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 firstname.lastname@example.org
USE OF THE WEBSITE
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
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:
- commit or encourage any criminal offence including fraud;
- 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
- hack into any aspect of the Website
- circumvent, or attempt to seek to circumvent, any of the security safeguards of the Website
- 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.
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:
- 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;
- you may only link to other Website from a website which you own; and
- 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.
YOU HAVE A RIGHT TO KNOW HOW WE WILL USE YOUR PERSONAL DATA.
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”?
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.
How we collect information about you
How we handle your personal data
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.
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.
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.
- 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).
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: email@example.com. 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: firstname.lastname@example.org . 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?
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: email@example.com .
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 firstname.lastname@example.org .
Last updated: 11 June 2019
Frolo Limited is committed to meeting our legal requirements with respect to Privacy for all who access and use our website. Under the EU/ and UK General Data Protection Regulation (together “GDPR”) and the UK Data Protection Act 2018, we must comply with certain requirements that are designed to ensure that any personal data you provide to us is processed with due care and attention, and that you as an individual are aware of and know how to exercise your rights with respect to any personal data you trust us with.
Who we are
Registered office address:
C/O Craufurd Hale Group The Ground Floor,
United Kingdom, SL6 8QZ
Company number: 11559309
VAT Number: GB318583287
We are registered as a data controller with the UK Information Commissioner’s Office, registration number: ZB272753.
What data do we collect and why
Frolo Limited collects some personal details when you enter your details into the App registration form, when using the Frolo App, we will also receive some personal information if you email us directly or using email@example.com.
Any use of the data you load into the App is governed by the App Terms and Conditions.
We collect and process then following information:
- Your name *
- Your picture *
- Your email address *
- Your postcode *
- Your birthday or your age range *
- Your children’s gender and date of birth *
- Your login credentials to social networks such as Facebook, Twitter, and Google if you choose to connect these to your Frolo account.
- records of your correspondence with us if you contact us.
- any information you provided when completing surveys that we use for statistical purposes.
- We collect information on your device identifier and operating system when you use the App.
- details of your visits to the App including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the App resources that you access.
If you use the Dating functionality of the App, additionally we also collect some or all of the following information:
- Information about you
- Your profile pictures – at least one *
- Your Gender *
- Your Job Title
- Information about your Job
- Your Parenting information *
- Your Height *
- Number of children you have *
- How long you have been single parent *
- Your bio
Information about the type of people you are interested in
- Age range of potential matches
- Sexual Orientation of potential matches
Note: Information relating to your children’s date of birth is not visible anywhere in the App and is used only by our matching algorithm.
None: Information marked ‘*’ is mandatory
We collect this information about you for the following purposes when using the App:
- to ensure the correct operation of the App and improve the App
- to ensure that data on screens is displayed to you in the most effective way on the device you are using
- if you have given us consent, to provide you with information, products or services that you request from us or which we feel may interest you
- to carry out our obligations arising from any contracts, if applicable, entered into between us and you
- to allow you to participate in interactive features of our service, when you choose to do so
- to notify you about changes to our service or App, which may affect you
Profiling and matching
We use the information you provide us, and information we collect, if you allow us, to help you find suitable matches based on your preferences.
Our matching algorithm uses the information you provided and presents to you as a set of filters you can adjust at any time to change the results you see.
You can make your account invisible at any time to prevent your profile being presented to other users.
We have access to the following information about you on the Veriff system:
- IP Location & address
- First & Last name
- Date of Birth
- Document country
- Document type
- Document Number
- Document expiry
We also have access to pictures taken during the verification process including the picture taken of you and pictures taken of the front and back of your ID.
We store the following information on our systems to enable us to manage this verification process:
- Date of Birth
- Picture taken during verification process
You must agree and successfully complete User Verification to be granted access to the App.
People who register to use the App
If you register to use the App we collect enough information to enable us to provide you the services the App offers, this includes all information marked as mandatory in section ‘What data do we collect and why’ above. We collect and process this information using the ‘performance of a contract’ legal basis so that we may provide the App and its services to you.
The legal basis of processing all other information we collect from you is ‘Consent’.
Unless you have specifically opted in to receive information about products and services from Frolo during the registration process or when using the App we will not send you any communication other than what is required for the delivery of the service. If you agree to allow us to send you information about Frolo Products and Services by opting into that service, you do that on the basis of consent.
People who email us
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with company policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
If we consider the contents of an email to contain personal data we have not requested or more detail than we need then we will delete some or all of it immediately and request another with less personal details, or no personal details.
By submitting personal data to us by way of an email or an enquiry you necessarily consent to us using that information to contact you in return to complete that enquiry. We do not use that data for any other purpose. For the avoidance of doubt the legal basis for processing your enquiry is ‘consent’.
Who we Share Information With
We share your public profile with other users of the App.
We also share our data with our App developer, App services provider and our hosting provider.
We share data with our user verification provider Veriff.
Our agreement with them identifies them as a processor and ensures that the data transfer is both legal and secure.
Our agreement with AWS is based on standard contractual clauses with supplementary measures which ensure that, within reason, US Government and Security Services are unable to access our data even if requested from the US parent organisation.
How long to we store your personal data
We keep your personal data for as long as we are providing access to the App and its services to you, after you have deleted your account and stopped using the App and its service(s) we keep the data for 12 months, then we anonymise it removing any personal information.
If there is no activity on your account for 12 months or more, we may delete your account and anonymise your personal data by removing any personal information. We will inform you prior to deleting your account and let you know how to prevent your account from being deleted and your personal data being anonymised.
Any data classified as financial that we are required to keep will be retained according to UK HMRC rules, currently 6 years plus current year.
Disclosing your Information
Your rights as an individual in respect of the data we hold
We respect the rights and freedoms of individuals and as such we would like to make you aware of the following.
Depending on the specific circumstances you have the right to:
- Request access to your data
- Request rectification of your data where there are errors or inaccuracies, or the data is not current
- Request that the data we hold is removed entirely from our systems (the right to have data removed is only applicable where it does not conflict with our legal and regulatory requirements to keep certain records according to the data retention period)
- Request us to restrict processing of your data
- Object to our processing of your data
- Request your data in a format that is commonly used/accepted
- Send your data to another controller
- Withdraw consent already provided – at any time
If you wish to exercise any of your personal data rights, please contact Frolo using any of the methods described under How to Contact us.
You also have the right to lodge a complaint with a supervisory authority, see Complaints or Queries below.
Protecting your information
Your information is only accessed by people who need it to perform their role.
Your personal data is encrypted transit.
We will retain personal information only for so long as the information is necessary to fulfil your request or provide you with the services you are using, or until you exercise one of your rights.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Complaints or queries
Frolo Limited tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously.
We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
If for any reason you believe that Frolo Limited is not in full compliance with the GDPR/UK DPA 2018 or that a request or complaint has not been properly dealt with you have the right to lodge a complaint with the relevant supervisory authority, in the UK this is the ICO.
https://ico.org.uk/concerns/handling/ or call the ICO on 0303 123 1113.
How to contact us
You can write to us at:
C/O Craufurd Hale Group The Ground Floor,
Arena Court, Crown Lane,
United Kingdom, SL6 8QZ
Changes to this privacy notice