Privacy Policy — all versions

Every version of our Privacy Policy, newest first, with the dates it was in force. Earlier versions are kept exactly as they were published, so you can see what changed.

  1. Version 1.3In force 14 October 2026 – today (current)

    Every provider that receives personal data is listed in s.12 and at /legal/sub-processors. Meetings are kept until the merchant closes their account, replacing “24 months”; quotations follow the merchant’s retention setting, at most 24 months, with no longer period for tax records (s.9.3). What we keep after a quotation is deleted, under Rule 8(3) (s.9.5). Recipients are under contract with us or governed by their published terms (s.13.3).

  2. Version 1.2In force 9 October 2026 – 14 October 2026

    Rights requests: we acknowledge within 48 hours and complete within 90 days of your request (s.11.2, s.19), replacing “promptly” and “within 30 days”. A child’s data held for a merchant that has not acted within 30 days of our notice: we notify the merchant again and escalate, rather than deleting it ourselves after 7 days (s.18.4). The text shown is the last one published under this number; it was revised on 10 October 2026 without a new number (s.15.2: we notify a merchant of a breach within 48 hours, not 24).

  3. Version 1.1In force 9 October 2026 – 9 October 2026

    Certifications (s.14.6): Frostrek LLP holds ISO/IEC 27001 and ISO 9001:2015 at company level; Frosty Agent is not separately certified.

  4. Version 1.0In force 1 September 2026 – 8 October 2026

    First published version. The text shown is the last one published under this number; it was revised on 5 September 2026 without a new number.