Introduction
At FreshUp24.com EireDigital Limited (referred to as “FreshUp24”, “we”, “us” and “our”), we are committed to protecting the privacy of our users. If you are in the UK or the EU, we are the data controller, unless otherwise stated. Please read the following privacy policy that explains how we collect, manage, and protect your personal information.
This is the Privacy (and Cookies) Notice (“Notice”) for the website www.freshup24.com, and all FreshUp24 affiliate sites (“Sites”), or our applications (“Apps”) (together “Services”).
Contacting Us
If you have any questions, comments, or requests regarding this Notice, you can get in touch with us via our Contact Us page or via email at support@freshup24.com.
What Information Do We Collect & How Do We Use It?
This Privacy Notice will apply to you if:
- You visit and browse our Sites and Apps.
- You order products from or book appointments with our Partners through us (we’ll refer to you as a “Client”).
- You are self-employed and/or you work for a business on the FreshUp24 platform (we’ll refer to you and/or the business as a “Partner”).
We will only use the information we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We say what these reasons usually are in each section below, and we explain each one under ‘What do each of these legal reasons mean?’
If You Visit Our Services
We use your information to provide you with our Services. If you visit any of our Services, whether you’re just browsing or you have an account, we will automatically collect information from you each time you use our Sites. This includes technical information, information about your visit, and (if you opt-in) location data:
Technical Information
Technical information may include the phone number, Internet Protocol (IP) address, login information, browser type and version, browser plug-in types and versions, device IDs, social log-in ID/email address, time zone setting, operating system and platform, hardware version, device settings (e.g. language and time zone), file & software names and types (associated with your device and/or the Services), battery & signal strength, information relating to your mobile operator or Internet Service Provider (ISP).
Information About Your Visit
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through, and from our Site (including date and time), pages and services you viewed or searched for, demographic information (including age and gender), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), traceable campaign links (e.g. in emails, or via tracking URLs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team and our social media accounts.
Location Data
Location data includes country location (based on your full or partial IP address and/or Google Analytics information) which we use to provide location services (if you ask or permit us to), so that we can deliver content, advertising, or other services that are dependent on knowing where you are, like checking for fraudulent transactions.
Location data may be collected in combination with device ID, so we can recognize your mobile browser or device when you return to the Service.
Delivery of location services will involve us checking any of the following:
- the coordinates (latitude/longitude) of your location,
- your current country or region, by referencing your current IP address against public sources, and/or
- your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.
You can opt-in and out of location sharing by changing your device settings.
We Use This Automatically Collected Information To
- Understand how individuals use our Site, and how we can improve it;
- Ensure content from our site is presented in the most effective manner for you and for your devices; and
- Provide you with the information, products, and services that you request from us or we think you may be interested in.
If You Contact or Engage With Us
If you contact or engage with us, we will collect your contact information and the other communications information you provide.
Contact Information
Contact information includes basic contact information you provide:
- email address,
and anything else you include, for example:- first and last name,
- phone number(s),
- social media handle (for example, if you engage with us on social media).
Communications Information
Communications information includes your correspondence with us, for example if you get in touch with our Customer Service team about an order or booking or to report a problem with our Site. This includes:
- emails,
- texts, in-app messaging & other digital messaging,
- calls,
- letters,
- any in-person conversations you have with us.
We Use This Contact and Communications Information To
- Contact you if you have asked us to do, including to respond to your queries, troubleshoot problems, and help with any issues you may have with our Services.
- Provide you with information you might request about our Services.
- Put you in touch with Partners you ask us to share your information with.
- Provide you with technical and other service updates (for example, if we update our Terms of Use and Terms of Service).
If You Contact or Engage with Us
If you contact or engage with us, we will collect your contact information and any other communications details you provide.
Contact information includes basic contact details you provide:
- Email address
- Any other information you include, such as:
- First and last name
- Phone number(s)
- Social media handle (e.g., if you engage with us on social media)
Communications information includes any correspondence you have with us, such as if you reach out to our Customer Service team about an order or booking, or to report an issue with our Site. This may include:
- Emails
- Text messages, in-app messaging, and other digital communications
- Calls
- Letters
- Any in-person conversations you have with us
We use this contact and communications information to:
- Contact you if you have requested it, including responding to your queries, troubleshooting problems, and helping with any issues you may have with our Services.
- Provide you with information you request about our Services.
- Connect you with Partners when you request it.
- Keep you updated on technical and other service-related matters (e.g., when we update our Terms of Use and Terms of Service).
If You Use Our Services to Book an Appointment
When you create an account with Freshup24, we may collect the following details:
- First and last name
- Date of birth
- Gender
- Email address
- Address
- Mobile phone number(s)
- Your photo, if uploaded (optional)
If you choose to use your Google, Facebook, or Apple account to sign in, we will receive an access token to facilitate the sign-in process, allowing us access to:
- First and last name
- Email address
- User ID
- Profile photo (if available; except for Apple users)
We assign unique user IDs or other account-level IDs to your Freshup24 account. As you use your account, we may also collect:
- Your purchase history, including product orders or appointment bookings, or voucher purchases and usage
- Your favourites (e.g., your preferred salon or gym)
- Your account settings
- Social login information
- Securely saved payment methods
- Additional information, if provided, such as preferences, referrals, or how you found out about our Services, and other user-generated content (e.g., profile photo, reviews)
We use this account and related information to manage your account with us, including:
- Maintaining your Freshup24 account
- Providing customer support
- Enabling you to contact, order from, and make bookings with our Partners
- Enabling you to make and pay for orders and bookings via your account
- If a Partner offers home services and you select that option, to enable you to book appointments at the address you provide
- Offering you a personalised experience by recommending features, services, products, and Partners that we think you may be interested in
You may provide Partners with consultation, order, and booking information (e.g., the date and time of your appointment). Partners may also ask for sensitive information via consultation forms on our Services (e.g., health-related details).
You may opt in to receive marketing from a Partner. Partners may also upload their own customer information to Freshup24 to send marketing via our Services (Freshup24 will not use this uploaded information for its own purposes). Partners are responsible for their own marketing.
The Partner is the data controller for this information. If you have any questions, please contact the relevant Partner.
If You Order Products from a Partner’s Shop
When you order products from a Partner’s shop through our Services, we may collect:
- Order details and purchase records, including any related correspondence via our Services
- Cancellation, return, and refund records
- Securely saved payment methods
- Your product reviews or ratings
We use your account and order information to help our Partners fulfil and manage your orders, including:
- Enabling you to contact and purchase products from our Partners, including processing payments
- Sharing your contact and order information with the Partner from whom you ordered, so they can fulfil and manage your order (including cancellations, returns, or refunds) and communicate with you about your order
- Storing your order, cancellation, return, and refund records
If You Work for a FreshUp24 Partner
If you are an employee, contractor, or worker for a FreshUp24 Partner, we may collect certain contact and company-related information from you:
Contact Information may include:
- First and last name
- Role title
- Company name
- Email address
- Contact number
- Log-in details
- KYC and ID verification results (we do not store underlying documents)
Company Information may include:
- Company address
- Business type (e.g., salon, spa, gym)
- Consultation form content
- Historical and future appointments
- Point of sale data
- Payment processing data (we don’t access this directly; our payment processors do)
- Reporting and analytics
- Client data and promotions
- Pictures and marketing materials
We also process non-personal information on behalf of your company, such as financial data and product inventory.
We use this information to manage the Partner’s account with us, which includes:
- Maintaining the Partner’s account
- Providing Partner customer support, including technical support for our suite of business tools
- Enabling the Partner to use our business tools (e.g., appointment scheduling, managing staff)
- Facilitating transactions and payments for the Partner
- Managing marketing promotions via our platform
- Enabling the Partner to list on FreshUp24’s marketplace
- Assisting with inventory management and point of sale devices
- Contacting Partner staff to create accounts and manage authorizations
The Partner you work for is the data controller for this information. If you have any questions, please contact your employer or the Partner directly.
If We Send You Offers, Updates, or Marketing Material
We may collect contact information (as described above) such as your name and email address. We may also collect marketing preferences, which are our records of what information you would or would not like to receive from us, and whether you’ve opted out of direct marketing.
We use this contact and marketing preference information to:
- Send you offers, updates, promotions, newsletters, insights, and other marketing materials
- Provide personalized marketing, including offers, services, and Partner promotions tailored to you
- Contact you if we are interested in collaborating with your company
- Request feedback, including through surveys or other marketing research
You can opt out of marketing at any time by selecting the “unsubscribe” link in any of our promotional updates.
What Do These Legal Grounds Mean?
We are required to have a valid legal basis (a ‘lawful basis’) for processing your personal data. These bases include consent, contractual necessity, compliance with legal obligations, and our legitimate interests.
Consent
We may process your personal information for marketing purposes if you have given us consent. You can withdraw consent at any time by unsubscribing from our promotional communications. We may also use legitimate interests to send direct marketing (e.g., updates, newsletters).
Contract
We process your data if necessary to perform a contract, such as our Terms of Service. This may include notifying you about changes or improvements to our services.
Legal Obligation
We may process your personal information to comply with legal obligations, including compliance with know-your-customer (KYC) and anti-money laundering regulations, where applicable.
Legitimate Interests
We may process your personal information when it is necessary for our legitimate interests or those of a third party, as long as these interests do not override your rights and freedoms. These interests include:
- Administering, improving, and expanding our site and services
- Gaining insights on your use of our services
- Collecting feedback and reviews
- Enhancing, customizing, or modifying our services and communications
- Improving security measures
- Promoting our services to companies or partners you may work with
- Measuring and delivering relevant advertising, including when you visit other websites
- Fulfilling our contractual obligations with partners or clients
If you need more details on how we assess our legitimate interests, feel free to contact us at support@freshup24.com.
We also use cookies, as explained in our Cookie Notice.
Who do we share your information with?
If you are a Client:
We will share your information with our Partners if you have asked us to (for example, if you want to connect with, order from, or make a booking with one of our Partners). We may share your contact and account information, and they will receive any other information you provide through FreshUp24 (for example, completing a Partner’s consultation form). Partners may use this information to manage your communications, orders, and bookings with them.
If you leave a public review for a Partner (or any of their products in their shop on our Services), your rating, review, review date, and first name and last initial will be published on FreshUp24. Other FreshUp24 users and members of the public may be able to see your reviews. Reviews may be published or syndicated on third-party websites. Public reviews will survive the termination or expiry of the FreshUp24 Terms of Service.
If you work for a Partner:
FreshUp24 users may rate the Partner you work at or for, and may rate you as an individual. Your individual ratings may be shared with the relevant Partner, and may be publicly available on our Services.
We may publish limited Partner information (including individual and business public reviews and ratings) to other websites, for example so it can be included in search results or advertising (including online and offline advertising and promotional media, including, but not limited to Google, Google AdWords, Facebook Ads, Twitter, email distribution lists, and third-party business partners and affiliates).
If FreshUp24 processes your information as a Client, Partner staff, or otherwise:
We may also share your information with:
- Any member of our company group, which means our ultimate holding company and its subsidiaries, and/or our subsidiaries who may support our processing of personal information under this Notice.
- Our service providers, organisations who process your personal data on our behalf and in accordance with our instructions and the data protection law. This includes supporting the services we offer through the Site, in particular those providing website and data hosting services, distributing communications we send, supporting or updating marketing lists, customer support, facilitating feedback on our services, digital invoicing and payment processing providers who provide secure payment processing services, and providing IT support services from time to time. These organisations (which may include third-party suppliers, agents, sub-contractors, and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
- If you create a Partner Account with us by using a Referral Link, the Partner who the Referral Link relates to may view the progression of your Partner Account.
- If we run surveys, competitions, promotional campaigns, offers, or other occasional activities and you opt-in, we may share certain information with our commercial partners (for example, if you chose to enter into a prize draw we run with a third party). We will provide more detailed privacy information at the time.
- Our auditors, legal advisers, and other professional advisers.
- If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer.
- Any person to whom disclosure is necessary to enable us to protect our rights, property, or safety, our clients, or other third parties, and to enforce our rights under this Notice or under any agreement (for example, our Terms of Use and Terms of Service) with you. This includes exchanging information with other companies and organisations for the purposes of detecting and preventing fraud and cyber-crime.
- If required to do so by court order or if we are under a duty to disclose your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation. This includes exchanging information with law enforcement agencies, regulators, or other similar government bodies.
Where do we store your information?
FreshUp24 operates globally, including in the United States, Canada, United Kingdom, Australia, the United Arab Emirates, Netherlands, and other countries in the European Economic Area (“EEA”). We generally don’t share personal data between group companies.
We may transfer your personal information outside the UK / EEA:
- In order to store it.
- In order to enable us to provide our Services to you.
- In order to facilitate the operation of our businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
- Where we are legally required to do so.
We will put legal protections in place to safeguard personal data transfers in compliance with data protection laws.
We may transfer your personal information outside the UK / EEA, including to the key organisations listed here.
We update our partners and service providers as we grow and will update this Notice regularly. For more information about how we currently transfer and protect data, please contact support@freshup24.com.
How do we protect your information?
All information you provide to us is securely stored. Our website uses secure end-to-end encryption to protect your information. All connections into our platform are secured using industry-standard security and encryption.
All data we capture is stored in secured databases and data storage systems with strict access limitations. All data access requests are logged and monitored in accordance with any threat detection policies.
Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal information, but we cannot guarantee the security of your data transmitted to us – even if there is a special notice that a particular transmission (for example, credit card information) is encrypted. Any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.
Payment processing
Payments made on our Services are made through our payment gateway provider, Adyen N.V., (“Adyen”) (or, if you are in the UAE, Checkout MENA FFZ LLC (“Checkout”)). You will be providing credit or debit card information directly to Adyen (or Checkout), which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. FreshUp24 can view pseudonymized cardholder and card details. In addition, FreshUp24 stores the following card information:
- Card brand.
- Card holder name.
- Card’s last four digits.
- Card expiry month and expiry year.
Information which you supply to Adyen (or Checkout) is not within our control and is subject to Adyen’s own privacy policy and terms (or Checkout’s own privacy policy).
External sites
FreshUp24 may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies. FreshUp24 does not accept any responsibility or liability for these policies or any content on external sites and does not necessarily endorse the views expressed within them. FreshUp24 has no control over the availability of any of these websites. Please check each site’s policies before you submit any personal information to these websites.
How long is your information kept for?
We will generally process personal information:
- For as long as it is necessary for the purpose(s) for which it was originally collected (for example, holding it on behalf of a Partner, or for as long as you have an account with us), and
- For up to six years after that to identify any issues and resolve any legal proceedings.
We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of legal proceedings, or we are aware of pending or ongoing legal proceedings. In some circumstances, we may keep data longer if applicable law says we have to.
If you have opted to receive insights, newsletters, or other promotional material, but later decide to opt-out from receiving these updates, or object to any other processing of your personal information, we may keep a record of your opt-out or objection so we can respect your preferences.
We may keep aggregated, anonymised, or pseudonymized data – for example, for reporting and analytics – for longer periods.
Aggregated data
In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you and you cannot be re-identified). This anonymised data (for example, aggregated statistics) is no longer personal data, and we may keep and use this anonymised information indefinitely without further notice to you.
We use this to help us provide, develop, and improve our services, including to:
- Better understand how people use our Services.
- Provide our Partners and Clients with information about our Services, including user statistics (e.g., total numbers, broad demographics statistics).
- Develop useful insights and improvements to the Services.
What rights do you have with your personal information?
In certain circumstances, you have the following rights:
- To be provided with a copy of your personal information held by us;
- To request the correction or deletion of your personal information held by us;
- To request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
- To object to the further processing of your personal information, including the right to object to marketing;
- To request that your provided personal data be moved to a third party, and
- To withdraw consent.
If you wish to exercise any of these rights in relation to the personal information we hold about you, you can contact us at support@freshup24.com. If you have any concerns, you have the right to lodge a complaint with a data protection supervisory authority.
