Fooengine Limited
Company Number 12570854
Wren House Betsy Lane, Bransgore, Christchurch, BH23 8AQ, United Kingdom
24 April 2020
Website Privacy Policy
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INTRODUCTION
1.1
Important information and who we are
Welcome to Fooengine Limited’s Privacy and Data Protection Policy (“Privacy Policy”).
At Fooengine Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your
privacy and Personal Data in compliance with the United Kingdom General Data Protection
Regulation (“GDPR”), the DPA 2018 and all other mandatory laws and regulations of the United
Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy
will tell you about your privacy rights, how the law protects you, and inform our employees
and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
Customers
Business contacts
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data
processed at any time by us.
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1.2
Who is Your Data Controller and Data Protection Officer
Fooengine Limited is your Data Controller and responsible for your Personal Data.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing
questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy,
including any requests to exercise your legal rights surrounding your Personal Data please
contact the DPO using the details set out below:
Full name: Ben Smith
Email address: Ben@fooengine.com
Postal address: Wren House Betsy Lane, Bransgore, Christchurch, BH23 8AQ, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office
(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.
1.3
Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with
your data on our behalf (known as “Processors”). Therefore, the responsibilities described
below may be assigned to an individual, or may be taken to apply to the organisation as a
whole. The Data Controller and our Processors have the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases laid
out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed
themselves to confidentiality or are under an appropriate statutory obligation of
confidentiality;
Implement appropriate technical and organisational measures to ensure a level of
security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging
another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to
requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance
with the obligations laid down in the GDPR and allow for and contribute to audits,
including inspections, conducted by the Controller or another auditor mandated by the
Controller;
Maintain a record of all categories of processing activities carried out on behalf of a
Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to
Personal Data does not process Personal Data except on instructions from the
Controller;
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Notify the Controller without undue delay after becoming aware of a Personal Data
Breach;
Designate a data protection officer where required by the GDPR, publish their details
and communicate them to the supervisory authority; and
Support the data protection officer in performing their tasks by providing resources
necessary to carry out those tasks and access to Personal Data and processing
operations, and to maintain their expert knowledge;
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LEGAL BASIS FOR DATA COLLECTION
2.1
Types of Data / Privacy Policy Scope
Personal Data” 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).
We may collect, use, store and transfer different kinds of Personal Data about you which we
have grouped together below. Not all of the following types of data will necessarily be
collected from you but this is the full scope of data that we collect and when we collect it from
you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date of
birth.
Contact Data: This is data relating to your phone number, addresses, email addresses,
phone numbers.
Marketing and Communications Data: This is your preferences in receiving marketing
information and other information from us.
Billing Data: This is information relating to your debit and credit card information such
as the name attached to your payment details and your billing address.
Transactional Data: This is information of details and records of all payments you have
made for our services or products.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
2.2
The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing
of Personal Data. The main avenues we rely on are:
Consent”: Certain situations allow us to collect your Personal Data, such as when you
tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to
a service.
Contractual Obligations”: We may require certain information from you in order to
fulfil our contractual obligations and provide you with the promised service.
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Legal Compliance”: We’re required by law to collect and process certain types of data,
such as fraudulent activity or other illegal actions.
Legitimate Interest”: We might need to collect certain information from you to be able
to meet our legitimate interests - this covers aspects that can be reasonably expected as
part of running our business, that will not have a material impact on your rights,
freedom or interests. Examples could be your address, so that we know where to
deliver something to, or your name, so that we have a record of who to contact moving
forwards.
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HOW WE USE YOUR PERSONAL DATA
3.1
Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table
containing the different types of Personal Data we collect and the lawful basis for processing
that data. Please refer to section 2.2 for more information on the lawful basis listed in the
table below.
Examples provided in the table below are indicative in nature and the purposes for which we
use your data may be broader than described but we will never process your data without a
legal basis for doing so and it is for a related purpose. For further inquiries please contact our
Data Protection Officer.
3.2
Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an
account and chosen to opt into receiving those communications. From time to time we may
make suggestions and recommendations to you about goods or services that may be of
interest to you.
3.3
Change of Purpose
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 our Data Protection
Officer.
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.
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.
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YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1
What Control Do I Have Over Fooengine Limited’s Use Of My Personal Data?
You may delete your account at any time - this will remove your account page from our
systems and our related software.
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We guarantee this will delete all stored data.
Your account information will be protected by a password for your privacy and security. You
need to prevent unauthorized access to your account and personal information by selecting
and protecting your password appropriately and limiting access to your computer or device
and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you
created with us.
Your account information will be protected by a password for your privacy and security. You
need to prevent unauthorized access to your account and personal information by selecting
and protecting your password appropriately and limiting access to your computer or device
and by signing off after you have finished accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California
residents are entitled to ask us for a notice identifying the categories of personal customer
information which we share with our affiliates and/or third parties for marketing purposes,
and providing contact information for such affiliates and/or third parties. If you are a California
resident and would like a copy of this notice, please submit a written request to
Ben@fooengine.com.
4.2
How Does Fooengine Limited Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate
disclosure. We implement a variety of security measures to ensure the security of your
Personal Data on our systems, including SSL. Any Personal Data collected by us is only
accessible by a limited number of employees who have special access rights to such systems
and are bound by obligations of confidentiality. If and when we use subcontractors to store
your data, we will not relinquish control of your Personal Data or expose it to security risks
that would not have arisen had the data remained in our possession. However, unfortunately
no transmission of data over the internet is guaranteed to be completely secure. It may be
possible for third parties not under the control of Fooengine Limited to intercept or access
transmissions or private communications unlawfully. While we strive to protect your Personal
Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any
such transmission is done at your own risk. If you believe that your interaction with us is no
longer secure, please contact us.
4.3
Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by email.
Where you opt out of receiving these marketing messages, we will continue to retain other
Personal Data provided to us as a result of interactions with us not related to your marketing
preferences.
4.4
How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other
rights). However, if your request is clearly unfounded, we could refuse to comply with your
request.
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We may need to request specific information from you to help us confirm your identity and
ensure you have the 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.
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YOUR DATA AND THIRD PARTIES
5.1
Will We Share Your Data With Third Parties?
We may share non-Personal Data with third parties. We may share your Personal Data with
subcontractors (only when necessary and with your consent) or affiliates (subject to
confidentiality obligations to use it only for the purposes for which we disclose it to them and
pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Fooengine Limited
anticipates a change in control or the acquisition of all or part of our business or assets or with
interested parties in connection with the licensing of our technology.
If Fooengine Limited is sold or makes a sale or transfer, we may, in our sole discretion,
transfer, sell or assign your Personal Data to a third party as part of or in connection with that
transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the
further use of your Personal Data. In all other situations your data will still remain protected in
accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to
enforce our terms or this Privacy Policy.
5.2
Third-Party Links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy
statements. When you leave our Site, we encourage you to read the privacy policy of every
website you visit.
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HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we
collected it for. We may retain your Personal Data for a longer period than usual in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship
with you.
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AGE LIMIT FOR OUR USERS
You must not use Fooengine Limited unless you are aged 18 or older. If you are under 18 and you
access Fooengine Limited by lying about your age, you must immediately stop using Fooengine
Limited.
This website is not intended for children and we do not knowingly collect data relating to children.
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INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictions outside
the US where Fooengine Limited has facilities. We are currently storing data in the EU and so, by using
Fooengine Limited, you are permitting and consenting to the transfer of information, including
Personal Data, outside of the US.
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NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. This version is
dated 24 April 2020. By using Fooengine Limited, you consent to the collection and use of data by us
as set out in this Privacy Policy. Continued access or use of Fooengine Limited will constitute your
express acceptance of any modifications to this Privacy Policy.
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INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated examples
are not intended to in any way limit the term which they serve to illustrate. Any email addresses set
out in this policy may be used solely for the purpose for which they are stated to be provided, and
any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the
right to not respond to emails, even if they relate to a legitimate subject matter for which we have
provided an email address. As a matter of common sense, you are more likely to get a reply if your
request or question is polite, reasonable and there is no relatively obvious other way to deal with or
answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Fooengine Limited, waive rights or make
representations (whether contractual or otherwise). If anything contained in an email from a
Fooengine Limited address contradicts anything in this policy, our terms or any official public
announcement on our website, or is inconsistent with or amounts to a waiver of any Fooengine
Limited rights, the email content will be read down to grant precedence to the latter. The only
exception to this is genuine correspondence expressed to be from the Fooengine Limited legal
department.
SeedLegals - Website Privacy Policy - PYCP-1-2020-02-19T01:00Z
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