Our Privacy policy explains the way in which we collect, use, maintain, protect, and disclose the personal information of the users of the Frolo App (the “App” or the “Service”).

 

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it. If you have any comments on this privacy policy, please email them to data@frolo.co.uk.

 

Introduction

 

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.

 

Who we are

 

Frolo Limited

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.

What data do we collect and why

 

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 data@frolo.co.uk.

 

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:

 

• Your name *
• Your picture *
• Your email address *
• Your postcode *
• Your birthday or your age range *
• Your children’s gender and date of birth *
• Your login credentials to social networks such as Facebook, Twitter, and Google if you choose to connect these to your Frolo account.
• records of your correspondence with us if you contact us.
• any information you provided when completing surveys that we use for statistical purposes.
• We collect information on your device identifier and operating system when you use the App.
• details of your visits to the App including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the App resources that you access.

 

 

If you use the Dating functionality of the App, additionally we also collect some or all of the following information:

 

Information about you

 

• Your profile pictures – at least one *
• Your Gender *
• Your Job Title
• Information about your Job
• Your Parenting information *
• Your Height *
• Number of children you have *
• How long you have been single parent *
• Your bio

 

Information about the type of people you are interested in

 

• Age range of potential matches
• Sexual Orientation of potential matches

 

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 collect this information about you for the following purposes when using the App:

 

• to ensure the correct operation of the App and improve the App
• to ensure that data on screens is displayed to you in the most effective way on the device you are using
• if you have given us consent, to provide you with information, products or services that you request from us or which we feel may interest you
• to carry out our obligations arising from any contracts, if applicable, entered into between us and you
• to allow you to participate in interactive features of our service, when you choose to do so
• to notify you about changes to our service or App, which may affect you

 

Profiling and matching

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.

 

User Verification

For the safety of our user community, we verify all users of the App using a 3^rd party called Veriff. We necessarily share your unique user ID with Veriff so that they may perform this service to us and to identify you between our systems and Variff. You can find the Veriff privacy policy at the following address https://www.veriff.com/privacy-policy.

 

We have access to the following information about you on the Veriff system:

 

• IP Location & address
• First & Last name
• Date of Birth
• Gender
• Document country
• Document type
• Document Number
• Document expiry

 

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:

 

• Name
• Gender
• Date of Birth
• Picture taken during verification process

 

You must agree and successfully complete User Verification to be granted access to the App.

People who register to use 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.

 

People who email us

 

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.

 

Whether you email us directly or via any of our generic addresses, we will only use the information you provide to respond to your enquiry and will keep it for 14 days after the last correspondence with you and then remove it, unless you are or become an App user then your data will be stored and processed in line with this privacy policy and any Terms and Conditions related to the services.

 

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’.

 

 

External Sites

 

Frolo Limited is not responsible for the content of external internet sites. You are advised to read the privacy policy of external sites before disclosing any personal information.

 

Who we Share Information With

 

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.

International Transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area. Data is stored using Amazon Web Services (AWS) in the following locations: AWS RDS (our persistent storage), AWS ElasticCache (our caching storage), and AWS ElasticSearch (Search DB.). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

 

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.

 

How long to we store your personal data

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.

 

Disclosing your Information

Unless specified in this Privacy Policy we do not disclose your information with anyone else.

Your rights as an individual in respect of the data we hold

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:

 

• Request access to your data
• Request rectification of your data where there are errors or inaccuracies, or the data is not current
• Request that the data we hold is removed entirely from our systems (the right to have data removed is only applicable where it does not conflict with our legal and regulatory requirements to keep certain records according to the data retention period)
• Request us to restrict processing of your data
• Object to our processing of your data
• Request your data in a format that is commonly used/accepted
• Send your data to another controller
• Withdraw consent already provided – at any time

 

If you have any issues with the service or the provisions set out in the privacy policy, then you may contact us or lodge a complaint with us as detailed within the ‘Complaints or Queries’ section of this Policy,

 

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.

 

Protecting your information

 

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.

 

Complaints or queries

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.

This privacy policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Frolo’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Please see the section How to Contact Us below for ways to get in touch.

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.

 

How to contact us

If you want to request information about our privacy policy or have any other queries or concerns regarding your personal information you can email us at:

data@frolo.co.uk

 

Changes to this privacy notice

We keep our privacy policy under regular review. This privacy policy was last updated on 3 December 2021.