Fraggle Privacy Policy

Fraggle Limited ("we", "our", "us" or "Fraggle") is committed to protecting the privacy of all users of our website fraggle.gi, or mobile applications (together, the "Sites"). Please read the following privacy policy that explains how we use and protect your information. We'll be the "data controller" of the information you provide to us.

1. Contact Details

If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch with us using the following details.

  • By contacting our customer services team at:

2. How We Collect Your Information

We collect your personal information when you interact with us or use our services, such as when you use our Sites to buy or sell Items. We also look at how visitors use our Sites to help us improve our services and optimise customer experience.

We collect information:

  • when you create an account with us or change your account settings;
  • when you list an Item for sale or place an order through the platform;
  • when you contact us directly via email, phone, post, message or via our chat function; and
  • when you communicate with other users through our messaging features.

3. Information We Collect From You

As part of our commitment to the privacy of our customers and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you.

When you visit the Sites or use Fraggle, you are asked to provide information about yourself including your name, contact details, payment information and, where applicable, bank account details for receiving payouts via Stripe Connect.

We also collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via e-mail, letter, phone or chat function.

We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.

We also collect technical information about your use of our services through a mobile device, including device identifiers used for push notifications. Unless you have elected to remain anonymous through your device and/or platform settings, this information may be collected and used by us automatically if you use the service through your mobile device via any Fraggle mobile application.

4. Use Of Your Information

We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.

Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information:

  • to enable us to provide you with access to the relevant parts of the Sites;
  • to facilitate transactions between Buyers and Sellers;
  • to enable us to collect payment from you and facilitate payouts to Sellers;
  • to verify identity and prevent fraud; and
  • to contact you where necessary concerning our services, such as to resolve issues you may have with an order or listing.

We also process your data where we have a justifiable reason for doing so, for example:

  • to improve the effectiveness and quality of service that our users can expect from us in the future;
  • to tailor content displayed to you, for example showing you listings relevant to your location or browsing history;
  • to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible;
  • to contact you for your views and feedback on our services and to notify you of any important changes or developments to the Sites or our services;
  • to analyse your activity on the Sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us prevent fraud;
  • to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of Fraggle, Sellers, Buyers or others (including to prevent fraud); and
  • if you submit comments and feedback regarding the Sites and the services, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will only identify you for this purpose by your first name.

We will also analyse data about your use of our services to create profiles relating to you. This means that we may make certain assumptions about what you may be interested in and use this, for example, to send you more tailored marketing communications or to let you know about special offers or products which we think you may be interested in. This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see the 'Your Rights' section below for more information.

Where we rely on legitimate interest as a basis for processing your personal information, we carry out a 'balancing test' to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. You can find out more information about these balancing tests by contacting us using the details above.

Where we are under a legal obligation to do so we may use your information to:

  • create a record of your transactions;
  • comply with any legal obligation or regulatory requirement to which we are subject.

5. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some Fraggle services may not work correctly. For more information about the cookies we use, please see our Cookie Policy.

6. Direct Marketing

Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know about our other products and services that may be of interest to you and we may contact you to do so by email or push notification. You can control your marketing preferences by:

  • visiting our website, www.fraggle.gi or mobile application;
  • clicking on "Account"; and
  • navigating to "Marketing Preferences".

7. Retention Of Your Information

We will not retain your information for any longer than we think is necessary.

Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the 'Use of your information' section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.

When determining the relevant retention periods, we will take into account factors including:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • statute of limitations under applicable law(s);
  • our legitimate interests where we have carried out balancing tests;
  • (potential) disputes; and
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information where we no longer require it for the purposes collected.

8. Disclosure Of Your Information

The information we collect about you will be transferred to and stored on our servers. We are very careful and transparent about who else your information is shared with.

Sharing your information with third parties:

We share your information with third party service providers. The types of third party service providers with whom we share your information include:

  • Payment providers (including Stripe): for the purposes of processing card payments, facilitating payouts to Sellers via Stripe Connect, and carrying out fraud checks;
  • IT service providers (including cloud providers): for the purposes of data storage and analysis;
  • Push notification providers (including OneSignal): for the purposes of delivering app notifications to your device;
  • Customer support partners: who will help us to resolve any issues you may have with our services; and
  • Marketing and advertising partners: so that they can ensure that you see advertising which is more relevant to you and send you email marketing on our behalf.

Fraggle will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy when it is transferred to third parties.

If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

We may also share your information:

  • if we are under a duty to disclose or share your information in order to comply with any legal obligation or regulatory requirement. This includes exchanging information with other organisations for the purposes of fraud protection and prevention;
  • in order to enforce our contractual terms with you and any other agreement;
  • to protect the rights of Fraggle, Sellers, Buyers or others, including to prevent fraud; and
  • with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police.

International transfers of data:

In some cases the personal data we collect from you might be processed outside the European Economic Area ("EEA"). These countries may not have the same protections for your personal data as the EEA. However, we are obliged to ensure that the personal data that is processed by us and our suppliers outside of the EEA is protected in the same ways as it would be if it was processed within the EEA. We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  2. we use the EU approved Standard Contractual Clauses; and
  3. where your personal data is transferred to third party providers based in the US, data may be transferred to them if they have self-certified under the Privacy Shield framework in relation to the type of data being transferred, which requires them to provide similar protection to personal data shared between the EU and the US.

Please contact us using the contact details above if you want further information on the countries to which personal data may be transferred and the specific mechanism used by us when transferring your personal data out of the EEA.

9. Security

We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.

We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

10. Your Rights

Under data protection law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact us using the contact details set out above.

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we're providing you with the information in this policy.

The right of access. You have the right to obtain access to your information (if we're processing it). This will enable you, for example, to check that we're using your information in accordance with data protection law. Please get in touch using the contact details above.

The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us.

The right to erasure. This is also known as 'the right to be forgotten' and enables you to request the deletion or removal of certain information that we hold about you.

The right to restrict processing. You have rights to 'block' or 'suppress' further use of your information. When processing is restricted, we can still store your information, but will not use it further.

The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch.

The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority.

The right to withdraw consent. If you have given your consent to anything we do with your information, you have the right to withdraw that consent at any time by contacting us. Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.

The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by changing your marketing preferences or disabling cookies as set out in sections 6 and 5 above.

11. Changes To Our Privacy Policy

Any changes to our privacy policy will be posted to the Sites and, where appropriate, we will notify you of the changes for example by email or push notification.

This privacy policy was last updated: 13th May 2026