Fruugo Privacy policy

PRIVACY POLICY, PRINCIPLES FOR PERSONAL DATA PROTECTION
Description of the personal data file: the customer register for Fruugo products and services.

PURPOSE OF THE PERSONAL DATA FILE AND GENERAL DESCRIPTION OF FRUUGO'S PRIVACY PRINCIPLES

The basis for processing personal data is the consent of the data subject, customer relationship or other relevant connection between the data subject and the operations of Fruugo.

Fruugo respects the privacy of its customers and is committed to comply with applicable data protection and other laws. Throughout this Policy the term "personal data" shall mean information relating to an identified or identifiable individual, that is, a natural person. "Fruugo" shall refer to Fruugo Ltd. and its subsidiaries.

This Privacy Policy is also the description of personal data file for Fruugo's products and services, describing the processing of personal data collected in connection with Fruugo's products and services.

Furthermore, additional information on the personal and other data collected in connection with the service in question and on its processing may be provided in connection with certain Fruugo services. Such additional information, should it contradict with this Policy, shall take precedence over the Policy.

By using this website you are expressing your agreement to the processing of your personal data in the manner provided in this Policy. If you do not agree with the processing of your personal data in accordance with this Policy, please do not use the Fruugo website or services.

DATA CONTAINED IN THE PERSONAL DATA FILE

Your personal data is collected when you register as a user of Fruugo's services, in connection with the sale of products and services and with the use of services, as well as in connection with promotional and sales campaigns related to Fruugo products and services.

Your personal data may also be collected from personal data files controlled by third parties, such as the Population Information System, "Robinson Lists" maintained by the Finnish Direct Marketing Association and other corresponding personal data files. The personal data collected by us includes, inter alia, data belonging to the following categories:

• Technical data. Although it is generally possible to browse the Fruugo website without the need for registration or identification, your browser submits certain information to Fruugo, such as your IP address, date and time of browsing, the site from which you came to Fruugo, the pages you visit, the links you use and the content you browse. Other technical data which is collected may also be created in connection with the use of Fruugo products and services. For example, your telephone number, the date and time of using the service and other data describing your use of service may be transferred to Fruugo as part of normal data communications. Fruugo uses cookies on its websites. For further information on the use of cookies, please see User Identification and the Use of Cookies.
• Information submitted by the customer. Fruugo may collect the following data in connection with its products and services: customer's name, address, telephone number, e-mail address. We may also collect other contact details required for the delivery of products and services, customer communications and user identification.
  Moreover, we may collect demographic information such as age, gender, language, place of residence as well as information pertaining to your preferences, wishes and consents, required by us, for example, to develop our products and services and to target our services.
  In connection with some of our services we may also collect information relating to other persons, for example, when you want us to deliver the products you have purchased to another recipient.
• Information relating to customer and contractual relationships. We collect information concerning matters relating to customer and contractual relationships, such as the products and services you order and/or use, contracts, contacts and customer complaints, as well as information relating to the provision and use of warranty and other services. We also collect information relating to the payment and invoicing of products and services, such as invoicing address and credit card information, as well as information relating to the validation of credit information and other corresponding financial information. We may also record customer service calls and collect other information related to the interaction between you and Fruugo and between you and the retailer represented by us.

PURPOSE OF THE PERSONAL DATA FILE

We use your personal data for the following purposes:

• Provision of products and services. We may use your personal data to manage your orders, to enforce contracts and other corresponding obligations, and to respond to your requests and queries. Personal data may also be used to identify users, to provide products and services, to ensure information security, and to prevent and investigate misuse within the limits of the applicable law. Your personal data will not be disclosed to third parties for marketing purposes without your consent.
• Development of products and services. Your personal data may be used for the development of Fruugo's products and services. We primarily use statistical and other corresponding information that cannot be used to identify individual users. Your personal data may also be used for the targeting of our products and services, for example, to allow us to show customised content to you. We may compile statistics required for the development of products and services and aggregate information collected in connection with different products and services insofar as the data was collected for the same purpose.
• Customer communications and marketing. Within the limits of the law, your personal data may be used for the marketing of the products and services of Fruugo and the retailers and partners represented by Fruugo, for direct marketing, for marketing research and for customer communications, for example, to inform you of our products and of matters relating to our services. We may also conduct surveys related to customer satisfaction.

SHARING OF DATA

Fruugo does not sell, lease or otherwise disclose your personal data other than in the following situations:

• Consent. We may disclose your personal data insofar as you have given your consent. Some of our services may be of such a nature that they publish users' personal data, such as community services and services that users may use to publish their own content.
• Subcontractors and Retailers. Your personal data may be disclosed to Fruugo's subcontractors insofar as they participate in the implementation of the purpose of the service described in this Policy. Your personal data which is necessary for the delivery of the product purchased by you (e.g. name, address and telephone number) will be disclosed to the retailer who is selling the product and to the logistics service provider who is taking care of the transportation of the product. Such third parties may not use your personal data for any other purpose than for the provision of the relevant service for which the data was disclosed; such third parties are obliged by us to keep your data confidential and to ensure that sufficient information safety measures have been taken to protect your personal data.
• International Data Transfers. Your personal data may be transferred between different countries. When products are ordered to be shipped from outside of the EU-area we may transfer personal data to countries that have different legal rules on data protection than the rules set by the law of Finland. In such cases we take steps to ensure the protection of personal data, such as with contracts on confidentiality and data protection as provided by law, and by applying for example the standard agreements approved by the European Commission.
• Mandatory Disclosures. Your personal data may be disclosed to authorities on the basis of demands made under applicable legislation.
• Mergers and Acquisitions. Should Fruugo sell its business or a part thereof, the personal data related to the business in question may be transferred to the new owner.

PROCESSING OF DATA RELATING TO MINORS

We avoid collecting personal data of persons under the age of 16. Since it may be difficult to verify the age of the users of the service, information relating to persons under the age of 16 may end up in our databases.

Our policy is that minors (in Finland persons under the age of 18) may not make purchases or engage in other legal acts on this site without the consent of their parent or legal guardian.

DATA QUALITY

We take reasonable steps to keep the personal data we possess accurate and up-to-date. Certain Fruugo services may allow users to manage their own personal data. Please remember that it is your responsibility not to provide Fruugo with false information.

SECURITY

While there are always risks associated with providing personal data, and no technology or process is completely safe, Fruugo takes appropriate technical and organisational information security measures to protect personal data against unauthorised access, disclosure or other unauthorised processing, considering the nature of the data, technical opportunities for data protection, relevant threats and data protection costs.

Such measures include, where appropriate, the use of firewalls, encryption, secure server facilities, implementing proper access rights management systems and processes, adequate instructions for persons involved in data processing, careful selection of subcontractors, and use of contractual and other relevant measures. We use technology complying with relevant standards to ensure the confidentiality of our transactions.

USER IDENTIFICATION AND THE USE OF COOKIES

Fruugo may use cookies on its website. Cookies are small files sent to your computer from our website, enabling the collection of certain information about your computer, including your IP address, your computer's operating system, your browser type and the address of the site from which you came to Fruugo's website. The use of cookies is intended to provide benefits to you, such as eliminating the need for you to enter your password frequently during a session or the need to re-enter items you place in a shopping cart if your shopping for some reason is interrupted. Cookies are also used for website traffic analysis so that we may develop our services.

We may also use so-called "web beacons" in connection with some websites. We do not use web beacons to identify individual users, but to develop our websites. Web beacons are typically graphic images placed on a website, which can be used to collect information on the use of the website. Web beacons do not typically produce information other than the information submitted by the user's browser to the service provider as part of the use of services. They also enable the analysis of cookies. If the use of cookies is not allowed, web beacons will be unable to track users' actions, but they will still be able to collect information produced by your browser.

If you do not wish to receive cookies, or want to be notified before they are placed, you should change your browser settings accordingly if the browser allows you to do so. However, please note that if you disable cookies, you may not be able to use all of the services or functionality on the website. Some service providers whose content is linked to or from the Fruugo website may also use cookies or web beacons on their websites. Fruugo does not have access to or control over such cookies.

YOUR RIGHTS

Within the limits of applicable law, you have the right to check the information relating to you that we have collected. Within the limits of applicable law, you have the right to demand that false, unnecessary, deficient or outdated personal data be corrected or removed. You also have the right to forbid Fruugo from processing information relating to you for purposes of direct advertising, remote sales or other direct marketing or marketing and opinion surveys.

In order to exercise the rights described above, you should send a signed written request to:

Fruugo.com Ltd
Privacy
Fountain Street House
Fountain Street
Cumbria
LA12 7EQ
UK

NAME OF PERSONAL DATA FILE AND CONTROLLER

The controller is Fruugo.com Ltd. (Company No: 6553460), 13 Fountain Street, Fountain Street, Ulverston, Cumbria, LA12 7EQ, United Kingdom.

Registration Number: Z1333679

CHANGES TO THE DESCRIPTION OF PERSONAL DATA FILE

We reserve the right to change the contents of this description of personal data file at any time. If the contents of this description of personal data file are materially weakened from the point of view of the data subjects, the data subjects shall be notified of such changes in the Fruugo service for 30 days.