Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.frontierpay.com you are accepting and consenting to the practices described in this policy.
For ease of reading, we have divided this policy into several sections:
- Who we are
- What information do we collect and how do we collect it?
- How and why do we use/share your information?
- How long do we keep your information for?
- Your Rights
- Contact Details
Please note that our Site is not intended for children (those aged 13 and under) and we do not knowingly collect data relating to children.
We may change this policy from time to time and at our absolute discretion. We will do so by updating this page. You should check this page from time to time to ensure that you are happy with any changes and are aware of the most up to date version of this policy.
This policy was last updated on 22.05.2018.
1. Who we are
www.frontierpay.com (our “Site") is operated by Frontierpay Limited. We are a registered company in England and Wales under company number 07061945 and have our registered office at Lynton House, 7-12 Tavistock Square, London, United Kingdom, WC1H 9LT.
The controller responsible for your personal data is Frontierpay Limited.
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, or if you think it has not been followed, please contact the Data Privacy Manager using the details set out below.
2. What information do we collect and how do we collect it?
We may collect and process the following data about you:
Information you give us
You may give us information about you by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Site, subscribe to our service, place an order on our Site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey, book any transaction and when you report a problem with our Site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
Information we collect about you
With regard to each of your visits to our Site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources
We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
What is personal data?
Where this policy refers to ‘personal data’ it is referring to data about you (or other living people) from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.
By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this policy.
3. How and why do we use/share your information?
Using your information
Here are some examples about how we may use the information we collect about you:
- Enhance your user experience;
- Provide analytics, consultancy and other services to third parties;
- Operate our service and send you information you request on our Site;
- Contact you for “service administration purposes” regarding any service you have signed up for or used. For example, we may wish notify you that a particular service has been suspended for maintenance.
For the avoidance of doubt, we will not contact you for promotional purposes, such as notifying you of unrelated new services unless you specifically agree to be contacted for such purposes at the time you submit your information on our Site, or at a later time if you sign up specifically to receive such promotional information.
Why are we allowed to use your information in this way?
We will only use your personal data in the following circumstances:
- Where you have asked us to do so, or consented to us doing so.
- Where we need to do so in order to perform a contract we have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Sharing your information
Depending on how and why you provide us with your personal data. We may share it in the following ways:
- We may disclose your data to our agents or third party service providers to undertake processing operations on our behalf (see ‘Service Providers’ below).
- We may analyse and disclose aggregate statistics about users of our services in order to provide services to our agents and service third parties and for other lawful purposes, but these statistics will include no personally identifying information.
- We may disclose personal data if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of our Site or its visitors.
Our service providers provide us with a variety of administrative, statistical, and technical services, for example, banking, IT and sales support. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.
Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld.
Links to third party websites
Please note that where we provide links to third party websites that are not affiliated with us such websites are out of our control and are not covered by this policy. If you access third party websites using the links provided, the operators of these websites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to these websites.
4. How long do we keep your information for?
Except if required otherwise by law, we retain your personal data for as long as necessary to fulfil the purposes for which we collect it and also where we have a legitimate interest in doing so, such as:
- To enable us to respond effectively to grievances that may arise after you cease to engage with us; or
- Where you sign up to receive e-mail marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving e-mails in order to ensure that we continue to honour and respect that request.
You can ask us to access, rectify or, in some circumstances, delete your personal data: see ‘Your Rights’ below for further information.
In some circumstances we may also anonymise your 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.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect, for example:
- Personal Data is encrypted using SSL.
- Personal Data is securely stored on a server with firewall protection.
- The server storing Personal Data is backed up using a cloud based solution that is also encrypted.
- Robust antivirus software is used.
7. Your Rights
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the section of this policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
8. Contact Details
If you have any queries regarding this policy, or if you think that it has not been followed, please contact:
The Data Privacy Manager
33 Stokenchurch Business Park
Alternatively, you can contact us at firstname.lastname@example.org.
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.