Last update: 24 May 2018
Seatfrog Ops Ltd (10784220) of 11 Staple Inn, London WC1V 7QH (Seatfrog, We or us) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
Seatfrog’s Services are not intended for minors under 18 years of age. No one under the age of 18 may provide personal data to or through the Seatfrog App or the Website. We do not knowingly collect personal data from minors under 18. If you are under 18, please do not create a Seatfrog account or send us any information about you.
For the purpose of the General Data Protection Regulation (GDPR), the data controller is Seatfrog Ops Ltd of 11 Staple Inn, London, United Kingdom, WC1V 7QH.
The type of information we collect from you will depend upon the type of interaction you have with us. Broadly speaking, the types of personal data that we collect may include:
We may collect personal data from you in a variety of ways, including the following:
Seatfrog may also collect your personal data from third parties. This may include (but is not limited to) the collection of your personal data from:
From time to time, you may be able to visit our Website and deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain information that we require, we may not be able to provide you with the particular Seatfrog Services that you seek. For example, if we do not have your first and last names and reservation number, you will not be able to participate in an auction using the App.
Cookies are small text files that may be placed on your computer or other device by websites when you visit them. Cookies enable Seatfrog to recognise your device on a subsequent visit by that device to our Website and allow us to deliver a more personalised experience by providing information to us. Cookies are essential for some website functions and these functions will not work in the absence of those cookies.
You can use the browser privacy functions to clear the cookies already on your computer or to block cookies in the future by altering the browser privacy settings. However, please note this may cause some of the functionality of the Website not to work correctly.
Our use of your personal data will always have a lawful basis, either because it is necessary to fulfil our contractual obligations in providing the Seatfrog Services, because you have consented to our use of your personal data (e.g. by subscribing our newsletter), or because it is in our legitimate interests.
The personal data we collect may be used in a number of ways as outlined below.
To fulfil our contractual obligations:
Upon your consent:
In our legitimate interests:
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We will also anonymise personal data regarding you and consolidate such data. We may provide our partners, such as travel service providers (including airlines and rail operators) with aggregated anonymised data about the users of Seatfrog Services, for example auction performance parameters, bidding characteristics and behavioural data.
Seatfrog may disclose personal data to third parties in certain circumstances including (but not limited to) the following:
We may transfer your personal data to overseas recipients for business purposes and operational, support and continuity purposes, for example, when we use IT service providers or data storage services which are located overseas. Countries where these recipients are located may have data protection laws which differ to the data protection laws in your country of residence.
Seatfrog also engages third party software service providers who, for example, provide data analysis services (but do not access personal data regarding you in providing these services). These software service providers may be located anywhere in the world.
Please note that third parties we engage with, such as travel service providers (including airlines and rail operators); online travel, car hire and accommodation reservation systems and ticketing agencies, may be located anywhere in the world.
We may distribute aspects of the Seatfrog Services (such as our auction engine) for display and/or use on Seatfrog’s partners’ and affiliates’ websites or apps using API-based technology.
We may also provide our partners, such as travel service providers (including airlines and rail operators) with aggregated data about the users of the Seatfrog Services via an online platform which Seatfrog operates, for example, auction performance metrics, bidding characteristics and behavioural data.
We will disclose personal data regarding you to third parties in order to:
Unfortunately, the transmission of information via the Internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once We have received personal data regarding you, We use strict procedures and security features to try to prevent unauthorised access.
All information you provide to Seatfrog is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology. The safety and security of your information also depends on you. Where We have given you (or where you have chosen) a password that enables you to access certain parts of the Seatfrog Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
The security of personal data regarding you is a high priority. We take such steps as are reasonable to securely store personal data regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Seatfrog Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Seatfrog takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by Seatfrog and Seatfrog is no longer required by law to retain the information.
You have the right to ask us not to process your personal data for email, sms or text marketing purposes. We inform you (before collecting your data) if We intend to use your data for or if We intend to disclose personal data regarding you to any third party for such purposes. You can exercise your right to prevent such processing by choosing not to check certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at to firstname.lastname@example.org or Seatfrog Ops Ltd at 11 Staple Inn, London, United Kingdom, WC1V 7QH.
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Seatfrog Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
The General Data Protection Regulation (GDPR) gives you the right to access personal data held about you. Your right of access can be exercised in accordance with that Regulation. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request.
Where a request is manifestly unfounded or excessive we may charge a reasonable fee for the administrative costs of complying with the request. We may also charge a reasonable fee if an individual requests further copies of their data following a request, based on the administrative costs of providing further copies.
To request access personal data that We hold regarding you, please send an email to email@example.com or send a letter to Seatfrog Ops Ltd at 11 Staple Inn, London, United Kingdom, WC1V 7QH.