Fruugo.com Ltd Privacy Notice

Fruugo.com Ltd and its wholly owned subsidiaries are committed to safeguarding the privacy of all individuals who interact with us and we respect the privacy choices you make.

In the context of this Privacy Notice, when we use the term ‘we’ it means Fruugo.com Ltd, Fruugo (Ireland) Ltd and Fruugo PLC. 

This Privacy Notice (together with our Terms of Use and any other documents referred to in it) sets out how we collect, use and manage your personal data through Fruugo websites and online services. In this context, ‘personal data’ is data which relates to you and that personally identifies you either directly or indirectly. 

This Privacy Notice helps to explain 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. By visiting www.fruugo.com (“our site”), you are accepting and consenting to the practices described in this Privacy Notice.

Changes to this Privacy Notice

We may amend this Privacy Notice from time to time to make sure it is up-to-date  and accurate. Historic versions can be obtained by contacting us. Any changes we may make to our Privacy Notice in the future will be posted on this page, and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.

We will assume that you agree to the Privacy Notice or revised versions of the Privacy Notice if you continue to use our websites and online services after the effective date shown at the top of the Privacy Notice. 

Data Controller

For the purpose of the Data Protection Act 2018, General Data Protection Regulation 2018 and the Privacy and Electronic Communications Regulations (the “DP legislation”), the data controller is Fruugo.com Ltd. Fountain Street House, Fountain Street, Ulverston, Cumbria, LA12 7EQ, UK. Registration Number: Z1333679.

Data Protection Officer 

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact our Data Privacy Manager using the details set out below.

Our full details are:

• Full name of legal entity: Fruugo.com Ltd

• Email address: dpo@fruugo.com  

• Postal address: Fountain Street House, Fountain Street, Ulverston, Cumbria, LA12 7EQ, UK

Your right to complain

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to address and respond to your concerns before you approach the ICO, so please do contact us in the first instance.

How do we obtain your personal data?

We may collect and process the following data about you:

• Information you give us. You may give us personal information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to any of our services, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, and financial and credit card information.

• Information we collect about you. With regard to each of your visits to our site, we may automatically collect the following information:

• • Technical information, including the Internet protocol (“IP”) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

  • Information about your visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Personal data that we collect and receive from third parties 

We may receive personal information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive information about you from them.

Examples of Information Collected

You provide information to us when you:

• place an order through Fruugo;

• view or use the content on a device, or through a service or application on a device;

• provide information in your Fruugo Account (and you might have more than one if you have used more than one e-mail address or mobile number when shopping with us);

• configure your settings on, provide data access permissions for, or interact with a Fruugo website or service;

• provide information in your Seller Account or any other account we make available that allows you to offer products to consumers on the Fruugo website;

• offer your products or services on or through Fruugo’s websites;

• communicate with us by phone, e-mail, or otherwise; or

• complete a questionnaire, a Helpdesk enquiry or any other form of enquiry. 

Following the above actions, you may provide us with such information as: your name; address and phone number; payment information; age; location information; your IP address; addresses and phone numbers, content included in e-mails to us; information and documents regarding identity and standing; corporate and financial information; credit history information; VAT numbers; and device log files. 

Automatic Information

Examples of the information we collect and analyse include:

• the Internet protocol (IP) address used to connect your computer to the Internet;

• login; e-mail address; password;

• the location of your device or computer;

• content interaction information, including information about your internet service provider;

• device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures;

• version and time zone settings;

• purchase and content use history, which we sometimes aggregate with similar information from other customers to create features such as Best Sellers; and

• the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); cookie number; products and/ or content you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs). 

We may also use device identifiers, cookies, and other technologies on devices, applications and our web pages to collect browsing, usage or other technical information for fraud prevention purposes.

How do we use your personal data and on what basis do we process your personal data? 

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. Where appropriate, we have also identified what our legitimate interests are in processing such data.

Cookies

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. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Interest Based Ads

Fruugo.com Ltd displays interest-based advertising content on our owned or operated sites and on unaffiliated sites. Interest based ads (also sometimes referred to as customised, tailored or targeted ads) are displayed to you on based on information collected from your activities, including but not limited to, browsing or purchasing products on or through our websites, mobile sites and applications or on third party websites, mobile sites and applications, or based on your responses to our marketing emails (collectively, the "Services"). For instance, you may see an advertisement on a Fruugo.com Ltd or third party site for  products, based on information indicating your interest in similar products.

• Information Collected: Pursuant to the terms of our Privacy Notice, the information collected and used for interest based advertising may contain the following, without limitation: age, gender, device unique identity or other device identifiers and settings, information about your use of the Services or other Internet sites, information about advertisements or our marketing emails viewed by you (including as date and time viewed, number of views, the location and duration, and your response, if any).

• Third Party Technologies: Analytics tools and ad serving technologies may use server log files, web beacons, cookies, tracking pixels and other technologies to collect the information listed above. They may combine the information collected through Fruugo.com Ltd products and Services with (a) information collected from third party sites, products and services and/or (b) with demographic, advertisement, market and other analytics data. In addition, some of these technologies can sync or connect your behaviour across different websites, mobile apps and devices. We make our best efforts to provide you with (a) the list of third parties whose ad serving technologies are used in our Services, (b) links to these partners’ own privacy policies according to which their tools and technologies are used, and (c) when available, a link to allow you to opt-out from these partners’ services. You can opt out of some third-party technology’s use of cookies for interest-based advertising by visiting aboutads.info. Of course, please note that opting out does not mean you won't see ads; it just means that the advertising you see may be less relevant to your interests. Standing alone, this information may not be personal information. However, if we combine any of this information with personal information to serve you interest based advertising, then we will provide you an opportunity to choose whether or not to allow such merger, as further described in the Custom Content Section below.

• Custom Content: We may, depending on your preferences, also combine your personal Information with the information you have independently provided third parties, in order to tailor advertisements for you on our Services and/or on third party sites..

• Do Not Track: Do Not Track (DNT) is a web browser setting that is currently under development. While we may adopt a DNT standard if a universal standard is established, in the meantime we adhere to the standards set out in this policy and our Privacy Notice.

Uses made of the information

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant unsubscribe box situated on the form or email on which we collect your data;

• to notify you about changes to our service; and

• to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

• to allow you to participate in interactive features of our service when you choose to do so;

• as part of our efforts to keep our site safe and secure;

• 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.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us however, we will notify you if this is the case at the time.

Who we share your personal data with

We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may use the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisements to that target audience. When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes.

• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

• Credit reference agencies for the purpose of assessing your credit score where which is a condition of us entering into a contract with you.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. If the transfer or sale goes ahead, the organisation receiving your personal data can use your data in the same way as us.

• If Fruugo.com Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. 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 our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Fruugo.com Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Cross-border transfers of your personal data

Some Fruugo retailers are based outside the European Economic Area (EEA). The processing of your personal data for the purposes of fulfilling your product purchase may involve a transfer of data outside the EEA or to countries deemed to provide an adequate level of protection for personal data by the European Commission. We will only transfer your personal data from the European Economic Area (EEA), United Kingdom or Switzerland to third countries, i.e. countries outside the EEA, on the basis of appropriate safeguards or if otherwise authorised by applicable law. In other cases, Fruugo provides the necessary safeguards, e.g. through the conclusion of data protection contracts with the recipients. 

Please see below a list of countries in which Fruugo retailers are currently located:

• Australia

• Austria

• Belgium

• Canada

• China

• Czech Republic

• Denmark

• Finland

• France

• Germany

• Greece

• Hungary

• India

• Ireland

• Israel

• Italy

• Luxembourg

• Malaysia

• the Netherlands

• New Zealand

• Norway

• the Philippines

• Poland

• Portugal

• Romania

• Russia

• Saudi Arabia

• Singapore

• Slovakia

• South Africa

• Spain

• Sweden

• Switzerland

• Turkey

• United Arab Emirates

• United Kingdom

• United States

How long we keep your personal data for 

We keep your personal data in accordance with our internal retention procedures, which are determined by our legal, regulatory and professional obligations including applicable data protection laws and in accordance with good practice. The retention periods may differ depending upon the nature of the data we hold and the reasons why we are holding it, and are subject to change. We only keep your personal data for as long as we need to. When your information is no longer required, we will delete it securely. 

How we protect your personal information

We are committed to ensuring that your personal data is kept secure. In order to protect the information you provide to our website from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss, we have put in place appropriate technical, physical and managerial procedures. All employees and any third parties we engage to process your information are obliged to respect the confidentiality of your personal data.

The data that we collect from you may be transferred to and stored at, a destination inside the European Economic Area ("EEA"). It may also be processed by staff operating inside the EEA who work for us or for one of our suppliers.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. We do not store payment or credit card details nor do we share customer details with any third parties other than for the purposes previously described.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet can never be completely secure. Although we will always 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.

Your data protection rights 

Access to information

The DP legislation gives you the right to access information held about you. Your right to access can be exercised in accordance with the DP legislation. Contact dpo@fruugo.com.  

Your rights

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at dpo@fruugo.com.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read below to find out more about these rights:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. Contact dpo@fruugo.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may have legitimate grounds to refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We aim to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary of Terms

Lawful Basis

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

External Third Parties

• Service providers acting as processors based in the UK who provide IT and system administration services.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Specific third parties, for example (but not limited to) Paypal, Bing, Mailchimp, Google, and Facebook who provide payment services, marketing services, analytics and/or customer service management software.

Contact

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to dpo@fruugo.com.