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TermDefinition
CustomerOrganization that has a valid subscription agreement with Frosmo.
Data controllerNatural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
Data processorNatural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
Frosmo platform

The Frosmo platform is a web UI development solution for improving website functionality and personalizing online user experience. The platform mainly works in the visitor's browser, through JavaScript tags placed directly in the web page HTML code.

Optimization and personalization is based on visitor usage data collected from the browser.

For more information, see Introduction to the Frosmo platformPlatform.

Data subject

Natural person whose personal data is being processed; "one who can be identified, directly or indirectly, in particular by reference to an identifier".

In the Frosmo context, the data subject is normally a visitor on a customer's website using the Frosmo platform.

Personal data

Basically, any data related to an identified or identifiable natural person ("data subject"), for example:

  • Name
  • Postal address
  • Email address
  • Social security number
  • Date of birth
  • Gender
  • Profession
  • Image or video
  • IP address
  • Device ID
  • Fingerprint
  • Car registration number
SiteCustomer's website that uses the Frosmo platform.
Visitor

User of a website and, in case the site collects personal data about its visitors, a data subject.

The Frosmo platform identifies the visitor based on the Frosmo visitor ID stored in the browser's local storage. By default, the Frosmo platform does not recognize the visitor across different browsers or devices

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The Frosmo platform stores data in the Frosmo back end as well as in the browser's local storage and cookies. For more information data storage, see Data collection and storage.

Most of the data collected by the Frosmo platform (for example, segmentation and modification IDs, site configurations, visitor context data, and analytics data) is stored for the duration of the subscription agreement between Frosmo and the customer.

When a subscription agreement is terminated, processing any data related to the sites of that specific customer account ceases immediately. After this, the data is stored in a format that prevents the platform using it or it being associated with a person. The data is then removed from the Frosmo systems according to the normal data retention cycle. Any data that must be manually removed, is removed within 6 months after the subscription agreement is terminated.

In the Frosmo back end, data is stored in:

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The personal data retrieved from a customer's databases or other back-end systems is not stored in the Frosmo platform, but transferred to the customer's system or third-party system used by the customer. However, Frosmo may combine it with segmentation data for personalization purposes. This type of data processing must always be determined by the customer and documented in the subscription agreement between Frosmo and the customer.

Access to data

Most of the data collected by the Frosmo platform (for example, segmentation and modification IDs, site configurations, visitor context data, and analytics data) is stored for the duration of the subscription agreement between Frosmo and the customer.

When a subscription agreement is terminated, processing any data related to the sites of that specific customer account ceases immediately. After this, the data is stored in a format that prevents the platform using it or it being associated with a person. The data is then removed from the Frosmo systems according to the normal data retention cycle.

Frosmo, as a data processor, always handles requests related to a specific data subject's access to their own personal data through the customer acting as the data controller regarding the specific site. Any personal data will be delivered only based on a written request or instructions given by a customer the data controller to Frosmo.

The requests related to a specific data subject's access to their own personal data are handled by the Data Protection Steering Group data protection steering group and conveyed to the Frosmo system administration for processing.

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For queries and requests related to data access and data protection in general, customers can contact data.privacy@frosmo.com or their Frosmo Project Manager, who will convey the queries to the Data Protection Steering Groupdata protection steering group. All queries must be handled by the Steering Group steering group to ensure the consistency and validity of the replies.

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When a data subject refuses profiling on a site, the Frosmo platform discontinues can discontinue all profiling for the corresponding Frosmo visitor ID. The platform does this by setting a cookie in the visitor's browser that prevents the use of the platform. After this, any collected data is stored in a format that prevents the platform from using it or associating it with a person. The data is then removed from the Frosmo back end according to the normal data retention cycle.

Frosmo can also implement selective profiling. This solution enables registering the visitor's profiling choice on the site, and showing content accordingly:

  • Personalized content for visitors who allow profiling
  • Generic, non-personalized content for visitors who refuse profiling

For more information, see Profiling solutions on the Frosmo platform.

The Frosmo platform identifies the visitor based on the Frosmo visitor ID stored in the browser's local storage. By default, the platform does not recognize the visitor across different browsers or devices.

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