FROTH

PRIVACY POLICY

1.   What we do

Froth Inc. (Froth, “we,” “us,” “our”) is the owner of the Froth apps, widgets, software and the www.Froth.nyc website (collectively, the Platform). Froth is a software platform and web application that offers its customers (Froth Users) bar recommendations, drink discounts and other services and offers Partner Bars, Restaurants, Caterers, etc. (collectively, the Partners) the opportunity to use the Platform to attract and retain new clientele (the Service).

This Privacy Policy should be read in conjunction with our Terms of Service that govern all use of Froth.

1.   Privacy Statement – Our commitment to you

Keeping customer information private and confidential is the foremost priority for us. To enable us to provide you with our services, we need to collect certain information from you. We provide this privacy notice to inform you of what personal information we collect about you and how we treat that information

This Privacy Policy governs the manner in which we collect, use, maintain and disclose information collected from users of Froth. We may update this Privacy Policy from time to time as a result of changes in technology or privacy law. In the event of any major changes, we will post a notice on the Froth Platform.

This privacy policy applies to the Froth Platform and all products and services offered by us. By signing up for any of the products or services offered by Froth, you agree to the terms of this Privacy Policy and our Terms of Service (INSERT HYPERLINK).

All individuals with access to personally identifiable information (hereinafter, the Personal Information)—as defined in Title 18 of the United States Code, section 1028, subsection d—about our customers are required to follow this policy effective as of 10/21/2015.

1.   PURPOSE OF OUR POLICY

We have adopted this Privacy Policy to ensure that we have standards in place to protect the Personally Identifiable Information that we collect about individuals that is necessary and incidental to:

Providing the system and services that we offer; and

The normal day-to-day operations of our business.

By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.

1.   THE INFORMATION WE COLLECT

In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, contact the individual in the ordinary course of business and transact with the individual.  Specifically, we require this information in order to verify the identity of our users, to protect our customers, and to ensure the integrity of the sales we facilitate.

You may, however, browse Froth anonymously. We will collect personal identification information from you only if you voluntarily submit such information to us. You can always refuse to supply personally identification information, except that it may prevent you from engaging in certain Site related activities.

Without limitation, the type of information we may collect is:

Personal Information.  We may collect personal details such as an individual’s name, location, date of birth, and other information, as defined in Title 18 of the United States Code, section 1028, subsection d, that allows us to identify who the individual is;

Contact Information.  We may collect information such as an individual’s email address, telephone & fax number, and other information that allows us to contact the individual;

Financial Information.  We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;

Statistical Information.  We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information; 

Other Personal Information. We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy. We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address.

Legal Drinking Age

This Platform and Service is not designed nor intended for use by anyone under the age of 21. If you are under the age of 21, you are not authorized to use this site so please do not submit any information to us.

1.   HOW INFORMATION IS COLLECTED by us and others

Most information will be collected in association with an individual’s use of Froth, buying or selling a product or service through the Platform, making an enquiry about Froth or generally dealing with us. However we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners.  In particular, information is likely to be collected as follows:

Registrations/Subscriptions.  When an individual registers or subscribes for a service, account, membership or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;

Payment.  When an individual submits their details to open a payment account or make a payment;

Sales and Purchases. When individuals transact sales and purchases using the Service;

Supply. When an individual supplies us with goods or services;

Contact.  When an individual contacts us in any way;

Access. When an individual accesses our offices we may require them to provide us with details for us to permit them such access. 

Cookies. Froth may use "cookies" to enhance user experience. Your web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of Froth may not function properly.

Social Media Features. Our Web site may include social media features, such as the Facebook Like button. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing them.

Third Party Links. Our Site or Services may contain links to third party websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. If you submit personal information to any of those sites, your information is governed by their privacy policies. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Phishing. It has become increasingly common for unauthorized individuals to send e-mail messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the e-mail address from which the e-mail appears to have been sent, and the domain name of the web site requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorized individual to be used for purposes of identity theft. This illegal activity is known as “phishing”. If you receive an e-mail or other correspondence requesting that you provide any sensitive information (including your password or credit card information) via e-mail or to a Web site that does not seem to be affiliated with Froth, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us at info@froth.nyc.

As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.

Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information.

1.   THE SAFETY & SECURITY OF PERSONAL INFORMATION

Physical Facilities. We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access.  We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on Froth. This includes appropriately securing our physical facilities and electronic networks.

Industry Standards. We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other Personal Information entrusted to us. Our information security systems apply to people, processes and information technology systems on a risk management basis.

Servers. We may use a variety of cloud services including Amazon Web Services, Google Cloud, and Microsoft Azure to store our data. These companies use some of the advanced data security methods available. Some Personal Information may be stored, hosted, and accessed from data centers in the United States. Data privacy laws or regulations in your home country may differ from those in United States. By using the Service, you consent to having some of your data hosted in the United States.

Privacy Officer. We may appoint a Privacy Officer to oversee the management of this Privacy Policy.  This officer may have other duties within our business and also be assisted by internal and external professionals and advisors.

Internet Security. The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed.  Each individual that provides information to us via the internet or by post does so at their own risk.  We do not accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.

1.   WHEN PERSONAL INFORMATION IS USED & DISCLOSED

Purpose. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted. We may share personal information with Partners in order to facilitate the Service or as otherwise indicated in this Privacy Policy.

Non-Disclosure. We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances. We do not sell, trade, or rent users personal identification information to others.

Business Operations. Information is used to enable us to operate our business, especially as it relates to an individual.  This may include:

The provision of goods and services between an individual and us;

Verifying an individual’s identity;

Communicating with an individual about:

Their relationship with us;

Our goods and services;

Our own marketing and promotions to customers and prospects;

Competitions, surveys and questionnaires;

Improve Customer Service. Information you provide helps us respond to your customer service requests and support needs more efficiently.

Personalize Your Experience. We may use information in the aggregate to understand how our users as a group use the services and resources provided on Froth.

Site Improvement. We may use feedback you provide to improve our products and services.

Payments. We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.

Emails. We may use the email address to send you information and updates pertaining to their order. It may also be used to respond to inquiries, questions, and/or other requests and will be shared with Partners. If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, you may do so by contacting us.

Disclosure. There are some circumstances in which we must disclose an individual’s information:

Subpoena. Where we are required to disclose by a United States Court of Law under subpoena.

Illegal Activities. Personal information may be shared with third parties to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the Services, or as otherwise required by law.

Change of Ownership. Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.

Consent. Except when required by law, we will never disclose your Personal Information without obtaining your consent.

1.   HOW TO ACCESS AND/OR UPDATE INFORMATION

The User can modify their information in the User’s account settings page.  

If for any reason an individual cannot update his or her own information, we will correct any errors in the Personal Information we hold about an individual as soon as feasible after receiving notice from them about those errors.

It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.

1.   Termination of account

Even after you close your account, we will continue to store archived copies of your Personal Information for legitimate business purposes and to comply with the law.

We will continue to store anonymous or anonymized information, such as website visits, in order to improve our Service.

1.   COMPLAINTS AND DISPUTES

If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the details below.

If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.

If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.

1.   Contacting INDIVIDUALS

From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.

1.   Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use Froth. Your continued use of Froth following the posting of changes to this policy will be deemed your acceptance of those changes.

1.   Changes to this policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify Customers by email (sent to the e-mail address specified in a Customer’s account) or users, including Customers, by means of a prominent notice on the Site or Services prior to the change becoming effective. Any access or use of the Site or Services by you after such notice shall be deemed to constitute acceptance by you of such changes, modifications or additions. We encourage you to periodically review this page for the latest information on our privacy practices. If you do not agree to abide by these practices or any future privacy policy, please do not use or access the Site or Services.

1.   Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

Froth

http://www.froth.nyc

info@froth.nyc

This document was last updated on October 28, 2015