We may do this for example by posting an update on the Website which users will see at their next visit.

This Privacy Policy relates to the personal data we collect about you via the Website, practices and may be supplemented by separate privacy policies, notices or other privacy related information which will apply to personal data obtained by us (or on our behalf) other than through the Website (for example, if you provide that personal data to us over the phone or make an inquiry) to obtain our services.  Additional privacy information will be made available to you at the relevant point if you interact with us via the Frolo App. Please contact us for more details (contact details are included at the end of this Privacy Policy).

YOU HAVE A RIGHT TO KNOW HOW WE WILL USE YOUR PERSONAL DATA.

We provide this Privacy Policy to make you aware of our practices in connection with your privacy and of the choices you can make about the way your personal data is collected via the Website and used.

We are committed to ensuring the security of your personal data.

The Data Protection Act 2018 (“DPA”) places obligations on us to process your information fairly and lawfully and to keep it secure. For the purposes of the DPA, the data controller of Website users’ personal data which is collected through the Website when users make an online enquiry is Frolo.

What is “Personal Data”?

For the purposes of this Privacy Policy, “personal data” is data which relates to a living individual who can be identified from the data or from that data and other information which is in the possession of, or likely to come into the possession of, Frolo.

The type of personal data we will collect about you via the Website

The Website provides users who are service with an opportunity to submit enquiries to us.

The personal data that you may provide to us when submitting an online enquiry (or contacting us via the Website for the other purposes mentioned above) includes the following:

• your name;
• your contact details (including postal address, email address and phone number); and
• any personal data you choose to include when typing additional comments in free text boxes (such as ‘tell us a little bit more about your enquiry’ or when submitting a complaint or inquiry via the Website).

In addition, you may also provide us with your personal data by corresponding with us by phone, e-mail, post or otherwise. This includes personal data you submit when you subscribe to our service, make an enquiry and/or when you report a problem with the Website. The information you give us may include some of the personal data listed above and any other personal data you choose to provide to us.

We will only collect information about you where this is necessary in order for us to be able to provide you with our products/services (including contacting you to discuss our products/services) and as otherwise set out in this Privacy Policy.

How we collect information about you

In addition to collecting your personal data via your use of the Website, and as otherwise described above, we also collect personal data and financial information which we obtain from you when you provide us with data over the telephone, correspond with us via email and post, when you send us documents, when you complete and send us a form via the Website or from any third parties.  This Privacy Policy details how we collect your personal data via the Website and when read alongside the other supplemental privacy information, notices and/or statements provided to you by us cover how we process your personal information across all channels.

When you provide any information via the Website you thereby confirm that you are fully authorised to provide such information and to approve Frolo’s processing of such information in accordance with this Privacy Policy (which you do thereby approve).

How we handle your personal data

We will only use the personal data you provide to us as described in this Privacy Policy, including any supplemental privacy information, as set out above.

We will observe the rights granted to you under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with. See below for details about how to contact us and how to exercise your right to obtain copies of your personal data from us under data protection laws.

We will only collect and process your personal data where we have lawful grounds to do so.

We will update our records if you inform us that your details have changed.   Please tell us (see contact details below) as soon as possible about this.  We will update our records promptly once we are satisfied that the new information (such as your new address or contact detail) is accurate.

We will put your name and contact details which we collect through this Website into our Customer Relationship Management tool.  We will only use this personal data for the purposes described in this Privacy Policy and as otherwise notified to you from time to time.

How we will use the personal data we collect about you.

We will store and process your personal data on our computers. Please see the Data Security header below for details about how we keep your personal data secure, in line with our obligations under the DPA.

We will use your personal data collected (including from any third parties, where relevant and lawful) to:

• contact you about our services (in response to your request for this contact which you have made via our Website);
• provide our services to you if you decide to go ahead and obtain them (but please note as explained above that supplemental privacy information when you sign up to the Frolo App, notices and/or statements will also be relevant to that processing);
• comply with our legal obligations; and
• identify patterns which we can use to help us develop, administer, support and improve our services.

This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate.

We may also use your personal data where such use is in our (or a third party’s) legitimate business interests, providing this use does not cause you unwarranted prejudice, and as otherwise set out in this Privacy Policy.

Sharing or disclosing your information with third parties

When our service is available via the websites of our partners, those partners may have access to your personal data. Their use of your personal data is governed by their privacy policies. We are not responsible for the privacy policies and practices of any other websites, even if you access them using links from the Website or if you can access the Website or use our services from them. We therefore recommend that you check the policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.

If we offer or supply a service to you that is provided on our behalf by a third party we may have to pass your personal data to them in order to deliver the service.   Where we do this, we will make this clear to you (by providing you with supplemental privacy information) before we pass your personal data to a third party.

We may also use third parties to provide services on our behalf which may include processing (but not using themselves for their own purposes) your personal data and this means we will disclose your personal data to them.  For example (amongst others), to provide IT services such as data hosting. In either case, we will in accordance with our obligations under data protection law put in place appropriate written protections for your personal data including in our contract with them.

Other than set out in this Privacy Policy (and supplemental privacy information, notices and/or statements where relevant), we will not otherwise disclose, sell or distribute your personal data we collect via the Website to any third party without your permission unless we are required or permitted to do so by law. In addition to the disclosures described above, we may disclose your personal data to:

• our auditors, solicitors, professional advisors, sub-contractors or any person providing services to Frolo and, who have agreed to treat your personal details as confidential;
• anybody having a legal right to your personal information, including the police and any other legal and regulatory authorities and government bodies;
• to any third party who acquires all, or substantially all, of the assets or shares in Frolo, any of our corporate group, and/or the Website, whether by sale, merger, acquisition or otherwise; and
• any other third party, where you have consented (where consent is required by law).

Marketing communications

From time to time and where we have collected appropriate consents under data protection laws to permit this, we, and other companies within our corporate group, would like to send you information about our/their other credit related and financial goods and services which may be of interest to you and which are similar to our own. If you have consented to receive these marketing communications, you may be contacted in each case by post, fax, telephone, recorded message, email, SMS or by any other method made clear to you at the time you gave your consent.

If you have consented to receive marketing communications but no longer want to receive details of these goods and services please contact us via email us at:  support@frolo.co.uk. You will be reminded of how to unsubscribe in each electronic marketing communication too.

Where you have provided your consent, we may also pass your personal data to selected businesses outside of our corporate group who may contact you directly about their services and products that may be of interest to you.

If you have consented to us passing your personal data to companies outside of our corporate group but no longer want us to do this, please email us at:  support@frolo.co.uk .   Please note this does not mean we can obtain data back from those other companies.   You would need to contact them directly to stop their marketing to you – their contact details should be in the marketing communications they send to you.

How long we keep your personal data.

We take steps with a view to deleting, destroying or permanently anonymising your personal data (which means that we are no longer able to identify you from it) when it is no longer necessary for its purpose and we are not required by law to keep it.

How long we keep your personal data depends upon the purpose for which your personal data was collected was provided. Generally however:

• we will keep the information no longer than is necessary to enable us to provide you with a service that you have requested for as long as it takes us to provide that service;
• we will keep your contact details for a reasonable period after you have given us your consent to use them for marketing purposes (but we will not retain these details indefinitely); and
• we will keep other information about you if it is necessary for us to do so to comply with our legal obligations.

Will my personal data be transferred outside of the European Economic Area?

This Privacy Policy describes above how users’ personal data collected via the Website may be disclosed outside of Frolo.  Your personal data will not be transferred outside of the European Economic Area.

Your right to see your records

You have a right to obtain a copy of the personal data we hold about you. If you wish to request a copy of the information we hold about you please email us at: support@frolo.co.uk .

Data Security

In accordance with our obligations under the DPA, to prevent unauthorised access to or disclosure of your personal data (including card payments), maintain data accuracy, and ensure the appropriate use of your personal data, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online.

However, you acknowledge that, unfortunately, the transmission of information via the internet, including the online enquiry forms you submit to us is not completely secure. We cannot guarantee the security of your data transmitted to the Website: any transmission (i.e. your sending of the personal data to us) is at your own risk. Once we have received your personal data, we will use the steps detailed above to protect it

You should be aware that there are inherent risks in transferring personal data over the Internet. For example, if you send us an e-mail from your private mailbox, we cannot guarantee the security of the content during its transmission to us. For that reason, please do not send to us an unsecured e-mail with confidential information such as your National Insurance or bank account numbers, or any sensitive personal data.

Customer feedback and complaints

If you have any questions about our Privacy Notice please contact us via email at support@frolo.co.uk .

Last updated:  11 June 2019