Privacy Policy

Last updat­ed: Octo­ber 19, 2020

Wel­come to Fringe Frequency’s Pri­va­cy Policy.

Fringe Fre­quen­cy (“we”, “us”, “the Site”, “Fringe Fre­quen­cy”) 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, and our exter­nal chan­nels, explain­ing your pri­va­cy rights and how the law pro­tects you.

1. Key Information and Who We Are

This Pri­va­cy Pol­i­cy aims to give you infor­ma­tion on how Fringe Fre­quen­cy col­lects and process­es your per­son­al data through your use of this web­site ( (the “Site”), includ­ing any data you may pro­vide through this web­site when you sign up to our newsletter.

This web­site,, is owned and oper­at­ed by Aaron Lee (“own­er”).

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

Please 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.


Fringe Fre­quen­cy is the con­troller and respon­si­ble for your per­son­al data (col­lec­tive­ly referred to as “we”, “us”, “our” or “the Site”, in this Pri­va­cy Policy).

The Site own­er is our data pro­tec­tion offi­cer (DPO) 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 DPO using the details set out below.

DPO con­tact details

If you have ques­tions about this Pri­va­cy Pol­i­cy or our pri­va­cy prac­tices, please con­tact our DPO in the fol­low­ing ways:

Name: DPO Aaron Lee at Fringe Frequency

Email address:

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 ( How­ev­er, we would 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 on Octo­ber 19, 2020.

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 use of our web­site ser­vices, such as our newsletter.

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. 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. This data includes:

Iden­ti­ty data: first name, maid­en name, last name, user­name or sim­i­lar iden­ti­fi­er, mar­i­tal sta­tus, title, date of birth, and gender.

Con­tact data: email address and tele­phone numbers.

Tech­ni­cal data: your inter­net pro­to­col (IP) address, login data, brows­er type and ver­sion, time­zone 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: your user­name and pass­word, your inter­ests, pref­er­ences, feed­back and sur­vey responses.

Usage data: infor­ma­tion about how you use our website.

Mar­ket­ing and Com­mu­ni­ca­tions data: your pref­er­ences in receiv­ing mar­ket­ing and com­mu­ni­ca­tion from us, and, where rel­e­vant, any third parties.

In addi­tion, we 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 spe­cif­ic web­site con­tent. 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, or infor­ma­tion about your health, genet­ic and bio­met­ric data. We do not col­lect any infor­ma­tion about crim­i­nal con­vic­tions or offences.

3. How We Collect Your Personal Data

We use dif­fer­ent meth­ods to col­lect data from and about you.

When you inter­act with our web­site or ser­vices, you may give us your Iden­ti­ty and Con­tact data by fill­ing in forms or by cor­re­spond­ing with us by email, social media, post, tele­phone, or oth­er­wise. This includes per­son­al data you pro­vide when you:

  • Sub­scribe to our ser­vices or publications
  • Request mar­ket­ing to be sent to you
  • Enter a com­pe­ti­tion, pro­mo­tion or survey
  • Give us feed­back or con­tact us

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 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.

In gen­er­al, we do not rely on con­sent as a legal basis for pro­cess­ing your per­son­al data. How­ev­er, we will ask for your con­sent before send­ing you newslet­ters, mar­ket­ing com­mu­ni­ca­tions or any com­mu­ni­ca­tions from a third par­ty. You have the right to with­draw your con­sent to com­mu­ni­ca­tions and mar­ket­ing at any time by con­tact­ing us.

Pur­pos­es For Which We Will Use Your Per­son­al Data

In the table below, we have detailed all of 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.

Purpose/ActivityType of dataLaw­ful basis for pro­cess­ing includ­ing basis of legit­i­mate interest
To reg­is­ter you as a new customera. Iden­ti­ty
b. Con­tact
a. Per­for­mance of a con­tract with you.
To man­age our rela­tion­ship with you:
a. Noti­fy­ing you about changes to our terms or pri­va­cy pol­i­cy
b. Ask­ing you to leave feed­back or take a survey
a. Iden­ti­ty
b. Con­tact
c. Pro­file
d. Mar­ket­ing and Communications
a. Per­for­mance of a con­tract with you.
b. Nec­es­sary to com­ply with a legal oblig­a­tion.
c. Nec­es­sary for our legit­i­mate inter­ests (to keep our records updat­ed and to study how cus­tomers use our products/services.
To enable you to par­take in a com­pe­ti­tion, prize draw, or surveya. Iden­ti­ty
b. Con­tact
c. Pro­file
d. Usage
e. Mar­ket­ing and Communications
a. Per­for­mance of a con­tract with you.
b. Nec­es­sary for our legit­i­mate inter­ests (to keep our records updat­ed and to study how cus­tomers use our products/services.
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
a. 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).
b. Nec­es­sary to com­ply with a legal obligation.
To deliv­er rel­e­vant web­site con­tent and adver­tise­ments or pro­mo­tions to you, and mea­sure or under­stand the effec­tive­ness of the adver­tis­ing we serve to youa. Iden­ti­ty
b. Con­tact
c. Pro­file
d. Usage
e. Mar­ket­ing and Com­mu­ni­ca­tions
f. Tech­ni­cal
Nec­es­sary for our legit­i­mate inter­ests (to study how cus­tomers use our products/services, to devel­op them, to grow our busi­ness and inform our mar­ket­ing strategy).
To use data ana­lyt­ics to improve our web­site, products/services, mar­ket­ing, cus­tomer rela­tion­ships and experiencesa. Usage
b. Tech­ni­cal
Nec­es­sary for our legit­i­mate inter­ests (to define types of cus­tomers for our prod­ucts and ser­vices, to keep our web­site updat­ed and rel­e­vant, to devel­op our busi­ness and inform our mar­ket­ing strategy).


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

Third-par­ty mar­ket­ing: We will ask for 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 con­tact­ing us.

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.

  • Ser­vice Providers

We require all third par­ties to respect the secu­ri­ty of your per­son­al data and to treat it in accor­dance with the law.

6. International Transfers

We share your per­son­al data with­in Paragon Inter­net Group Ltd trad­ing as tso­Host. This may involve trans­fer­ring your data out­side the Euro­pean Eco­nom­ic Area (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. Links to Other Websites

Our Site, and its newslet­ter, may con­tain links to oth­er web­sites or ser­vices that are not owned or con­trolled by us, includ­ing, but not lim­it­ed to, web­sites of our adver­tis­ers, spon­sors and partners.

These links are offered pure­ly as a con­ve­nience and does not indi­cate endorse­ment of, or asso­ci­a­tion with, the par­ty by Fringe Fre­quen­cy or its owner.

This Pri­va­cy Pol­i­cy only applies to infor­ma­tion col­lect­ed by our Site. We have no con­trol over third-par­ty web­sites, and your use of third-par­ty web­sites is sub­ject to their pri­va­cy poli­cies. We are not respon­si­ble or liable for the pri­va­cy or busi­ness prac­tices of any third-par­ty web­sites linked to our Site. Your use of third-par­ties’ web­sites linked to our Site is at your own risk. We encour­age you to read the pri­va­cy pol­i­cy of any linked third-par­ty web­sites when you leave our Site.

8. 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 who have a busi­ness need-to-know pur­pose. 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.

9. Data Retention

How long will we use your 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. As well as the applic­a­ble legal, reg­u­la­to­ry, tax, account­ing or oth­er requirements.

In some cir­cum­stances, we will anonymise your per­son­al data (so that it can no longer be asso­ci­at­ed with you) for research or sta­tis­ti­cal pur­pos­es, in which case we may use this infor­ma­tion indef­i­nite­ly with­out fur­ther notice to you.

10. Your Legal Rights

Under cer­tain cir­cum­stances, you have rights under data pro­tec­tion laws in rela­tion to your per­son­al data.

You have the right to:

  • request access to your per­son­al data;
  • request the cor­rec­tion of your per­son­al data;
  • request the era­sure of your per­son­al data;
  • object to the pro­cess­ing of your per­son­al data;
  • restrict the pro­cess­ing your per­son­al data;
  • trans­fer your per­son­al data; and
  • with­draw consent.

If you wish to exer­cise any of the rights set out above, please con­tact us via privacy[at]

No Fee Usu­al­ly Required

You will not have to pay a fee to access your per­son­al data, or to exer­cise any of your oth­er rights. How­ev­er, we may charge a rea­son­able fee if your request is 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.