Privacy Policy

Welcome to the Frindow privacy policy.

Frindow Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and use our Frindow online community services. It also tells you about your privacy rights and how the law protects you.

Frindow is public. Your profile on Frindow, and any messages you post in forums on Frindow, are immediately visible and searchable by anyone in countries around the world. You will be visible to all Frindow users as the creator of any calendar invites for get-togethers you organise on Frindow. Other Frindow users may send you messages using Frindow.

Frindow is designed as a forum to foster communication in person, on the message boards, internal mail, in person and by video. Please do not use the Frindow site to share or post any sensitive information that could disclose your home, work or any other address belonging to you, a friend or relative. Do not disclose your bank details, card details or any other information relating to your finances. Do not disclose your date of birth, full name or any details that could reveal your full identity (unless you are an approved third-party service provider).

Frindow does display an approved list of third-party service providers. You may provide your full name, email address and phone number to these service providers when you contact them via the “Email” button on the service provider’s profile. You must not share your private details with these service providers on the public forums. If you choose to contact a service provider via the form on their profile, you must acknowledge that you are passing on your personal information to a third-party. This is done by ticking the checkbox in the service provider’s contact form. The information that you are sharing with the service provider will be outside of the scope of protection offered by this privacy policy.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Frindow Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you register for and use the Frindow service.

Frindow is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Frindow Ltd is the ‘data controller’ and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy). We are a company registered in England and Wales under company number 10668048.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Email address: help@frindow.com

Postal address: 278 Mitcham Lane, Streatham, London, SW16 6NU.

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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

● Identity Data includes first name, last name, username or similar identifier.

● Contact Data includes email address and (for ‘Confirmed’ users), street address.

● Technical Data includes internet protocol (IP) address, your login data, 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 .

● Profile Data includes a photo (optional), languages spoken, marital status, whether you have children, your local authority (which we derive from the postcode you provide ), age (but not date of birth), an optional personal description, and the groups that you belong to on Frindow .

● Usage Data includes your username and password, information about how you use the Frindow website and service, including details of messages you send and receive using Frindow and your use of the video chat feature.

● Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

● Proxy Users . If you have been appointed by someone to operate an account on their behalf, we will receive Identity Data and Usage Data about them from you. You must ensure that you have the express consent (or power of attorney) to use Frindow on their behalf. You must ensure that you present them with or explain to them the provisions of this privacy policy, including their rights set out in the your legal rights section below. Do not disclose any personal data about them in your profile or forum posts.

● Like-minded Questionnaire . Personal information in the form of preferences, likes, lifestyle, values and views are collected for the Like-minded Score feature. In order to fill in the questionnaire, you must explicitly agree that we can collect this personal information from you. This is in accordance with Art. 9 of the General Data Protection Regulation (GDPR) section 2(a) and Art. 6 1(a) and Art. 9 2(a) of UK GDPR. The mechanism for providing explicit permission is on the site prior to the questionnaire starting. The information collected will not be revealed to other Frindow users or third parties. The information can only be used to provide the percentage of similarity between your answers and the answers given by others. The Like-mind Score feature makes no guarantee on how well you will get on with another user, it only seeks to expose the level of similarity based on the questions asked. On leaving the site, any answers provided by you will be associated with an anonymised account making it impossible for the answers to be traced back to you.

● Contacting Third-party Service Providers. If you choose to contact one of our approved third-party service providers, we will collect the information that you have provided, which includes your contact information and what you may need help with, and we will pass that information onto the service provider by email. We do not store the information that you have shared with the service provider in the contact form in our database.

● Third-party Service Providers(for Frindow Business). If you are a third-party service provider operating under Frindow Business, we collect information that would allow a Frindow user to contact you. This includes, but is not limited to, your email address, full name, phone number (optional), website address (optional), postal address (optional) and social media links (optional). You can choose what information is shared on your profile and can edit your profile information at any time. You must confine your contact information to your profile - it must not be shared on the forums.

If a payment is made for your account, we store the data that is sent back from Opayo This data does not include any sensitive card information. No debit or credit card details are stored in our system.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

Frindow is a platform that allows for open discussion (subject to our Acceptable Use Policy ). This may include sensitive information. If we collect any Special Categories or Personal Data about you (which 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), we will not without your consent use it for any purpose that you have not asked us to. For example, if you join a Frindow group for LGBTQ people, we will use this information solely for the purposes of your membership of that group.

If you fail to provide personal data

Where we need to collect personal data by law, or under the Frindow Terms of Service (see here if you are a Frindow Business user: Frindow Business Terms of Service) and you fail to provide that data when requested, we may not be able to provide you with the Frindow service. We will notify you if this is the case at the time. If you are a Frindow Business user, you must provide the minimum information required to publish your profile.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

● Direct interactions. You may give us your Identity and Contact Data by creating an account to use the service (or to receive news about Frindow) on our website. This includes personal data you provide when you create an account on our website; request promotional information to be sent to you; enter a competition, promotion or survey; or give us feedback about the Frindow service or contact us.

● Automated technologies or interactions. As you interact with Frindow, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

● Third parties or publicly available sources . We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from our use of Google Analytics, a tool we use to measure and report usage patterns and trends in relation to visits to Frindow.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

● Where we need to perform the contract we are about to enter into or have entered into with you, under which you are granted access to use the Frindow service subject to our Terms of Service and these Terms of Service for Frindow Business users.

● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

● Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. That means communications originating from us, not sent by other Frindow users. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Lawful basis for processing
To register you as a new Frindow account holder	Performance of a contract with you (under the Frindow Terms of Service)
To determine your status as a ‘Confirmed’ user	Performance of a contract with you (under the Frindow Terms of Service)
To provide you with access to the Frindow service, including personalising Frindow for you, allowing access to the video chat facility, making recommendations for items on Frindow that may interest you, and applying your settings in respect of the Frindow service.	(a) Performance of a contract with you (under the Frindow Terms of Service) (b) Necessary for our legitimate interests
To pass on and receive messages between you and other Frindow users	(a) Performance of a contract with you (under the Frindow Terms of Service) (b) Necessary for our legitimate interests
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Performance of a contract with you (under the Frindow Terms of Service) (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use Frindow)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Necessary for our legitimate interests (for running Frindow and our business generally, 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 a legal obligation
To deliver relevant Frindow content and advertisements to you and measure or understand the effectiveness of the content and advertising we serve to you	Necessary for our legitimate interests (to study how customers use Frindow, to develop it to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, the Frindow service, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for Frindow, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Necessary for our legitimate interests (to develop Frindow and grow our business)
Promotional Messages sent by SMS or email, or for any third party goods or services	Consent
To pass your contact information on to a service provider (such as a coach or a therapist).	Consent
If you are a Frindow Business user, to register you as a new Frindow Business account holder	Performance of a contract with you (under the Frindow Business Terms of Service)
To collect information for the Like-minded Score feature.	Consent

Promotional Messages

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Frindow services may be relevant for you.

You will receive these marketing communications from us if you have requested information from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time

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 about the cookies we use, please click here .

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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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

Other Frindow users will be able to see: your profile, any ‘Get Together’ invites you create on Frindow your posts on forums in Frindow. Any direct messages you send to another user on Frindow will only be seen by the user you send them to, and no other users. We will review your message in the event that it is the subject of a complaint by another user that it is abusive, offensive or otherwise contravenes our Terms of Service.

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

● Service providers acting as ‘data processors’ who provide email, IT and system administration services. These include Mailchimp (our email service provider) and Freshdesk (our customer support partner). Learn more about Mailchimp’s privacy practices here . Learn more about FreshDesk’s privacy practices here .

● Our hosting services partner, Amazon Web Services.

● For Frindow Business users, our payment gateway is Opayo. Learn more about Opaya’s privy practices here .

● For non-Frindow Business users, our payment gateway is Stripe. Learn more about Stripe's privacy practices here .

● In some cases where you use our video chat feature, this will be routed via Twilio, the provider of video chat relay services. Twilio does not retain a record of your video chat, it merely provides a server that assists in routing the chat between you and the other user. Twilio’s privacy practices are set out here .

● Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

● HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

● 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 policy.

6. International transfers

We share your personal data with Mailchimp, our email service provider. This will involve transferring your data outside the United Kingdom and European Economic Area ( EEA ) to the United States. Mailchimp is part of the ‘Privacy Shield’ which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield .

FreshDesk, our customer support partner, may process your data in the USA. It does so under its EU-US Privacy Shield Certification, which requires Freshdesk to provide similar protection to personal data shared between Europe and the US as the protection under EU laws . Learn more about the Privacy Shield here .

Twilio, our video chat relay provider, is based in the USA. It has adopted ‘ binding corporate rules ’ (BCRs). These are binding data protection policies that are approved by European data protection authorities after significant consultation with those authorities and enable multinational businesses, such as Twilio, to make intra-organisational transfers of personal data across borders in compliance with EU data protection law.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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. In addition, we limit access to your personal data to those employees, agents, contractors 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 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

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will 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. Please click on the links below to find out more about these rights:

● Request access to your personal data

● Request correction of your personal data

● Request erasure of your personal data

● Object to processing of your personal data

● Request restriction of processing your personal data

● Request transfer of your personal data

● Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to make Frindow and the best and most secure experience we can. 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 (including under the Frindow Terms of Service).

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Protection of Vital Interests means if we are notified that a user is in need of emergency assistance.

YOUR LEGAL RIGHTS

You have the right to:

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:

● If you want us to establish the data's accuracy.

● Where our use of the data is unlawful but you do not want us to erase it.

● 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.

● 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 Frindow to you. We will advise you if this is the case at the time you withdraw your consent.