Privacy Notice

Last updated: 21/07/2019

Folloh LTD respects your right to privacy.  This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.  This Privacy Notice only applies to personal information that we collect through our website at folloh.com (“Website”).  

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

What personal information does Folloh LTD collect and why?

The personal information that we may collect about you broadly falls into the following categories:

  • Information that you provide voluntarily

Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us.  The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

  • Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device.  In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.  

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

  • Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.  

The types of information we collect from third parties include cookies, analytics, personalisation and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you.

Who does Folloh LTD share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. 
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
  • to any other person with your consent to the disclosure.

Legal basis for processing personal information 

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.  

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).  

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.  We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below hello@folloh.com.

Cookies and similar tracking technology 

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you.  For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

How does Folloh keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include encrypting your personal information in transit and at rest.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country.

Specifically, our Website servers are located in Germany, and our group companies and third party service providers and partners operate around the world.  This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.  

Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).  

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

Your data protection rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us at hello@folloh.com.  
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by emailing us at hello@folloh.com.
  • You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us by emailing us at hello@folloh.com.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority. 

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. 

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.  

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us at hello@folloh.com.