This thedigitalfrogs.com website and our mobile applications and mobile websites (“the Platforms”) are owned and operated by The Digital Frogs, whose principal office is at 2A Marshall Road OX42NR (OXFORD - UK).
This Privacy Statement covers the thedigitalfrogs.com website and our other Platforms, and explains how we use personal information that we may obtain about you.
How this Privacy Statement applies
By visiting our Platforms or using any of our products or services, you agree and consent to your personal information being used and disclosed in the manner set out in this Privacy Statement. In certain countries, we will not collect personal information from you unless you have specifically agreed or consented to us doing so (for example through your acceptance of this Privacy Statement or via an electronic tick-box or other similar measures as required by local privacy and data protection laws).
You do not have to provide your personal information to us, but if you do not provide certain information we will only be able to provide limited products and services to you.
The personal information that we collect
We may collect personal data directly from you when you use our Platforms, contact us by telephone, by email or in person.
We may also collect personal information from third parties who you have authorised to provide your personal information to us.
We will combine the information that we collect automatically from you with any other information that you collect directly from you or about you.
We also collect and store certain personal information as set out below.
Using the Platforms
- when you are making payment we will collect different information depending on the payment method. For example for credit card payments we will collect - credit cardholder name, address, card number, expiry date and CVC code. You may also choose to store your credit card details with us for future use. However, we do not store your CVC/CVV code (the security code on the back of a credit card);
- From time to time we may update the methods of collection and data fields above. Where there are significant changes we will find a way to notify you, in accordance with the section "Notification of changes to this Privacy Statement" below.
How we use personal information?
We use the information provided in the following ways:
- To fulfil our agreement with you and/or dealing with your or your collaborators during our agreement
- We may use location data for our mobile website and mobile app to enable us to provide the most helpful format and content
- To administer any contest, competition, prize draw or your acceptance of any other promotional offer you may enter, and notify winners, as more fully set out in the applicable terms and conditions;
- To personalise the look and feel of our Platforms and our communications with you, so as to align with preferences you may have told us about or which we have inferred from your use of our Platforms, market research and, (where you have agreed to this) via social media and networks;
- To answer any queries which you may send to us by email or other forms of communication, and we may keep a record of these contacts including call recordings (to the extent permitted by applicable law);
- In order to conduct customer satisfaction surveys and improve the products and services we offer or create new products and services;
- To meet our legal compliance obligations or for accounting or audit purposes, including the prevention of fraud for online payments;
- To protect our property, rights, and interests as well as the property, rights, and interests of other persons;
- For legal purposes, such as to respond to a valid legal subpoena or regulatory order;
- For credit checking and credit scoring purposes;
- For crime prevention and detection;
- For direct marketing purposes, as set out in detail below in the section "How do we use your personal information for marketing purposes?
- As you may authorise or consent to additionally from time to time.
What sensitive personal data might you require or hold?
- Sensitive personal data includes data about an individual's health and religion and other categories of personal data which are closely protected. We do not generally collect this information from you, but where we do, we seek to minimise the collection and use of it.
- you agree that you have voluntarily provided that information to us and that you consent for us to use that information to provide you with these products or services and/or determine your fitness to avail yourself of our products or services.
- In each case, you specifically consent that we can use and transfer outside your local country to anywhere in the world where you reside or where we provide products or services from
How do we use your personal information for marketing purposes?
- Where you have indicated you would like to receive updates from us:
- we may send marketing to you to tell you about developments in the products and services available through our Platforms and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);
- where we are able to determine or you have indicated to us that you would like to receive it.
- You can also unsubscribe from receiving certain electronic messages (see "Withdrawing your consent" below).
To whom do we disclose your personal information?
- We may disclose information about you as follows:
- To governments, border control agencies, regulators and others as permitted or required by law.
- To third parties whose products or services you are purchasing and you acknowledge and consent that this may also be sensitive personal data;
- To our third party service providers and processors, as set out below;
- To third party advertising and social media platforms to provide advertising and the information requested by social media platforms to deliver the user's requested functionality;
- We may also disclose your personal information as permitted or required by law. For example, we will disclose personal information to those governmental bodies who have authority to obtain it, in order to comply with a warrant or subpoena issued by a court of competent jurisdiction, and to comply with record production requirements;
- to anyone to whom we transfer or may transfer our rights and duties under our agreement with you;
- your friend, if you make a "refer a friend" request or similar;
- where you have authorised someone else to manage your agreement (or part of) with us;
- to customs and/or immigration departments or other regulatory authorities in your country (or where you operate/reside) in order to comply with the law in those countries;
- if we have a duty to do so or if the law allows us to do so; and
- to our employees and agents to do any of the above on our behalf, now or in the future.
Working with other service providers
- For operational reasons, we transfer personal information to service providers who help us manage our systems and processes, and to deliver our products or services to users. These may include: banks and payment card verification providers, our data warehouse and customer relationship management centre, marketing organisations (who may provide support for marketing and promotional communications); internet service providers who administer our Platforms and provide internet services and host our facilities; IT service providers, and consumer research companies that assist us with understanding consumer interests by conducting surveys. We have implemented safeguards to ensure that our service providers treat personal information in a way that is consistent with the terms of this Privacy Statement and applicable laws, and that it is not used except to fulfil products or services to us or where we believe it is necessary for a legitimate reason connected with the products or services we offer, or as set out in the "What sensitive personal data might you require or hold?" section above.
- These service providers and group companies may be located in your country, countries in the European Economic Area, in the United Arab Emirates or elsewhere in the world. Different privacy laws may apply in these countries See further detail in our "Transfer of Personal Information" section below.
- By choosing to provide us with your personal information you are consenting to its use in accordance with the principles outlined in this Privacy Statement and as outlined at the time you are asked to provide any personal information. We and other members of The Digital Frogs may contact you by phone, email, SMS and mobile device messages or notifications (and gaining your consent where we are required to do so) in order to provide you with updates pertaining to our products or services as well as information about additional offers, products, services or events that we believe may be of interest to you.
Withdrawing your consent
- You do not have to provide us with your personal information. However, if you choose not to provide certain personal information we request and/or require or consent to its use and disclosure, you will still be able to visit our Platforms but you may be unable to access certain options, products or services, and in some cases we may not be able to fulfil your booking.
- All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt-out of receiving these communications..
- Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs.
- Please note that if you unsubscribe from marketing communications we may hold your details on a suppression list so we don't send you marketing communications in the future.
- We will take appropriate steps to protect the personal information you share with us. We have implemented technology and security features to safeguard the privacy of your personal information. We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
Protecting your details and protecting yourself against internet fraud
- Here are some simple steps you can take to ensure your information is kept securely:
- Be aware of "Phishing", which is where someone tries to represent themselves as someone else to gain information from you - always check whether emails from any sender are actually from them, and if in doubt, go directly to their website and do not click on links in emails, as these may take you to "clone" websites which use your information illegally.
Aggregate data, data analytics and social media functionality
- We may aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and product offerings, and to customize our Platforms’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.
- We gather certain usage information like the number and frequency of visitors to our Platforms. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you.
- If you use buttons on our Platforms linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from our Platforms may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers or generally to anyone who has access to your profile page).
Cookies and other tracking technologies
- See also our section on "Aggregate data, data analytics and social media functionality" above.
Do Not Track
- Our Platforms may contain links to other websites. Please be aware that we are not responsible for the privacy practices of websites not operated by us or. We encourage you to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by our Platforms.
Correction/updating of personal information
- If your personally identifiable information changes or is inaccurate, or if you no longer desire our service, we will provide a way to correct, update or suppress your personal information provided to us. If you are concerned that any of the information we hold about you is incorrect please Contact Us. These rights are without prejudice to any legal rights you may have in applicable laws, including your right to object to certain processing of data.
Access to your personal information
- You may have the right to receive a copy of personal information we keep about you, including the sources of the data, the purposes and methods of processing, any electronic decision-making and the entities with whom we share your data. We will endeavour to provide the information you require within a reasonable time. There may be a small monetary charge for some requests, depending on the information requested, to the extent permitted by applicable law.
Transfer of your personal information
- Some parties that process or store personal information in accordance with this Privacy Statement may be located in jurisdictions outside your country of residence or our country of incorporation. Therefore, you understand and unambiguously agree that your information may be processed and stored in these jurisdictions and that different privacy laws may apply in these countries which may not ensure the same level of data protection as granted in your country of residence. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country.
- In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.
Notification of changes to this Privacy Statement
- If we decide to change our Privacy Statement, we will post those changes on our Platforms. If at any point we decide to use personally identifiable information in a manner materially different from that stated at the time it was collected (and/or where we are required under applicable law), we will notify you. You will have a choice as to whether or not we use your information in this different manner. We will use information in accordance with the Privacy Statement under which the information was collected until you agree otherwise, but if you do not accept the amended Privacy Statement, please stop using our Platforms. Each version has a version number and date so you can check this easily.
Queries, concerns or complaints regarding your privacy or this Privacy Statement
Owner and Data Controller
The Digital Frogs
Types of Data collected
Among the types of Personal Data that this the Platforms collects, by itself or through third parties, there are: first name, last name, date of birth, phone number, company name, profession, address, country, email address, ZIP/Postal code, various types of Data, city, field of activity, User ID, website, Usage Data, gender, username and Cookies.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the Platforms.
Unless specified otherwise, all Data requested by the Platforms is mandatory and failure to provide this Data may make it impossible for the Platforms to provide its services. In cases where the Platforms specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through the Platforms and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Platforms (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Managing contacts and sending messages, Tag Management and Analytics.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
- The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics with anonymized IP (Google Inc.)
- Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
- Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
- This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
- Personal Data collected: Cookies and Usage Data.
Contacting the User
Contact form (the Platforms)
- By filling in the contact form with their Data, the User authorizes the Platforms to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
- Personal Data collected: address, city, company name, country, date of birth, email address, field of activity, first name, last name, phone number, profession, User ID, various types of Data, website and ZIP/Postal code.
Managing contacts and sending messages
- This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
- These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
MailChimp (The Rocket Science Group, LLC.)
- MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
- Personal Data collected: address, company name, Cookies, country, date of birth, email address, first name, gender, last name, phone number, Usage Data and username.
- This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
- This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
- Google Tag Manager is a tag management service provided by Google LLC.
- Personal Data collected: Cookies and Usage Data.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the Platforms or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
For operation and maintenance purposes, the Platforms and any third-party services may collect files that record interaction with the Platforms (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
the Platforms does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through the Platforms (or third-party services employed in the Platforms), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Platforms, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Platforms) and the details about the path followed within the Platforms with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Platforms. The Data Controller, unless otherwise specified, is the Owner of the Platforms.
This Application/ The Platforms/ This Website/
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User's device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: May 23, 2018