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Last Updated: 1 September 2024

Our Commitment to Data Protection

frosty-lotus is committed to ensuring the security and protection of the personal information that we process. We have implemented robust policies and procedures to comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This page provides information about how we handle personal data in accordance with these regulations and outlines your rights as a data subject.

Data Controller

For the purposes of the UK GDPR, the data controller is:

frosty-lotus
47 Queensway Business Centre
London, W2 4QH
United Kingdom
Email: [email protected]

Lawful Basis for Processing

We only process personal data where we have a lawful basis to do so. The lawful bases we rely on include:

Consent

Where you have given clear consent for us to process your personal data for a specific purpose, such as receiving marketing communications or using non-essential cookies.

Contract

Where processing is necessary for the performance of a contract to which you are party, or to take steps at your request before entering into a contract. This includes processing necessary to provide our fraud protection services.

Legal Obligation

Where processing is necessary for compliance with a legal obligation to which we are subject, such as maintaining financial records or responding to lawful requests from authorities.

Legitimate Interests

Where processing is necessary for our legitimate business interests, or those of a third party, except where such interests are overridden by your interests or fundamental rights. Examples include:

  • Improving our services based on how users interact with our website
  • Ensuring the security of our systems and services
  • Preventing fraud and protecting our business

Your Data Protection Rights

Under the UK GDPR, you have the following rights regarding your personal data:

Right of Access (Article 15)

You have the right to request a copy of the personal data we hold about you. We will provide this information free of charge within one month of receiving your request. In certain circumstances, we may extend this period by a further two months if the request is complex.

Right to Rectification (Article 16)

You have the right to request that we correct any personal data that is inaccurate or incomplete. We will respond to such requests within one month.

Right to Erasure (Article 17)

Also known as the "right to be forgotten", you have the right to request that we delete your personal data in certain circumstances, including:

  • The data is no longer necessary for the purpose it was collected
  • You withdraw consent and there is no other legal basis for processing
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed

Right to Restrict Processing (Article 18)

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

Right to Data Portability (Article 20)

You have the right to receive personal data you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer this data directly to another controller where technically feasible.

Right to Object (Article 21)

You have the right to object to the processing of your personal data where we are relying on legitimate interests as our legal basis. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

Rights Related to Automated Decision-Making (Article 22)

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We do not currently engage in automated decision-making that falls within this scope.

How to Exercise Your Rights

To exercise any of your data protection rights, please contact us at:

Email: [email protected]
Post: frosty-lotus, 47 Queensway Business Centre, London, W2 4QH

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or exercise 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.

Data Security Measures

We have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of personal data during transmission and storage
  • Regular testing and evaluation of the effectiveness of security measures
  • Access controls limiting who can access personal data
  • Staff training on data protection and security
  • Procedures for restoring access to personal data following an incident
  • Regular backups and secure data storage

Data Breach Procedures

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

  • Notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of the breach
  • Communicate the breach to affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms
  • Document all breaches, including facts, effects, and remedial actions taken

International Data Transfers

We primarily store and process personal data within the United Kingdom. If we transfer personal data to countries outside the UK, we will ensure appropriate safeguards are in place, such as:

  • Transfers to countries with adequate data protection laws as determined by the UK government
  • Standard contractual clauses approved by the ICO
  • Other approved transfer mechanisms under UK GDPR

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Different retention periods apply to different types of data based on:

  • Legal and regulatory requirements
  • Contractual obligations
  • Operational needs
  • Industry standards and best practices

Supervisory Authority

If you are not satisfied with how we handle your personal data or respond to your requests, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Website: www.ico.org.uk

We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

Updates to This Information

We may update this GDPR compliance information from time to time to reflect changes in our practices or legal requirements. We encourage you to review this page periodically.

Contact Us

If you have any questions about our GDPR compliance or data protection practices, please contact us:

frosty-lotus
47 Queensway Business Centre
London, W2 4QH
United Kingdom
Email: [email protected]