Frenkels Calculator Limited ("we", "us" or "our") is committed to protecting and respecting your privacy. We own and operate the Website.
- 1. About us
3. Information we may collect from you
- 3.1 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).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- 3.2.1 Identity Data includes your title, name, date of birth and business name.
- 3.2.2 Contact Data includes your address, email address and telephone numbers.
- 3.2.3 Financial Data includes bank account and payment card details.
- 3.2.4 Transaction Data includes details about payments to and from you and other details of Services you have purchased from us.
- 3.2.5 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 the Website.
- 3.2.6 Profile Data includes your username and password.
- 3.2.7 Usage Data includes information about how you use the Website and the Services.
- 3.2.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- 3.2.9 Service Data includes information that you provide in order to use, and whilst using, the Services, including information (and personal information) about, and of, your clients. Note that Service Data is personal data that we are not a controller of; we are a processor of that personal data only, and our commitments in respect of Service Data are set out in our Terms and Conditions.
- 3.5 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel the Services you obtain from us but we will notify you if this is the case at the time.
- 3.6 You should only submit to us or the Website information which is accurate and not misleading. You should keep that information up-to-date and let us know if any of that information changes by emailing us at firstname.lastname@example.org.
- 3.7 By submitting your or anyone else’s data to us or the Website, you must ensure that you have full authority and consent to supply us with that data on their behalf and you warrant to us that you have that authority.
4. How we use your personal data
We use different methods to collect data from and about you including through:
4.1 Direct interactions. You may give us your Identity, Contact, Profile, Financial, and Marketing and Communications, Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- 4.1.1 apply for the Services;
- 4.1.2 create an account on the Website;
- 4.1.3 subscribe to the Services or our publications/newsletters;
- 4.1.4 request marketing to be sent to you; or
- 4.1.5 give us feedback or contact us.
4.3 Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- 4.3.1 Technical Data from analytics providers such as Google based outside the UK.
- 4.3.2 Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- 4.3.3 Identity and Contact Data from data brokers or aggregators.
- 4.4 Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
- 4.1 Direct interactions. You may give us your Identity, Contact, Profile, Financial, and Marketing and Communications, Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
5. Why 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:
- 5.1 Where we need to perform the contract we are about to enter into or have entered into with you. This 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.
- 5.2 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. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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.
- 5.3 Where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.
6. How we 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 ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer (a) Identity
Performance of a contract with you For us to deliver the Services to you, including: (a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(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 our products/services)
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(a) Necessary for our legitimate interests (for running our business, 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 Website content to you and measure the effectiveness of the Website (a) Identity
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve the Website, the Services, marketing, customer relationships and experiences (a) Technical
Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about products or services that may be of interest to you (a) Identity
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- 7.1 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 products, services and offers may be relevant for you (we call this marketing).
- 7.2 You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
- 7.3 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
9. Changing the reasons for processing personal data
- 9.1 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.
- 9.2 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.
- 9.3 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.
10. Disclosures of your personal data
We may share your personal data with the parties set out below:
- 10.1 Service providers acting as processors based in the UK who provide IT and system administration services.
- 10.2 Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- 10.3 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
11. International transfers
We do not transfer your personal data outside the UK.
12. 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.
13. Data retention
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 paragraph 15 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.
14. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- 14.1 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.
- 14.2 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.
- 14.3 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.
- 14.4 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.
14.5 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:
- 14.5.1 If you want us to establish the data's accuracy.
- 14.5.2 Where our use of the data is unlawful but you do not want us to erase it.
- 14.5.3 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.
- 14.5.4 You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 14.6 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.
- 14.7 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15. Other websites