By providing us with your data, you warrant to us that you are over 13 years of age.
Our full details are:
Full name of legal entity: Frugal Confessions, LLC
Email address: A[email protected]
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymized data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
- We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook ads or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected] In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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 do not collect any information about criminal convictions and offences.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
We may receive data from third parties such as analytics providers such as Google, advertising networks such as Facebook, such as search information providers such as Google, providers of technical, payment and delivery services, such as data brokers or aggregators.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by clicking the unsubscribe link on any marketing message sent to you or OR by emailing us at [email protected] at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Other companies in our group who provide services to us.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
- We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at [email protected]
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 or refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE
California Consumer Privacy Act (hereafter, “CCPA”) is a California privacy law that is effective as of January 1, 2020.
Under CCPA, California consumers have several added rights and privileges that serve to protect their personal information from being used in a way that the consumer does not agree with. This notice is in place to comply with the California Consumer Privacy Act (CCPA) of 2018 that went into effect as of January 1, 2020.
A consumer has the right to request and know what categories of information and what personal information we collect, how we collect it, and for what purpose we collect it.
CONSUMER’S RIGHT TO DEMAND DISCLOSURE
You have the right to demand that we disclose what categories of information we have or are collecting about you and what personal information we have collected or are collecting about you.
In an effort to maintain full compliance, we are disclosing the categories of information that we generally collect from and/or about consumers.
As a consumer, you are free to request disclosure of your information at no extra charge to you if you make such requests no more than twice (2) during a 12-month period.
General Information We Collect
We generally collect personal information, as listed under CCPA, in the form of your first name and email address when you use an optin form, and what Google Analytics collects.
We collect the consumer information stated above through Google Analytics and opt-in forms.
You have the right to request disclosure of the personal information we collected about you by contacting us at: [email protected]
CONSUMER’S RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION
Under CCPA, a consumer has the right to contact the business that collected personal information about the consumer and request deletion of that information.
There are certain limited circumstances under which the business does not have to comply and delete the information, as follows:
- To provide and complete the transaction for which the information was collected in the first place (for example, selling and delivering goods and services);
- To be in compliance with a legal obligation;
- To carry out and be compliant with another legal requirement; and
- To keep the information for internal use that is reasonable to the consumer.
CONSUMER’S RIGHT TO DEMAND DISCLOSURE IN CASE OF SALE
As a consumer, you have the right to request full disclosure if a business sells or transfers your personal information for a business purpose. You have the right to know what specific information has been sold or transferred, to whom, and for what business purpose.
We do not sell personal information we collect from consumers.
However, in the event we do so within the next 12 months, you will be given the option to opt out if you do not wish for your personal information to be sold.
The consumer has the right to request that we disclose what category of information we sold, the specific pieces of information we sold, to whom we sold it, and for what business purpose we sold it. Consumers can make this request by contacting us at: [email protected]
CONSUMER’S RIGHT TO REQUEST THAT A BUSINESS DOES NOT SELL THEIR INFORMATION
Under CCPA, a consumer has the right to request that a business that collected personal information about the consumer does not sell that information to anyone.
In our efforts to comply with the CCPA, you can find a “Do Not Sell My Personal Information” link in the footer of our website. If there is a field asking for your email address, please be sure to include the same email you opted in with.
If and when you select “Do Not Sell My Personal Information,” you will be marked as an opt out. Therefore, you can be sure that your personal information and other general data collected about you will never be sold.
OUR BUSINESS WILL NOT DISCRIMINATE AGAINST ANY CONSUMER
If you choose to exercise your right and request that we never sell your information, in accordance with CCPA, we will not and cannot discriminate against you for choosing to exercise your right.
You will have access to the same services at the same prices as everyone else. The quality and conditions of products and services you receive will be the same as everyone else, regardless of your choice to exercise your CCPA right to forbid the selling of your information.
SECURING YOUR PERSONAL INFORMATION
Under CCPA, a business that collects or receives personal information about a consumer must implement and maintain reasonable security procedures and practices.
If a business experiences a data breach, then it will be held liable if it did not implement and maintain reasonable security procedures and practices.
We do our due diligence and maintain reasonable security procedures and practices to make sure that the consumer data and private information we collect is safe and secure.
Here are the security practices we have in place to protect consumer data:
- All the systems containing consumer information (such as our email service provider) are password protected.
○ The passwords are considered strong and are not easy to figure out.
- Only 1 person knows the password.
- To make our Email Service Provider database even more secure, we change the password every six months.
- Our computers are protected from third-party access by having an additional password layer before a user can start working on the computer.
- In addition to the statements above, we take reasonable precautions on a daily basis to protect consumer information from unauthorized use, modification, destruction, and disclosure.
If you wish to exercise your rights under CCPA and make requests for disclosure or deletion of your personal information or disclosure about sale of information, you can contact us directly and make such requests. You can also contact us at any time if you are not happy about the way we are handling your data.
We will respond as quickly as reasonably possible. Please keep in mind that we do not have to comply with requests if you make them more than twice during a 12-month period.
Make your requests by contacting us at: [email protected]
EFFECTIVE AS OF January 1, 2020.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older. We recommend that anyone under 18 years of age participate and use our website, products or services only with parental permission and supervision.
We do not intend to collect any personal information from children under the age of 18. If a parent or guardian of a child who has provided us with such personal information would like the information deleted from our records, he or she should contact us at the email address listed at the bottom of this policy statement. We will then delete the child's personal information from our files.
If we become aware that personally identifiable information regarding a child under the age of 13 has been collected at the site, we will use such information for the sole purpose of contacting a parent or guardian of the child to obtain verifiable parental consent. If we cannot obtain consent after a reasonable time, or if when contacted a parent or guardian requests that we do not use or maintain such information, we will make reasonable efforts to delete it from our records. Upon request by a parent or guardian, we will provide a description of the specific types of personal information collected from a child who is under the age of 13.
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