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          Privacy Policy

The FroXx GmbH Privacy Policy effective from 01/01/2021


Please also refer to our Terms and Conditions of business which apply to all orders/reservations/enquiries placed with FroXx GmbH.


FroXx GmbH is committed to ensuring that your privacy is protected. This Privacy Policy describes how we use the personal information that we collect from you, or that you provide, when you:

· visit our website (the “Website”);

· use the services (together the “Services”) that we provide;

· use software products (together the “Software”) that we provide to you; or

· communicate with us.

FroXx GmbH will act as a Data Controller within our relationship.


1. Information We Collect

1. 1. Information that you provide directly

We collect personal information from you:

(a) through the use of forms, which may be on paper or on our Website, such as when you make a purchase, download a Software we provide, use one or more Services we provide, or commence a course of study, signup to receive our newsletters or register for information;

(b) when you make a purchase (including booking for events or for trainings) on our Website and provide us with information about any special requirements, such as dietary requirements, that you may have; and

(c) if you choose to provide us with information when you use our Website or access our Services;

(d) when you communicate with us for any reason, including by email, postal mail, LiveChat or telephone, and when you use our Services.

(e) When you request marketing information about related products and services from us (also see separate Marketing Permissions section below).

(f) If you are a Booker (a person booking a product or service on behalf of yourself and/or others), you confirm that you have gained permission for the person/s to whom the product or service will be provided, information to be provided, used and stored for the purposes of providing the products or services you have requested on their behalf. This includes all Personal and Sensitive Data as is required in order to provide the product or service requested.

(g) During usage of our Services or Software and post usage of our Services or Software we may collect your feedback on your user experience in order to help others evaluate the services and software provided.

Some of the personal information that you provide may include sensitive personal information, such as health-related information to ensure that we can provide the necessary duty of care or information about your race or ethnicity, which we need for statutory registration/reporting purposes.


1. 2. Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device.

The information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading ‘Cookies’, below.


1. 3. Information that we obtain from third-party sources

(a) We may receive personal information about you from third-party sources (such as your employer or referral from a friend), but only where we believe that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. We collect only the minimum amount of information required from these third parties to enable us to provide the requested service or process any booking you send to us (for example, your educational or employment history). We only use the information we receive from these third-parties as set out in this Privacy Policy.

(b) Where Services are certified training courses, the Client consents to allow FroXx GmbH full access to examination results arising from their bookings. This information will be used in accordance with the requirements of relevant data protection legislation. The data will only be used to evaluate effectiveness of training and to assist FroXx GmbH in providing advice to its clients.

(c) FroXx GmbH reserves the right to assess the financial status of any organization or individual making a booking or in the process of making a booking via a third-party credit rating agency and also reserves the right to require payment prior to confirming a booking and will store this information within your record.

2. Use of Your Information

The information that we collect and store relating to you is primarily used to enable us to provide our Services to you. In addition, we may use the information for the following purposes:

(a) to provide you with information or Services you request from us;

(b) depending upon your separate Marketing Permissions selections we may send you information about related news, products and services and carefully selected third parties (see section Marketing Permissions).

(c) to meet our contractual commitments to you;

(d) to personalize your use of the site, assist your use of the site and improve the site and services we provide generally.

(e) to monitor and analyze trends, usage, and activities in connection with our Websites/Services; and as necessary to prevent or detect crime.

When you are calling our customer service, we may also monitor or record telephone calls for training, customer service and quality assurance purposes, and to detect or prevent crime. These recordings will be retained for a maximum of 30 days. You have the right to opt-out if you don’t want your phone conversation with customer service agents to be monitored or recorded.

In general, we will use any of the information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect such information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable data protection laws.

If you do not want us to use your data for any marketing purposes, you will have the opportunity to withhold your consent to this when you provide your details to us.

Consent can be withdrawn by contacting us using the contact details provided below.

3. Storing and Retaining Your Personal Data

(a) The personal information you provided to us is stored within secure servers. We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

(b) Please note that the transmission of information via the internet (including email) is not completely secure and therefore, although we endeavor to protect the personal information you provide to us, we cannot guarantee the security of data sent to us electronically and the transmission of such data is therefore entirely at your own risk. We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business or statutory need to process your personal information, we will either delete or anonymize it.

4. Disclosing Your Information

We may disclose your personal information to any company within our corporate group. This includes, where applicable, our holding company and its subsidiaries. This will only be done where lawful bases exists.

We may also disclose, where required, your personal information with:

(a) third-party service providers and partners who provide data processing services to us (for example, to support the delivery of Services), or who otherwise process personal information for purposes that are described in this Privacy Policy;

(b) providers of technical services to us in the provision of our website and other technical systems internal to FroXx GmbH;

(c) your employer (or Booker), where required when your employer (or Booker) has undertaken the booking on your behalf;

(d) government agencies, where required by the scheme or education path you elect to follow;

(e) partners with whom we work to provide Services (such as course vendors, examination bodies and training partners) If required to provide the service

(f) any third-party in connection with, or during negotiations of, any merger, sales of company assets, financing or acquisition of all or a portion of our business by another company;

(g) any law enforcement agency, court, regulator, government authority or other third-party where we believe this is necessary to comply with a legal or regulatory obligation (and may not be able to inform you so as not to compromise any investigation or other proceedings), or otherwise to protect our rights or the rights of any third-party; and to

(h) any other person with your explicit consent (separately obtained) to the disclosure

(i) if you give your explicit consent (separately obtained), we may pass your contact details to third parties who may then occasionally send communications to you to provide information, offers and services that may be of interest to you.

(j) in certain circumstances we may need to disclose information that is considered as Sensitive Data in order that third-party can provide you with the requested product or service.

(k) with your permission (separately obtained) we may provide your feedback on your services or training experience in order to help others evaluate the services or training on the FroXx GmbH website. We will never provide your full name or other personal data on the website.

Upon request we will advise you who the information has been passed to and why by contacting us using the contact details provided below.

5. Third-party Links

You might find links to third-party websites on our Websites or within documentation we provide.

If you access other websites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their own Privacy Policy which you should review.

We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

6. Social Networking

The Website may offer you the opportunity to share or follow information about us (or the Website or our Services) using third-party social networking functionality (such as through “share this”, “like” or “follow” buttons).

We offer this functionality in order to generate interest in us, the Website and our Services and Software among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about us with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly available, including through Internet search engines.

Please note that we do not exercise, endorse or control the policies or practices of any third-party social network whose functionality you may access through the Website.

You should always read the Privacy Policy of any social network through which you share information carefully in order to understand their specific privacy and information usage practices.

7. International Data Transfers

For some of our Services, your personal information may be transferred to, and processed in, countries outside of the EEA. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy whenever possible. Regarding countries the European Commission has determined has data protection laws that are not at least as protective as those in Europe Union (and EEA space) we will ask you for explicit consent.

8. Cookies

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why we use them and how you can control Cookies please see our Cookie Policy at

9. Legal Basis

Our legal basis for collecting and using personal information will depend on the personal information being collected and the specific context in which we collect it.

However, we will normally collect personal information from you only:

(a) where we need the personal information to perform a contract with you (for example, to enroll you into a course or provide you with learning materials);

(b) where the processing is undertaken on the grounds of legitimate interests and is not overridden by your rights; or

(c) where we have your consent to do so;

In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third-party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

10. Data Protection Rights

You have the following data protection rights:

(a) If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.

(b) In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.

(c) You have the right to opt-out of marketing and telemarketing communications we send you at any time. You can exercise this right by contacting us using the contact details provided below.

(d) Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

(e) You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

11. Marketing Permissions

If you give us explicit permission (separately obtained) to do so we may store and use your information for the provision of email marketing, newsletters and other information you have agreed to receive.

(a) You may withdraw this permission at any time. Please confirm your withdrawal of consent using the contact details provided below.

(b) You may request to be removed from our database for Marketing purposes at any time. Please confirm your request to be removed by emailing us using the contact details provided below.

(c) Booking or Reserving a Service or a Training product from FroXx GmbH will not automatically result in the assumption of additional Marketing Permissions which will be both Explicit and separately obtained.

(d) We will never sell to or allow any third-party to use this data and your Marketing Permissions for marketing purposes without your explicit permission, separately obtained.

All other relevant provisions of this Privacy Policy shall apply to Marketing Permissions.

12. Contacting Us

The data controller of your personal information will be FroXx GmbH.

We welcome any queries, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us at

13. Changes to the Privacy Policy

We may change this Privacy Policy from time to time by updating this document. 

You should check this page from time to time to ensure that you are happy with any changes.


14. Company Information

FroXx GmbH is a registered company in Federal Republic of Germany.

Registered Company Address is:

Wetzlarer Strasse 30,

1st Floor, Office # 3,

14482 Potsdam,


Telephone:+49(0)331-98 222 507


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