Privacy Policy

Fruugo.com Ltd. (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) 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. By visiting www.fruugo.com (“our site”) you are accepting and consenting to the practices described in this policy.

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

We have appointed a data privacy manager 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 the 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

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 chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Information we may collect from you

We may collect and process the following data about you:

Information you give us. You may give us 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, 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.
Information we receive from other sources. We may receive 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, credit reference agencies) and may receive information about you from them.

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 see our Cookie policy.

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;
- 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;
- 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 but we will notify you if this is the case at the time.

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. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact (c) Profile	Performance of a contract with you.
To process and deliver your order, including: managing payments, fees and charges; and managing your queries through our Customer Service team – this may include recording calls to our teams.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	Performance of a contract with you. We may also use some of the data related to your queries for our legitimate interests of ensuring our customer service quality standards are met.
To collect and recover money owed to us in respect of your order	(a) Identity (b) Contact (c) Financial (d) Transaction	Necessary for our legitimate interests (to recover debts due to us).
To carry out fraud assessments	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical	Necessary for our legitimate interests of ensuring payments are not fraudulent
To process your purchase of a gift voucher from us	(a) Identity (b) Contact (c) Financial (d) Transaction	Performance of a contract with you.
To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy	(a) Identity (b) Contact (c) Profile	Necessary for our legitimate interests of ensuring our customers are updated on these changes.
To help us improve our offering to our customers, including asking you to leave a review or take a survey, or provide customer insights	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business).
To enable you to partake in a prize draw or competition	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Performance of a contract with you to fulfil the promotion and run the competition/prize draw. We may also subsequently use your entries for the legitimate interests of understanding our customer base more effectively.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Profile (d) Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
To deliver relevant website content, advertisements and other marketing material to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business to inform our marketing strategy and to improve our offering to you). Please note that where cookies are used for this purpose, this is covered separately by our Cookies Policy.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). Please note that where cookies are used for this purpose, this is covered by our Cookies Policy.
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business, and to improve our offering to you).

Disclosure of your information

We may share your personal information 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 make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement 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 this 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.

International transfers

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 countries deemed to provide an adequate level of protection for personal data by the European Commission.

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
Netherlands
New Zealand
Norway
Philippines
Poland
Portugal
Romania
Russia
Saudi Arabia
Singapore
Slovakia
South Africa
Spain
Sweden
Switzerland
Turkey
United Arab Emirates
United Kingdom
United States

Where we store 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 3rd 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.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. 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 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. 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 on 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 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 try 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.
Comply 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, Facebook who provide payment services, marketing services, analytics and/or customer service management software.

Changes to our privacy policy

This version was last updated on 24th May 2018 and historic versions can be obtained by contacting us. Any changes we may make to our privacy policy 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 policy.

Contact

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

Cookies policy

A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.

We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website but the information does not usually identify you directly. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

These also include social media plug-ins which enable you to share our website content via your social media account(s) or easily share information with others. We have a presence on YouTube, LinkedIn and Twitter, and if you click on any of these icons on our website, you will be taken to our pages or profiles on those platforms. The platforms may then start tracking your behaviour using cookies for their own purposes; for example, to better understand your interests so that they can present relevant content or advertising to you. Data about you may also be transmitted to the social media channel even if you do not click on the plug-in. The social media platforms will provide us with statistical information, which we use to help understand how you and our other users interact with our social medial presence. All these platforms provide you with some control over their use of non-essential tracking technology and you can find details of how to exercise this control by reviewing their privacy and cookie notices. We have contractual arrangements in place with the social media channels we use. Please contact us for more information.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Below we describe the cookies which are installed upon this website.

You can change your cookie preferences at any time by clicking on the icon at the bottom left of this webpage. You can then adjust the available sliders to “On” or “Off” and then click “Save and close”. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:

If you use a smart phone, you can usually prevent cross-site tracking and block cookies in the settings section on your device. You may also be able to visit websites without leaving a history by turning private browsing on. You should visit the support section of the website of your device for more information on how to do this.

Strictly necessary cookies

These cookies are always active and are necessary for this website to function. They cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Function provider	Cookie name	Data stored	Purpose	Duration
Youtube.com	LOGIN_INFO, 1p_JAR, ANID, APSID, CONSENT, DSID, GPS, HSID, SID, SSID, IDE, NID, OGP, OGPC, PREF, SAPISID, SID, SIDCC, SSID, VISITOR_INFO1_LIVE, YSC, permutive-id, permutive-session, watched_video_id_list, demographics	Various unique identifiers, as well as login information that may relate to a Google account.	Video functionality	Some of the cookies expire up to 20 years after your last visit to a page containing a Youtube video, although some expire sooner.
fruugo.com	PHPSESSID	Works by creating a unique id (UID) for each visitor and stores variables based on this UID.	Session cookie	When browsing session ends.
	moove_gdpr_popup		Cookie set by the UK cookie consent plugin to record that you accept the fact that the site uses cookies.
BrighterIR	AWSALB, AWSALBCORS		Cookie set by Amazon Web Services Load Balancer to preserve server session stickiness.	1 week

Performance cookies

These cookies allow us to count visits and traffic so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular, and see how visitors move around the site.

All information that is collected by these cookies is aggregated, and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

These cookies are set by the Google Analytics service, but hosted by Fruugo.

Host	Cookie name	Duration
fruugo.com	_ga	1 year
fruugo.com	_gat	1 minute
fruugo.com	_gid	24 hours

Targeting cookies

We do not currently use targeting cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you require further information please contact us by emailing dpo@fruugo.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above and with business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, and credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

External Third Parties as set out below.
Specific third parties such as HMRC.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

External third parties

Service providers acting as processors based in the UK who provide Investor Registrar services, Nominated Adviser and Broker services, and marketing services.
Professional advisers based in the UK who provide banking, legal, insurance, accounting and auditing services and company secretarial services.
HMRC, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Fraud prevention agencies, credit reference agencies, HM Courts & Tribunals Service.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with our instructions. If you require further information please contact us by emailing dpo@fruugo.com.

6. International transfers

We do not transfer your personal data outside the European Economic Area (“EEA”) to be used by any other party. We do however use US-based cloud email and storage system providers. This will therefore involve transferring your data outside the EEA.

Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

If you require further information please contact us by emailing dpo@fruugo.com.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology. Of course, data transmission over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet. You are responsible for keeping your password and user details confidential. We will not ask you for your password.

In addition, we limit access to your personal data to those employees, agents and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention and storage

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We review the personal data that we hold every 12 months.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for accounting, tax and legal purposes. This also helps us, for example, in the event that there is a complaint about our Services, to respond to you in full.

Details of retention periods for different aspects of your personal data are available from us by emailing us at dpo@fruugo.com.

In some circumstances, you can ask us to delete your data: see “Request erasure” below for further information.

In other circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

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 email us at dpo@fruugo.com with specific details of who to contact for subject access rights.

No fee usually required

Data Subjects have the right to access their personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing.

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, or requires copies of previously provided information. Alternatively, we may refuse to comply with your request in these circumstances.

In the event of manifestly unfair or excessive requests, we may refuse to respond to the request and any such refusal will be notified to the requester with a reason for the refusal and, in addition, information as to your rights to complain to the ICO or judicial authority within one month of such a request being received.

Information we may collect from you

Cookies

Uses made of the information

Disclosure of your information

International transfers

Where we store your personal data

Access to information

Your rights

Glossary of Terms

Lawful Basis

Third Parties

External Third Parties

Changes to our privacy policy

Contact

Cookies policy

Strictly necessary cookies

Performance cookies

Targeting cookies

Change of purpose

5. Disclosures of your personal data

External third parties

6. International transfers

7. Data security

8. Data retention and storage

How long will you use my personal data for?

9. Your legal rights

You have the right to:

No fee usually required

What we may need from you

Time limit to respond