At Farlo Group Limited – (“Farlo”, “we”, “us” or “our” in this Policy), we are committed to respecting your privacy and protecting the personal data (as set out below) that we obtain and hold about you and others.

This privacy policy (“Policy”) explains how we will process the personal data relating to you that you provide to us when you visit our website, namely the website at https://farlo.io, or in relation to any query or communication that you may send to us, or that we may collect from others about you when you visit our website.

INTRODUCTION

The website is operated by Farlo, a company registered in the United Kingdom. The website allows users to see more information about the company, among other things (“Services”).

Where we decide the purpose or means for the processing of the personal data that you provide when using our website, we are the “data controller” for the purposes of the General Data Protection Regulation 2016/679 and the General Data Protection Regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (together “GDPR”).

Our website may contain hyperlinks to third party websites. These websites operate fully independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our website is not an endorsement. Should you use any of these websites, such use is at your own risk, and we would recommend that you review their respective privacy policies and terms of use.

WHAT INFORMATION WILL WE COLLECT ABOUT YOU?

Information provided by you when using our Services You may give us information about you by filling in forms when using our Services, creating an account, signing up to our newsletter, or contacting us with e-mail and other similar inquiries. Such information can include: Identity and contact data: including your name, address, email address, and telephone number. Correspondence: including any information you submit to us in messages and correspondence.

Analytics Information Our website uses cookies and other mechanisms to collect and log analytical information, to help analyse how visitors use the website and to compile statistical reports on website activity. This processing is crucial to the running of our online business. Please see our cookie policy for more information. When you visit our website, our analytics service providers may collect the following data: number of visitors to our website; pages visited while at the website and time spent per page; page interaction information, such as scrolling, clicks and browsing methods; websites where visitors have come from and where they go afterwards; page response times and any download errors; and other technical information relating to end user device, such as IP address or browser plugin Should you visit social media pages and choose to follow or connect with us on social media, we may receive personal information from the social media providers (depending on your social media privacy settings), including: your name (and/or your social media unique username); your email and/or postal address; your telephone number(s); IP or MAC address; your gender and/or age; and your general interests and preferences (e.g. Likes, Shares, Posts)

HOW WE USE YOUR PERSONAL DATA

Contacting Us (Your Enquiries)

If you contact us via our website, to make an enquiry or otherwise, in certain situations we will ask you to provide a limited amount of personal data about yourself, such as your name, email address, and your message enquiry. In line with the legitimate interest, we have in operating and promoting our business, we will process your enquiries to reply to your query, including providing you with information about the Services we offer. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our Services. You are under no obligation to provide us with any details, but if you choose to not provide us with relevant information, we may not be able to respond and/or provide the assistance that you request.

Newsletter and Mailing List

If you ask to be added to our mailing list by subscribing to our newsletter, we will keep you updated with information on news, offers, and updates about the company. Consent-based mailing lists: We may process your data to keep you updated with information on news, offers, and updates about us. We may rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time. Please let us know by clicking unsubscribe at the bottom of any marketing email that you receive and following the simple opt-out process. ‘Soft opt-in’ or B2B mailing lists: In some instances (such as with our existing UK customers) the law may permit us to process your personal information in order to send information to you by email that we think is of interest for you and/or your business on the basis of our legitimate interests, being our legitimate interest to promote our business. If you would like to be removed from that list, please let us know by clicking unsubscribe at the bottom of any marketing email that you receive and following the simple opt-out process.

Online Advertising

We may process data for online advertisements. While we do not permit third party advertising on our website, we undertake: Remarketing, which allows us to show display ads to people who’ve previously visited our website; Advertising on social networks, which means that if you link to one of our social media platforms you may be subject to targeted marketing via that platform (including in your newsfeed); Ad performance monitoring, meaning that your information may be used to understand how advertisements have performed or how many people have viewed/interacted certain advertisements; Serving personalised ads, meaning that your information may be used to service you more relevant online advertising on third party services. We work with third party advertising networks and social media platforms as set out in our cookie policy. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies and/or terms and conditions. By interacting with the consent tool on our website, you are able to consent to our use of cookies or similar technologies. You are able to withdraw your consent at any time by going back to the consent tool and changing your settings there

All content you submit to us

If you send us objectionable content or otherwise behave in a disruptive manner when using our website, we may process personal data included in your messages to respond to and stop such behavior. We only process personal data in this way for the legitimate interests of ensuring that use of our website and services is lawful, does not disrupt our systems, does not harass our staff or other individuals, and to enforce our legal rights and to comply with our legal obligations. Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

DO WE SHARE YOUR INFORMATION?

We keep your information confidential, but may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.

If we provide your personal data to third party suppliers, we shall only do so provided that such suppliers do not make independent use of the information. All our third-party service providers are required to take appropriate security measures to protect your personal data. Activities which are carried out by or in collaboration with third party service providers include digital marketing.

Personal data may be accessed or collected by third party advertising networks as set out in our cookie policy here. In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention). If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the website of any changes in ownership or use of your information, as well as any choices you may have regarding that information.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA WHICH WE PROCESS.

You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:

for a copy of personal data, we are processing about you and/or to have inaccuracies corrected;
to restrict, stop processing, or to delete your personal data;
for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
to make a complaint to a data protection regulator. You may contact them at:https://ico.org.uk/concerns/

To make a request in relation to any of the aforementioned rights, please send your requests to [email protected].

CHILDREN

We do not use the website to knowingly solicit information from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information within a reasonable time.

SECURITY

We will take appropriate technical and organizational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our website and Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our website visitors and customers.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorized disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

Please be aware that, while we make the security of our website and your personal data a high priority, but no security system can prevent all security breaches. When you choose to share your personal data with us, you accept the aforesaid and provide your information at your own risk.

INTERNATIONAL DATA TRANSFERS

We are a UK registered Company and our servers are located in the UK and the information that we collect directly from you will be stored in these servers.

Where we transfer your information outside of the UK and/or EEA, we will have agreements in place with the recipient which include (where necessary) standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to [email protected].

RETENTION PERIODS OR CRITERIA

We will hold your personal data for as long as is necessary for the relevant purpose for which that personal data was obtained, or as otherwise described in this Privacy Policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you would like us to stop using or holding your personal data and/or would like to request its deletion, please email us at [email protected].

CHANGES

This Policy may be updated from time to time. We will notify you of any changes by posting the new Policy on this page and, where feasible, by letting you know by email or your account.

CONTACT US

Questions, comments and requests in relation to this Policy are welcome and should be addressed to [email protected].

Last Updated: 12^th June 2024