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.