Introduction

Welcome to F1F9’s privacy policy.

F1F9 respects your privacy and is committed to protecting your personal data. This privacy
policy will inform you as to how we look after your personal data when you visit our website
(regardless of where you visit it from) and tell you about your privacy rights and how the law
protects you.

This privacy policy is provided in a layered format so you can click through to the specific
areas set out below. Please also use the Glossary to understand the meaning of some of the
terms used in this privacy policy.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY

1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how F1F9 collects and processes your
personal data through your use of this website, including any data you may provide through
this website when you sign up to our newsletter or purchase a service.

This website is not intended for children and we do not knowingly collect data relating to
children.

It is important that you read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data.
This privacy policy supplements other notices and privacy policies and is not intended to
override them.

Controller

The F1F9 group is made up of different legal entities. This privacy policy is issued on behalf of
F1F9 UK Ltd and F1F9 India Private Limited so when we mention “F1F9”, “we”, “us” or “our” in
this privacy policy, we are referring to the relevant company in the group responsible for
processing your data. F1F9 UK Ltd is the controller in respect of the data processed in
accordance with this privacy policy and responsible for this website.

We have appointed a data privacy manager 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, please contact the data privacy manager using the
details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact
our data privacy manager in the following ways:

Full name of legal entity: F1F9 UK Ltd

Email address: info@f1f9.com

Postal address: Data Privacy Manager, F1F9 UK Ltd, 149 Church Road, Bath, BA2 5JN

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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in August
2018.

It is important that the personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship with us.
Third-party links

This website 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 website, we encourage you to read the privacy policy
of every website you visit.

2. The data we collect about you
Personal data, or personal information, 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 as follows:

Identity Data includes first name, last name, username or similar identifier, job title
and company.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account and payment card details for business to
business transactions only.
Transaction Data includes details about payments to and from you and other
details of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices you use to
access this website.
Profile Data includes your username and password, purchases made by you, your
interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving
marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for
any purpose. Aggregated Data could be derived from your personal data but is not considered
personal data in law as this data will not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with your
personal data so that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy policy.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with
you, and you fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide you with goods
or services). In this case, we may have to cancel a product or service you have with us but
we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by
filling in forms on our website or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
purchase our services;
create an account on our website;
use our instant messaging tools;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we
will automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit other
websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about
you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google; and
(b) search information providers such as Google or Bing.
Contact, Financial and Transaction Data from providers of technical, payment
and delivery services such as Shopify and Payment Express.
Identity and Contact Data from data brokers or aggregators such as Business
Funding Research Ltd and Prospect Global Ltd.
Identity and Contact Data from publicly available sources such as LinkedIn,
Companies House and the Electoral Register.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use
your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered
into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data
although we will get your consent before sending third party direct marketing communications
to you via email or text message. You have the right to withdraw consent to marketing at any
time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on
the specific purpose for which we are using your data. Please contact us if you need details
about the specific legal ground we are relying on to process your personal data where more
than one ground has been set out.

Purpose / Activity: Type of data: Lawful basis for processing including basis of
legitimate interest
To register you as a new customer: (a) Identity (b) Contact: Performance of a
contract with you
To process and deliver your order including (a) manage payments, fees and
charges (b) collect and recover money owed to us: (a) Identity (b) Contact (c)
Financial (d) Transaction (e) Marketing and Communications: (i) Performance of a
contract with you (ii) Necessary for our legitimate interest (to recover debts due to us)
To manage our relationship with you which will include (a) notifying you
about changes to our terms or privacy policy (b) asking you to leave a review
or take a survey: (a) Identity (b) Contact (c) Profile (d) Marketing and
Communications: (i) Performance of a contract with you (ii) Necessary to comply with
a legal obligation (iii) Necessary for our legitimate interest (to keep our records
updated and to study how customers use our services)
• To enable you to use our instant messaging services: (a) Identity (b) Profile (c)
Usage (d) Marketing and Communications: (i) Performance of a contract with you (ii)
Necessary for our legitimate interests (to keep our records updated and to study how
customers use our services to grow our business)
To enable you to partake in a prize draw, competition or complete a survey:
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications: (i)
Performance of a contract with you (ii) Necessary for our legitimate interests (to keep
our records updated and to study how customers use our services to grow our
business)
To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data): (a) Identity (b) Contact (c) Technical: (i) Necessary
for our legitimate interests (for running our business, provision of administration and
IT services, network security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise) (ii) Necessary to comply with a legal
obligation
To deliver relevant website content and advertisements to you and measure
or understand the effectiveness of the advertising we serve to you: (a)
Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f)
Technical: Necessary for our legitimate interests (to study how customers use our
services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer
relationships and experiences: (a) Technical (b) Usage: Necessary for our
legitimate interests (to define types of customers for our and services, to keep our
website updated and relevant, to develop our business and to inform our marketing
strategy)
To make suggestions and recommendations to you about services that may
be of interest to you: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f)
Marketing and Communications: Necessary for our legitimate interests (to develop our
services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what
we think you may want or need, or what may be of interest to you. This is how we decide
which services and offers may be relevant for you (we call this marketing).

If you receive marketing communications from us it may be because you have requested
information from us or purchased services from us and you have not opted out of receiving
that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third
party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by
following the opt-out links on any marketing message sent to you or by contacting us at any
time.

Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a service purchase, service experience or other transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more information about the
cookies we use, please follow this link.

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 us.

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in
the table above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the F1F9 group. This will involve transferring your data
outside the European Economic Area (EEA).

Many of our external third parties are based outside the EEA so their processing of your
personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following safeguards is
implemented:

We will only transfer your personal data to countries that have been deemed to
provide an adequate level of protection for personal data by the European
Commission.
Where we use certain service providers, we may use specific contracts approved by
the European Commission which give personal data the same protection it has in
Europe.
Where we use providers based in the US, we may transfer data to them if they are
part of the Privacy Shield which requires them to provide similar protection to
personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax,
accounting or reporting requirements. We may retain your personal data for a longer period in
the event of a complaint or if we reasonably believe there is a prospect of litigation in respect
to our relationship with you.

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 unauthorised 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,
regulatory, tax, accounting or other requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.
No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we could refuse to comply with your request in these
circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and
ensure your 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us
longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden
by the impact on you (unless we have your consent or are otherwise required or permitted to
by law). You can obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before
entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary
for compliance with a legal obligation that we are subject to.

THIRD PARTIES
Internal Third Parties

F1F9 India Private Limited acting as processor who provides services to you, and IT and
system administration to us.

External Third Parties

Service providers acting as processors who provide IT and system administration
services, such as:
Office 365, who provide Microsoft Office services to us and hold our
SharePoint and OneDrive data.
Our website hosting, development and maintenance service providers.
Third parties who provide an instant messaging services to us or allow
us to use their instant messaging and call service.
Our external IT system administration and support function providers.
Third parties who process orders and support us with fulfilment,
accounting and record keeping.
Professional advisers acting as processors or joint controllers including lawyers,
bankers, auditors and insurers who provide consultancy, banking, legal, insurance
and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or
joint controllers who require reporting of processing activities in certain
circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about you and to
check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to verify
the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have the
right to ask us to delete or remove your personal data where you have successfully exercised
your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the time of
your request.
Object to processing of your personal data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which makes
you want to object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which override your rights and
freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:- If you want us to establish the data’s accuracy.
-Where our use of the data is unlawful but you do not want us to erase it.

-Where you need us to hold the data even if we no longer require it as
you need it to establish, exercise or defend legal claims.

-You have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time you withdraw
your consent.