Privacy Policy

Last updated: March 10, 2020

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service, and tells You about Your privacy rights and how the law protects You.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Fluff Software Limited, Delta 606 Welton Road, Delta Office Park, Swindon, England, SN5 7XF.
  • Website refers to Fluff Software, accessible from https://www.fluff.software
  • Service refers to the Website and other digital touchpoints, including Our presence on Facebook.
  • Country refers to: United Kingdom
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which determines the purposes for which and the means by which the Personal Data is processed.

Collecting and Using Your Personal Data

Types of Data Collected

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service. The technologies We use may include Cookies or Browser Cookies. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

  • Necessary / Essential Cookies: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features, such as session cookies enabling core Service functionality.
  • Tracking and Performance Cookies: These are persistent Cookies used to track information about traffic to the Website and how users use the Service, potentially identifying individual visitors through pseudonymous identifiers.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • For the performance of a contract and compliance with related obligations.
  • To contact You by email, telephone, or other equivalent forms of electronic communication regarding updates or informative communications.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about.
  • To manage Your requests to Us.

Sharing Your Personal Data

We may share Your personal information in the following situations:

  • With Service Providers for the purposes of monitoring and analysing the use of our Service.
  • With business partners in the context of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of assets.
  • With Affiliates, in which case we will require those affiliates to honor this Privacy Policy.
  • With business partners to offer You certain products, services or promotions.
  • With other users, when You share personal information or otherwise interact in public areas.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, may be processed at, and transferred to and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

Disclosure of Your Personal Data

Personal Data may be disclosed in the following circumstances:

  • Business Transactions: If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred, with prior notice.
  • Law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.
  • Other legal requirements: to comply with a legal obligation, protect the rights or property of the Company, prevent or investigate possible wrongdoing, protect the personal safety of Users, or protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Service Providers

Analytics

We use Google Analytics to monitor and analyse the use of our Service. Google uses the data collected to track and monitor the use of our Service. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send, or by contacting Us.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or those of another natural person.
  • Public interests: Processing Personal Data is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right, under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data.
  • Request correction of Your Personal Data if it is inaccurate or incomplete.
  • Object to processing of Your Personal Data, particularly for legitimate interests or direct marketing.
  • Request erasure of Your Personal Data where there is no good reason for Us continuing to process it.
  • Request the transfer of Your Personal Data to You or to a third party in a structured, machine-readable format.
  • Withdraw Your consent at any time where the Company relied on Your consent to process Your Personal Data.

You are able to exercise Your rights free of charge by contacting Us. We will try our best to respond to You as soon as possible. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data, particularly the data protection authority in the European Economic Area where You live, work or where You suspect a breach may have occurred.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As the Company uses Facebook Fan Pages, We and the operator of the social network Facebook are Joint Controllers, in relation to the Facebook Fan Page (https://www.facebook.com/fluffsoftware).

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Pages and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Fan Page. Facebook Cookies remain valid for up to two years. Information received from the Facebook Cookie will be transmitted to and stored by Facebook, which may transfer the information to countries outside the European Union. For more information, please see Facebook's data policy: https://www.facebook.com/full_data_use_policy

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page, and updating the "Last updated" date at the top of this Privacy Policy. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By visiting our contact page: https://www.fluff.software/contact
  • By post: Swindon, England