Frolo Limited is committed to meeting our legal requirements with respect to Privacy for all who access and use our website. Under the EU/ and UK General Data Protection Regulation (together “GDPR”) and the UK Data Protection Act 2018, we must comply with certain requirements that are designed to ensure that any personal data you provide to us is processed with due care and attention, and that you as an individual are aware of and know how to exercise your rights with respect to any personal data you trust us with.
Registered office address:
Huckletree West Mediaworks
191 Wood ln
London W12 7FP
Company number: 11559309
VAT Number: GB318583287
We are registered as a data controller with the UK Information Commissioner’s Office, registration number: ZB272753.
Frolo Limited collects some personal details when you enter your details into the App registration form, when using the Frolo App, we will also receive some personal information if you email us directly or using email@example.com.
Any use of the data you load into the App is governed by the App Terms and Conditions.
We collect and process then following information:
Note: Information relating to your children’s date of birth is not visible anywhere in the App and is used only by our matching algorithm.
None: Information marked ‘*’ is mandatory
We use the information you provide us, and information we collect, if you allow us, to help you find suitable matches based on your preferences.
Our matching algorithm uses the information you provided and presents to you as a set of filters you can adjust at any time to change the results you see.
You can make your account invisible at any time to prevent your profile being presented to other users.
We have access to the following information about you on the Veriff system:
We also have access to pictures taken during the verification process including the picture taken of you and pictures taken of the front and back of your ID.
We store the following information on our systems to enable us to manage this verification process:
You must agree and successfully complete User Verification to be granted access to the App.
If you register to use the App we collect enough information to enable us to provide you the services the App offers, this includes all information marked as mandatory in section ‘What data do we collect and why’ above. We collect and process this information using the ‘performance of a contract’ legal basis so that we may provide the App and its services to you.
The legal basis of processing all other information we collect from you is ‘Consent’.
Unless you have specifically opted in to receive information about products and services from Frolo during the registration process or when using the App we will not send you any communication other than what is required for the delivery of the service. If you agree to allow us to send you information about Frolo Products and Services by opting into that service, you do that on the basis of consent.
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with company policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
If we consider the contents of an email to contain personal data we have not requested or more detail than we need then we will delete some or all of it immediately and request another with less personal details, or no personal details.
By submitting personal data to us by way of an email or an enquiry you necessarily consent to us using that information to contact you in return to complete that enquiry. We do not use that data for any other purpose. For the avoidance of doubt the legal basis for processing your enquiry is ‘consent’.
We share your public profile with other users of the App.
We also share our data with our App developer, App services provider and our hosting provider.
We share data with our user verification provider Veriff.
Our agreement with them identifies them as a processor and ensures that the data transfer is both legal and secure.
Our agreement with AWS is based on standard contractual clauses with supplementary measures which ensure that, within reason, US Government and Security Services are unable to access our data even if requested from the US parent organisation.
We keep your personal data for as long as we are providing access to the App and its services to you, after you have deleted your account and stopped using the App and its service(s) we keep the data for 12 months, then we anonymise it removing any personal information.
If there is no activity on your account for 12 months or more, we may delete your account and anonymise your personal data by removing any personal information. We will inform you prior to deleting your account and let you know how to prevent your account from being deleted and your personal data being anonymised.
Any data classified as financial that we are required to keep will be retained according to UK HMRC rules, currently 6 years plus current year.
We respect the rights and freedoms of individuals and as such we would like to make you aware of the following.
Depending on the specific circumstances you have the right to:
If you wish to exercise any of your personal data rights, please contact Frolo using any of the methods described under How to Contact us.
You also have the right to lodge a complaint with a supervisory authority, see Complaints or Queries below.
Your information is only accessed by people who need it to perform their role.
Your personal data is encrypted transit.
We will retain personal information only for so long as the information is necessary to fulfil your request or provide you with the services you are using, or until you exercise one of your rights.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Frolo Limited tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously.
We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
If for any reason you believe that Frolo Limited is not in full compliance with the GDPR/UK DPA 2018 or that a request or complaint has not been properly dealt with you have the right to lodge a complaint with the relevant supervisory authority, in the UK this is the ICO.
https://ico.org.uk/concerns/handling/ or call the ICO on 0303 123 1113.
Changes to this privacy notice