PRIVACY POLICY
FROOTHY DATA PROTECTION DIRECTIVE
Last updated: July 18, 2022
This Privacy Policy explains in detail how we collect, use and share your personal data when you use the Froothie website. It also informs you of the choices you have regarding your personal data.
Please read this Privacy Policy carefully before you submit any personal data to us.
- ABOUT US AND THIS PRIVACY POLICY
- WHAT DATA DO WE COLLECT?
- ANALYSES AND ADVERTISING
- HOW LONG DO WE STORE YOUR DATA?
- HOW WILL YOUR DATA BE TRANSFERRED?
- HOW DO WE PROTECT YOUR DATA?
- HOW CAN YOU MANAGE YOUR PERSONAL DATA?
- KONTAKT
In this section we provide you with general information about us, the Froothie website and this Privacy Policy.
1.1 About the Privacy Policy . This Froothie Privacy Policy (the "Privacy Policy") governs the processing of personal data collected from individual users ("You" and "Your") through the e-commerce websitehttps://froothie.deand related services (collectively, the "Froothie Website "). The Privacy Policy does not apply to third-party websites, applications or software that are integrated into the Froothie Website or to other third-party products and services.
1.2 Controller of the data.The Froothie website is owned and operated by Athena Solutions UG with registered office at Oberstraße 3, 47829 Krefeld, Germany, HRB 18251 and VAT ID DE345401048 (" we ", " us" and "our").
1.3 Children.The Froothie website is not intended for use by persons under the age of 18. Therefore, we do not knowingly collect personal information from children. If you become aware that someone under the age of 18 has provided us with their personal data and you are a parent or legal guardian of that person, please contact us immediately and we will remove the child's personal data from our systems.
1.4 Term and Termination. This Privacy Policy shall enter into force on the date set out in the Privacy Policy above and shall remain in force until terminated or updated by us.
1.5 Amendments. This Privacy Policy may be amended from time to time to reflect changes in our business, the features of the Froothie website, applicable laws, regulations and industry standards. The amended version of the Privacy Policy will be posted on this page and, to the extent we have your e-mail address, we will send you a notice of any changes we implement. We recommend that you read our privacy policy from time to time to keep up to date. In the event of material changes to the Privacy Policy or where required by applicable law, we may seek your consent.
In this section, we explain in detail what personal data we collect, the purposes for which we use it, what data is automatically collected when you use Froothie, and how we contact you.
2.1 Sources of personal data.We obtain your personal data from the following data sources:
- Directly from you . For example, to the extent that you provide your personal data when registering your user account, purchasing our products or contacting us;
- Directly or indirectly through your activities on the Froothie website.When you use the Froothie website, we automatically collect technical information about your use of the Froothie website using cookies and analytics services; and
- Von Dritten . We may receive information about you from third parties to whom you have previously provided your personal data to the extent that these third parties have a legal basis for sharing your personal data with us (e.g. for payment processing).
2.2 Collection of personal data. We adhere to the principles of data minimization. This means that we only collect the minimum amount of personal data necessary for your use of the Froothie website. We use your personal data for limited, specified and authorized purposes, which are explicitly stated in this Privacy Policy. For example, we use it only to provide you with access to the Froothie website, to process and ship your orders, to maintain and optimize the Froothie website, to respond to your inquiries, and to pursue our legitimate interests. We do not share your personal data for any other purpose. This means that we will not use it for purposes that are different from the purposes for which your personal data was provided. Below is an overview of the categories of personal information we collect, the purposes for which we use it and the legal bases we rely on for processing it.
- Your user account. As soon as you register your user account, we store your first name, last name, email address and password. When you update your user account, we save your first name, last name, company name and address. We use this information to register and maintain your user account, to enable you to purchase our products, to process your orders, to contact you if necessary, to ensure security and to maintain our business records. The legal bases we rely on are the "performance of a contract entered into with you" and the "pursuit of our legitimate interests" (i.e. the operation, analysis, growth, protection and administration of the Froothie website). We store this data until your user account is deleted, unless we are required by law to store certain data for longer.
- Orders and payments. When you place an order on the Froothie website, we store your first name, last name, full address and telephone number. When you make a payment, we collect your billing address and payment details depending on the payment method you choose. If you pay by credit card, we record the name of the cardholder, the credit card number, the CVV code, the month and year of validity. If you choose to pay by PayPal, we collect the PayPal data. If you wish to pay by bank transfer, we store the account number and the name of the holder. Your payment data is used to process payments and for our accounting purposes. The legal bases we rely on are "performance of our contractual obligations" and " managing legitimate interests " (i.e. operating, analyzing, enhancing, protecting and administering the Froothie website). We store this data for the period required by law.
- Order information.When you place an order, we store information about your order (e.g. the products you ordered, payment methods and returns). This information helps us analyze your use of the Froothie website, develop new products and services, and ensure that you comply with our legal terms. The legal basis we rely on is " pursuing our legitimate interests " (i.e. analyzing, growing and protecting our business). We will retain this data until your user account is deleted. We reserve the right to retain this information for longer, to the extent that all personal data is removed from it.
- Rezensionen. If you write a review to be published on the Froothie website, we will store your email address, name or Facebook profile information (if you log in via Facebook). In addition, we store any information and materials (photos or videos) that you provide to us in your review. We use this information to publish your review, filter fake reviews, ensure compliance with our legal requirements and run our business. The legal bases we rely on are the " fulfilment of our contractual obligations " and the " protection of legitimate interests" (i.e. the administration and protection of our business). If you decide, at your own discretion, to provide certain personal data in your review that we have not requested, we will process this data on the basis of your'consent'. We store this data until you delete your review.
- Anfragen. If you contact us by e-mail, we will store your first name, last name, e-mail address and any information you provide in your message. If you contact us via the form available on the Froothie website or claim your warranty, we will store your email address, first and last name, phone number (optional), country, order number (optional), date of purchase (optional), product name and any information you provide us in your message. If you contact us via WhatsApp, we will store your name, phone number and any information you choose to share with us in your message. We use this data to respond to your inquiries and to provide you with the requested information. The legal bases we rely on are the " protection of legitimate interests " (i.e. the growth and promotion of our business) and your " consent" (for voluntary personal data). We will store this data until you stop communicating with us.
- Once you register for our newsletter, subscribe to our newsletter on the Froothie website by providing your country, e-mail address and name, or purchase a product from us, we will inform you by e-mail about our products and special offers. The legal bases we rely on to do this are " your consent " (where you opt in) and " the pursuit of legitimate interests " (i.e. promoting our business). You can unsubscribe from receiving our commercial communications at any time free of charge by clicking on the "unsubscribe" link in our newsletters or by contacting us directly. We will store your contact details until you unsubscribe from our newsletters.
- Warranty registration. When you register your warranty, we store your first name, last name, email address, address, date of purchase, order number and product serial number. We use this information to register your warranty and to keep our business records. The legal bases we rely on are " fulfilling our contractual obligations " and " protecting legitimate interests" (i.e. managing our business). We will retain this data for as long as your warranty is valid
2.3 Cookies and other tracking technologies. When you visit Froothie, we store your cooking-related data and use other tracking technologies (e.g. Facebook Pixel). We use this information to analyze the technical aspects of your use of the Froothie website, to carry out our marketing campaigns, to prevent fraud and abuse and to ensure the security of the Froothie website. For more information about our use of cookies and other tracking technologies, please see our Cookie Policy The legal bases we rely on are "the pursuit of legitimate interests " (i.e. analyzing our content and protecting the Froothie website) and " your consent". We will store this data for as long as the analytics records are required for our activities or you withdraw your consent.
2.4 Sensitive Data.We do not store or have access to any special categories of personal data ("Sensitive Data") about you unless you choose, at your own discretion, to provide us with such data. Sensitive Data relates to your health, your religious and political beliefs, your racial origin, your membership of a professional or trade association or your sexual orientation.
2.5 Refusal to provide personal data. To the extent that you refuse to provide us with your personal data when we ask you to do so, we may not be able to perform the requested operation and you may not be able to use the full functionality of the Froothie website, purchase products, obtain the requested information or receive our response. Please contact us immediately if you believe that the personal data we hold is excessive or unnecessary for its intended purpose.
2.6 Your feedback. To the extent you contact us, we may keep a record of your questions, complaints, recommendations or compliments and our response to them. Where possible, we will de-identify your personal data (i.e. we will remove any personal data that is not necessary to keep such records).
2.7 Aggregated and de-identified data. If your non-personal data is combined with certain elements of your personal data in a way that enables us to identify you, we will treat that aggregated data as personal data. To the extent that your personal data is aggregated or de-identified so that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any lawful purpose.
2.8 Transactional communications. To the extent we have your email address and it is required, we may send you important informational messages such as order confirmations, payment receipts, invoices and other technical or administrative emails. Please note that such messages are sent on an "as necessary" basis and do not fall within the scope of commercial communications, for which your prior consent may be required. You cannot unsubscribe from service-related notifications.
3.1 Collection of analytics data. When you browse the Froothie website, we store certain technical analytics data that is collected from you. This data includes the following information:
- URL addresses from which you access the Froothie website;
- Your device type;
- Ihr Betriebssystem;
- Average time spent on the Froothie website;
- Products viewed;
- Which products you add to your shopping cart;
- Initiated payouts;
- Payment information provided;
- Your purchases;
- Number of visits;
- Bounces from visitors;
- Session by data source;
- Approximate geographic location; and
- Ihre IP-Adresse.
3.2 Purposes of use of the analytics data . We use your Analytics Data to analyze what type of users access and use the Froothie website, to measure your engagement, to see what parts of the Froothie website are of interest to you, what products you purchase, to improve our content, to develop new products, and to investigate and prevent security issues and abuse. In most cases, the analytics data is non-personal data that does not allow us to identify you as a natural person. However, some of this data, such as your IP address, may be considered personal data and we ensure that we have the necessary legal basis to process this data. When we process your analytics data, which is personal data, we rely on the bases of " permissible interest" (i.e. to analyze, improve and protect the Froothie website) and "your consent".
3.3 Google Analytics . We use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google "). Google uses cookies to generate statistical information and reports on your use of the Froothie website. You can find more information about the cookies used by Google Analytics in our Cookie Policy. These cookies from Google are anonymous first-party cookies that do not allow us to identify you in any way. These cookies are transferred to Google and stored by Google on servers in the United States. To protect your privacy, your IP address will be anonymized and Google will not combine your IP address with other information that Google has about you. Therefore, Google cannot identify you. In certain cases (e.g. when required by law or when third parties provide services on Google's behalf), Google may transfer the information to third parties. For more information about the privacy practices of Google Analytics, please visit https://support.google.com/analytics/answer/6004245To the extent you wish to opt-out of Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available athttps://tools.google.com/dlpage/gaoptout?hl=en . We will ask you to give us your consent for non-essential Google Analytics cookies via a cookie consent banner. Unless you provide this consent, we will not use Google Analytics to analyze your use of the Froothie website.
3.4 Interest-based advertising and profiling.
Based on your use of the Froothie website and other websites on the internet, you may encounter personalized and non-personalized advertising. We use Google Ads and Facebook Ads, which provide such services. This advertising may also be based on profiles that automatically categorize Froothie website users into groups. Where necessary, we will ask for your consent (for example, for the use of non-essential cookies for advertising). If you give your consent, you will see personalized and non-personalized advertising, which may be based on your interests and cookie-generated data. If you would like to learn more about how such advertising is served, please see Google's Privacy Policy and Terms of Service website available at https://policies.google.com/privacy?hl=en-USand Facebook and the Facebook Privacy Center athttps://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0.
You can control the way you are shown such advertising or opt out of targeted advertising by consulting the Digital Advertising Alliance's guide available at https://youradchoices.com For more information on opting out of advertising features on your device, please see https://www.networkadvertising.org. If non-essential cookies are used for interest-based advertising, we will ask for your consent to these cookies. You can also customize your Google or Facebook account settings to manage the advertising content that is displayed to you.
3.5 Facebook Custom Audience. We use Facebook Custom Audience and remarketing. This is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. based in the United States, which connects your activities on the Froothie website with the Facebook advertising network. This information may be stored by you, namely your cookie-related data and your e-mail address. Where necessary, we will ask for your consent to use this tool or the cookies associated with this tool. The use of this tool enables us to display interest-based advertising when you visit the social network Facebook or other websites that also use this tool. This allows you to see advertisements that may be relevant or interesting to you. You can disable the display of this advertising by adjusting your cookie settings. You will also find links in section 3.4 above that provide you with further information on controlling interest-based advertising.
In this section we explain how long we store and delete your data in our system.
4.1 Retention of personal data.We and our data processors will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy or until you ask us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please see section 2.2. After your personal data is no longer necessary for the purposes for which it was collected and there is no other legal basis for storing it, we will immediately delete your personal data securely from our systems. We do not store personal data for longer than is strictly necessary.
4.2 Retention of non-personal data.We will retain non-personal data about you for as long as is necessary for the purposes set out in this Privacy Policy. This may include retaining non-personal information for the period necessary to review our activities, fulfill our contractual obligations, pursue legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.
4.3 Gesetzlich vorgeschriebene Speicherung. If we are required by law to store your personal data for a certain period of time (e.g. for accounting purposes), we will store your personal data for the period required by law and delete the personal data as soon as the prescribed retention period has expired.
In this section you will find information about third parties who may have access to your personal data.
5.1 Disclosureto data processors . We store your personal data in strict confidence. However, to the extent necessary for the purposes for which your personal data is used, we will disclose your personal data to companies that provide services on our behalf (our data processors). Your personal data may be shared with companies that provide technical support services to us, such as hosting, payment processing and email delivery services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to situations where it is necessary for the following purposes:
- Ensuring the proper functioning of the Froothie website;
- Processing your payments;
- Delivery of your products;
- Receiving your messages;
- Responding to your requests;
- Protecting legitimate interests
- Enforcing our rights, fraud prevention and security purposes;
- Fulfillment of our contractual obligations;
- law enforcement purposes; or
- if you have previously consented to such disclosure.
5.2 List of data processors. We carefully select our data processors and ensure that they provide an adequate level of protection for personal data in accordance with this Privacy Policy and applicable data protection laws. The data processors that have access to your personal data are:
- Our email marketing service provider ActiveCampaign, based in the United States;
- Our e-commerce software provider Shopify, based in Canada;
- Our review service provider Trustpilot based in Denmark;
- Our provider of behavioral analytics services Hotjar, based in Malta;
- Our messaging service provider Facebook Messenger, based in the United States;
- Our payment service providers PayPal and Stripe, based in the United States, and Klarna, based in the United Kingdom;
- Our analytics service provider Google Analytics based in the United States;
- Our advertising service providers Google Ads and Facebook Ads based in the United States;
- Our web performance and security service provider Cloudflare, based in the United States;
- Our chat marketing service provider ManyChat, based in the United States;
- Our forms service provider Typeform based in Spain; and
- Our independent contractors and consultants.
5.3 International transfers. Some of our data processors may be based outside the country in which you are located. For example, where you are a resident of the UK or a country in the European Economic Area (EEA), we may need to transfer your personal data outside the UK or EEA. Where such a transfer is necessary, we will ensure that the country in which our data processor is located provides an adequate level of protection for your personal data or we will enter into an agreement with them that ensures such protection (e.g. a data processing agreement based on pre-approved standard contractual clauses).
5.4 Disclosure of non-personal data.Your non-personal data may be disclosed to third parties for any purpose, as it does not identify you as a natural person. For example, we may share it with prospective customers or partners for business or research purposes, to improve the Froothie website, to respond to lawful requests from public authorities or to develop new products and services.
5.5 Rechtliche Anfragen . If requested by a public authority, we will disclose information about Froothie website users to the extent necessary for the pursuit of a public interest objective, such as national security or law enforcement.
Here you can find information about how we protect your data from data breaches.
6.1 Sicherheitsmaßnahmen. We implement technical and organizational information security measures to protect your personal data from loss, misuse, unauthorized access and confidentiality. The security measures we take include proper authentication, secured networks, SSL data encryption, Transport Layer Security (TLS), strong passwords, limited access to your personal data by our employees, anonymization of personal data (where possible) and carefully selected data processors. Shopify, which provides us with its e-commerce software, is Level 1 PCI DSS compliant.
6.2 Sicherheitsverstöße. Although we will use our best efforts to protect your personal data, given the nature of communications and information processing technology and the internet, we cannot be liable for the unlawful destruction, loss, use, copying, alteration, leakage and corruption of your personal data caused by circumstances beyond our control. In the event of a serious breach, we will take reasonable steps to mitigate the breach as required by applicable law. Our liability for security breaches is limited to the maximum extent permitted by applicable law.
Here you will find detailed information about the rights you have in relation to your personal data and how you can exercise these rights.
7.1 Thelist of your rights . You have the right to control how we process your personal data. Subject to any statutory exceptions, you have the following rights:
- Right of access: You may obtain a copy of your personal data that we hold on our systems and a list of the purposes for which your personal data is processed;
- Right to rectification: You can have inaccurate personal data that we hold about you rectified;
- Right to erasure ("right to be forgotten") : You can ask us to delete your personal data from our systems;
- Right to restriction : You can ask us to restrict the processing of your personal data;
- Right to data portability : You can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and to transmit those personal data to another processor;
- Right to object : You can ask us to stop processing your personal data;
- Right to withdraw consent: You have the right to withdraw your consent where you have given it; or
- Right to lodge a complaint: You can lodge a complaint about our processing of your personal data.
7.2 How can you exercise your rights? If you wish to exercise any of your permitted rights, please contact us using our contact details at the end of the Privacy Policy and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information so that we can identify you in our system. We will respond to your request within a reasonable period of time, but no later than 30 days.
7.3 Reklamationen. If you wish to complain about the way we handle your personal data, please contact us first and express your concerns. Once you have contacted us, we will investigate your complaint and provide you with our response as soon as possible (within 30 days at the latest). To the extent you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
If you have any questions about this Privacy Policy, your rights or our privacy practices, please contact us using the following contact details:
E-Mail: support@froothie.de
Postal address: Athena Solutions UG, Oberstraße 3, 47829 Krefeld, Germany.
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