Frisk Privacy Notice
Last updated: [10/01/2020]
Frisk Online Limited ("Frisk Online", "us", or "we") respects your right to privacy.
This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our websites at: https://frisk-online-shop.myshopify.com; https://www.frisk-online.com; https://www.frisk-online.net; https://www.frisk-online.co.uk; https://portal.frisk-online.
What does Frisk Online do?
Frisk Online is headquartered in the UK. We provide e-learning Software and training for business, unique digital design assets, such as branded characters, to complement the training, and specialised consultancy services to the fintech sector. Through the Frisk Online Portal (which is accessible via our Site) we give Customers access to our Training Materials and the ability to create their own Customer Materials, including electronic study packs that can be issued to Users through the Portal. We also sell Training Materials to Customers and Private Individuals through a Shopify shop (https://frisk-online.com). For more information about Frisk Online, please see our homepage at https://www.frisk-online.com.
What personal information does Frisk Online collect and why?
The personal information that we may collect about you falls broadly into the following categories:
— Information that you provide voluntarily
Certain parts of our Site may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details (including your full name, email address, employer details, department name, job title and industry sector) to us in order to register a trial account with us on behalf of your employer, subscribe to marketing communications from us, update Training Materials or Transcripts and/or submit enquiries to us on behalf of your employer. Individuals may voluntarily enquire about our Services or purchase training materials via our Shopify shop.
We may also collect information such as your postcode, preferences or interests and other information if you choose to provide this to us, for example as part of a customer survey. Where you use our Services, you may also upload personal information to our Site. As such, we may monitor any information transmitted or received through our Site to ensure compliance with our Terms and Conditions (found here: https://frisk-online.com/policies/terms-of-service).
We may also use your personal information for the purpose of managing the general business relationship with Frisk Online, including contract management. For example, we may use your personal data to enable us to deliver our services to your employer, audit the provision of our services to your employer, manage our daily business activities (such as invoicing and billing), manage any queries, complaints or claims relating to our services, for product development purposes (i.e. to allow us to improve our products and services, or develop new products and services), and to help us conduct our business more effectively and efficiently. The personal information that you are asked to provide, and the reasons why you are asked to provide it will be made clear to you when we ask you to provide your personal information.
— Information that we collect automatically
When you visit our Site or access Frisk Lessons through your Target Learning Management System (TLMS), we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (EEA), this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information such as your IP address, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site to our visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
Additionally, when you visit our Shopify shop and make a purchase or attempt to make a purchase, we collect certain information from you, including your name, billing address, shipping address, payment information (including payment card numbers, sort code and cardholder name), email address, and phone number. We refer to this information as “Order Information”.
Order information is used to:
- Fulfil any orders placed through the site
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
Who does Frisk Online share my personal information with?
We may disclose your personal information to the following categories of recipients:
to our third party services providers and partners, who provide data processing services to us (for example, those who support the delivery of, provide functionality on, or help to enhance the security of our Site), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
to Shopify and Google, when you visit our Shopify shop. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. Shopify also use Google Analytics. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. Please see the “Behavioural advertising” header below to see how Shopfiy use personal information for advertising purposes.
to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
to any other person with your consent to the disclosure.
The Frisk Online Portal does not use personal information for any behavioural advertising purpose. However, when you visit our Shopify shop, Shopify does use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Please note: Shopfiy does not alter the collection of data and uses practices when a Do Not Track signal is detected via your browser.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only (i) where we need the personal information to perform a contract with you or your employer, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Site and communicate with you as necessary to provide our services to your employer and for our legitimate commercial interests, for instance, when responding to your queries, improving our Site, updating you with more information about training materials you are permitted to view (in accordance with your licence), undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact email: firstname.lastname@example.org
Cookies and similar tracking technology
How does Frisk Online keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures that we use include: operating a security policy, encrypting each page of our Site with a valid HTTPS certificate and secure coding frameworks.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident, if we store billing contacts on Google ‘G Suite’, 'Google Analytics' and 'Shopify' for example. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Our Site servers are located in Ireland, and our group companies and third-party service providers and partners generally operate within the European Economic Area ("EEA"), with the exception of Shopify (who transfer data outside Europe, including to Canada and the United States). This means that when we collect your personal information we may process it in any of these countries.
If we do need to transfer personal information outside the EEA, we will take appropriate safeguards to require that your personal information remains protected in accordance with this Privacy Notice. These will include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information to our third-party service providers and partners, where applicable, to protect personal information they process from the EEA in accordance with European Union data protection law. Further details can be provided upon request.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so; for example, to provide you with a service that you (or your employer) have requested us to provide, or to comply with applicable legal, tax or accounting requirements. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
You have the following data protection rights:
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting: email@example.com.
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details: firstname.lastname@example.org.
The data controller of your personal information is Frisk Online Limited, a UK company with company number 06534650 and registered office address 22 Downhurst Road, Ewhurst, Cranleigh, Surrey, GU6 7QB. Our ICO registration number is Z1457593.