PRIVACY POLICY
This privacy policy will inform you about how we handle your personal data when you visit our website (regardless of your location) and explain your privacy rights and the legal protections in place.
1. Important Information and Who We Are
Purpose of This Privacy Policy
This privacy policy provides information on how Frogspawn Marketing Ltd collects and processes your personal data through your use of this website, including any data you may provide when submitting an enquiry, contacting us, or downloading a guide. Please note that this website is not intended for children, and we do not knowingly collect data related to children.
It is crucial to read this privacy policy in conjunction with any other privacy policy or fair processing policy we may provide on specific occasions when collecting or processing personal data about you. This privacy policy supplements other notices and privacy policies and does not intend to override them.
Controller
Frogspawn Marketing Ltd is the controller responsible for your personal data. In this privacy policy, "we," "us," or "our" collectively refer to Frogspawn Marketing Ltd. We have appointed a data protection officer (DPO) who oversees questions related to this privacy policy. If you have any questions or wish to exercise your legal rights, please contact the DPO using the details below.
Contact Details
If you have questions about this privacy policy or our privacy practices, please contact our DPO:
- Email address: dpo@frogspawnmarketing.co.uk
- Postal address: 8 Tavistock Street, Leamington Spa, CV32 5PL
- Phone number: 0121 505 4001
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK regulator for data protection issues, at www.ico.org.uk/make-a-complaint or by telephone: 0303 123 1113. However, we appreciate the opportunity to address your concerns before involving the ICO, so please contact us first.
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We regularly review our privacy policy. It is essential to keep your personal data accurate and up-to-date. Please notify us of any changes to your personal data during our relationship.
Third-Party Links
We may collect information that your browser sends whenever you visit our Service or access the Service through a mobile device.
2. The Data We Collect About You
Personal data, or personal information, includes any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal data we collect about you depends on the activities carried out through our website. We may collect, use, store, and transfer the following personal data:
- Your name, address, and contact information, including email address and telephone number
- Your activities on and use of our website
- Your contact history
- Technical data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
- Information about how you use our website and technology systems
- Marketing and communications data, including your preferences for receiving marketing communications and your communication preferences.
We also collect, use, and share aggregated data, such as statistical or demographic data, for various purposes. Aggregated data is not considered personal data in law, as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data, we treat the combined data as personal data and use it in accordance with this privacy policy.
3. How Is Your Personal Data Collected?
We collect personal data from you:
- Directly, when you enter or send us information, such as when you submit an enquiry form or download a guide.
- Indirectly, through your browsing activity on our website. As you interact with our website, we automatically collect technical data about your equipment, browsing actions, and patterns. This personal data is collected using cookies, server logs, and similar technologies. For further details, please refer to our cookie policy.
We also receive personal data about you from various third parties, as outlined below:
- Technical data from analytics providers like Google, based both inside and outside the UK.
- Technical data from advertising and social media networks, based both inside and outside the UK.
- Technical data from search information providers, based both inside and outside the UK.
4. How We Use Your Personal Data
Under data protection law, we can only use your personal data if we have a valid reason, such as:
- Your consent.
- Compliance with legal and regulatory obligations.
- Pursuing legitimate interests, ours or those of a third party, provided your interests and fundamental rights do not override those interests.
We will conduct an assessment when relying on legitimate interests to balance our interests against your own. Details of this assessment are available upon request (see 'How to contact us' in the "Your Legal Rights" section below).
Purposes for Which We Will Use Your Personal Data
The table below provides a description of all the ways we intend to use your personal data, along with the legal bases for doing so. When appropriate, we identify our legitimate interests.
If the type of data processed involves Special Category Data, we will rely on explicit consent in addition to other lawful bases, as relevant.
Note that we may process your personal data for more than one lawful ground, depending on the specific purpose. Please contact us for details about the specific legal ground(s) for processing your personal data when multiple grounds are stated in the table below.
What we use your personal data for
Type of data
Our reasons/lawful basis for
processing including basis of
legitimate interest
Providing general information regarding products and services offered by our suppliers that may be of interest to you
(a) your name, address and
contact information, including email address and telephone number
(a) Your consent to provide
- marketing services to third parties;
(b) necessary for our or third party legitimate interests (i.e. to realise or grow the value in our business and assets)
To manage our relationship with you which will include:
(a) notifications not related to marketing, including about changes to our terms or policies or other important notices
(b) asking you to leave a review or take a survey
(a) your name, address and contact information, including email address and telephone number
(a) necessary to comply with a legal obligation
(b) necessary for our legitimate interests (to keep our records updated and to study how website users use our website)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) your name, address and contact information, including email address and telephone number
(b) technical data such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
(a) 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)
(b) necessary to comply with alegal obligation
To use data analytics or to share your personal data with advertising and social media networks and search information providers to improve our website, marketing and user experiences and to grow our business and inform our marketing strategy.
(a) your name, address and contact information, including email address and telephone number
(b) your activities on, and use of, our website
(c) your contact history
(d) technical data such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
(e) information about how you use our website and technology systems
necessary for our legitimate interests (to define types of users of our website, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consent where relevant
(a) your name, address and contact information, including email address and telephone number
To comply with our legal and regulatory obligations
To share your personal data with third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases information will be anonymised where possible and only shared where necessary
(a) your name, address and contact information, including email address and telephone number
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) your name, address and contact information, including email address and telephone number;
(b) your activities on, and use of, our website;
(c) technical data such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
(d) information about how you use our website and technology systems
necessary for our legitimate interests (to develop our products/services and grow our business)
How and Why We Use Your Personal Data - Sharing
For details on how we protect your personal data when sharing it with others, please refer to the 'Disclosures of Your Personal Data' and 'International Transfers' sections.
Marketing
We use your personal data to send you updates (by email or phone, including SMS) about our website. Additionally, we may use your personal data to determine your preferences and interests, allowing us to tailor our marketing efforts. This is referred to as "marketing," and we have a legitimate interest in using your personal data for this purpose (see 'How We Use Your Personal Data' above). Consequently, we do not require your consent to send you marketing information. If we alter our marketing approach in the future to require consent, we will request it separately and explicitly.
You have the right to opt out of receiving marketing communications at any time through:
- Contacting us at help@frogspawnmarketing.co.uk
- Using the 'unsubscribe' link provided in emails.
If there are changes in the law, regulations, or our business structure, we may request you to confirm or update your marketing preferences.
We always treat your personal data with the utmost respect and never share or sell it with other organizations without your explicit consent. For additional information on your right to object to the use of your personal data for marketing purposes at any time, please refer to the 'Your Legal Rights' section below.
Third Party Marketing
Before sharing your personal data with any third party for marketing purposes, we will obtain your express opt-in consent.
Change of Purpose
We will only use your personal data for the purposes for which we initially collected it, unless we reasonably determine that it should be used for another purpose that aligns with the original one. If you require an explanation of how the new processing purpose is compatible with the original purpose, please contact us. Please note that, in compliance with the above rules, we may process your personal data without your knowledge or consent when required or permitted by law.
5. Disclosures of Your Personal Data
We may share your personal data with the following parties for the purposes outlined in the table:
(a) Service Providers and other third parties serving as processors, based in the United Kingdom, providing IT and system administration services to us.(b) Providers of data analytics services, advertising and social media networks, and search information providers, based in the United Kingdom, providing information to enhance our website, marketing, user experiences, business growth, and inform our marketing strategy.(c) Professional advisers serving as processors or joint controllers, including lawyers and the DPO based in the United Kingdom, providing consultancy and legal services.(d) Regulators and other authorities serving as processors or joint controllers, based in the United Kingdom, requiring reporting of processing activities in specific circumstances.(e) Third-party providers of professional services for commercial kitchens (e.g., design, installation, servicing, supplying, repair, and maintenance), serving as controllers, based in the UK, to whom we provide marketing services.(f) Third Parties to whom we may choose to sell, transfer, or merge parts of our business or assets. In the event of a change to our business, the new owners may use your personal data in accordance with this privacy policy.
We require all third parties to respect the security of your personal data and treat it in compliance with the law. We do not permit our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes, following our instructions, and obtaining explicit consent when necessary.
Further Information
For more information about who we share our data with and why, please contact us (see 'How to contact us' in the "Your Legal Rights" section below).
6. International Transfers
Many of the third parties we share your data with are located outside the UK, involving a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar level of protection by implementing at least one of the following safeguards:
(a) Transferring your personal data to countries deemed to provide an adequate level of protection for personal data.(b) Using specific contracts approved for use in the United Kingdom when we use certain service providers, providing the same level of personal data protection as in the United Kingdom.
Please contact us for further information about the specific mechanism we use when transferring your personal data outside the United Kingdom. Any changes in the destinations or transfer mechanisms for personal data will be notified to you in accordance with the 'Changes to the privacy policy' section in Important Information and Who We Are above.
Further Information
If you require more information about data transferred outside the UK and EEA, please contact us or our Data Protection Officer (see 'How to contact us' in the "Your Legal Rights" section below).
7. Data Security
You have the right to exercise your rights of access, rectification, cancellation, and opposition by contacting us. Note that we may verify your identity before responding to such requests. We will make every effort to respond as soon as possible.
If you are in the European Economic Area (EEA), you have the right to lodge a complaint with your local data protection authority in the EEA regarding our collection and use of your Personal Data.
8. Data Retention
We will not retain your personal data longer than necessary for the purpose for which it was collected. The reasons for retaining data include fulfilling the purposes we collected it for, meeting legal, regulatory, tax, accounting, or reporting requirements, handling complaints, or anticipating potential litigation concerning our relationship with you.
To determine the appropriate retention period, we consider factors such as the amount, nature, and sensitivity of personal data, the potential risk of unauthorized use or disclosure, the purposes of processing, applicable legal and regulatory requirements, and whether those purposes can be achieved through other means. In some cases, we may anonymize your personal data for research or statistical purposes, allowing us to use this information indefinitely without further notice. In any event, once the relevant retention period ends, we will delete or anonymize your personal data.
9. Your Legal Rights
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of 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.
Correction (also known as rectification)
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.
Erasure (also known as the right to be forgotten)
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.
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. 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.
To object to use
The right to object:
- at any time to your personal data being used for direct marketing (including profiling)
- in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
We do not make any such decisions based on data collected by our website
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by emailing help@frogspawnmarketing.co.uk
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
If you withdraw your consent, we may not be able to provide certain information or offers to you. We will advise you if this is the case at the time you withdraw your consent.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- Provide enough information to identify yourself i.e. your full name and email and any additional identity information we may reasonably request from you, and
- Let us know which right(s) you want to exercise and the information to which your request relates.
No Fee Usually Required
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 could refuse to comply with your request in these circumstances.
What We May Need From You
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.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally, it could 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.
How to Contact Us
You can contact us and/or our Data Protection Officer by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Frogspawn Marketing Ltd. 8 Tavistock Street, Leamington Spa, CV32 5PL help@frogspawnmarketing.co.uk Phone number: 0121 505 4001
DPO
8 Tavistock Street, Leamington Spa, CV32 5PL dpo@frogspawnmarketing.co.uk Phone number: 0121 505 4001
Do You Need Extra Help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).