Privacy Policy

FOH® Worldwide Privacy Policy

At FOH® and all its subsidiaries (FOH Europe B.V.), collectively referred to as FOH® Worldwide, we value your privacy and your confidence in us to keep the information you provide, and that we collect, safe, protected, and handled transparently.

We have written this Privacy Policy in plain language and organized it by topic so it is easy to find what matters to you. Your use of our websites and platforms indicates you agree to our collection, use, and disclosure of your information as described here. If you would like to exercise any of the rights described below, you may contact us at privacy@foh.cc at any time.

01

Who we are

FOH® Worldwide, and its divisions and brands Front of the House® and room360®, is a foodservice and hospitality industry authority on tabletop and hotel lifestyle accessories. We design and manufacture commercial-grade product solutions for customers across the industry.

For purposes of the laws described in this Policy, FOH® Worldwide is the Data Controller (GDPR) or Business (CCPA/CPRA and other U.S. state laws) responsible for your Personal Data unless stated otherwise.

02

Definitions

  • Personal Data — information that identifies, relates to, describes, or could reasonably be linked with a particular person or household.
  • Sensitive Personal Data — categories that receive extra protection under applicable law, such as precise geolocation, government identifiers, financial account details, or health information.
  • Data Controller / Business — the entity that determines the purposes and means of processing Personal Data.
  • Data Processor / Service Provider — a third party that processes Personal Data on behalf of, and under the instructions of, a Data Controller or Business.
  • Sale / Share — under U.S. state laws, disclosing Personal Data to a third party for money or other valuable consideration (“sale”), or for cross-context behavioral advertising (“share”), regardless of whether money changes hands.
  • Cookies — small data files your browser places on your computer or device when you visit a website.
  • IP Address — a unique string of numbers that identifies a device using the Internet Protocol.
03

Personal Data we collect

You do not need to provide Personal Data simply to browse our websites. To access certain features, such as creating an account or placing an order, we may ask you to provide information. Depending on the purpose, we may process:

  • Your name, IP address, cookie and usage data, job title, company, business address, business phone, mobile phone, and email
  • What you viewed or did on our websites
  • Links to your public social media profile(s)
  • Your settings and preferences
  • Your order and customer history

We do not intentionally collect Sensitive Personal Data through our websites.

[CONFIRM: if any forms collect Sensitive Personal Data, such as government ID numbers for credit applications, this section should say so and describe the added protections that apply.]
04

How & why we use your Personal Data

Customer support

We may record communications across channels including email, chat, and phone calls, and store the Personal Data you share, to provide the service you request and to train our team.

GDPR basis: performance of a contract & legitimate interest in service quality

User accounts

If you register on our websites, we process your Personal Data, such as your email address and password, to create and maintain your account.

GDPR basis: performance of a contract

Marketing

To provide offers and improve marketing efficiency, we may process your Personal Data for direct marketing, including your contact details, transaction history, and product preferences, for customer segmentation and personalization. You may object to marketing processing at any time by contacting privacy@foh.cc or using the unsubscribe link in any marketing communication; we will stop processing your data for this purpose, though this means we can no longer send you offers or FOH® news.

We do not share your contact details with other Data Controllers or third parties for their own marketing purposes without your knowledge, other than authorized representatives who comply with this Policy.

GDPR basis: legitimate interest, or consent where required by law

Marketing analytics

We use third-party Data Processors to analyze campaign performance and conversion rates. We remain the Data Controller of your Personal Data in all cases; these processors may only use your data to fulfill our purposes. You may object to this processing at any time.

GDPR basis: legitimate interest in market research

Advertising

[CONFIRM WITH MARKETING: the paragraph below assumes FOH® Worldwide displays ads on third-party websites based on past engagement and customer history, which under the CCPA/CPRA and similar state laws counts as “sharing” Personal Data for cross-context behavioral advertising even if no money changes hands. If this is not accurate, this section and the Do Not Sell or Share section below should be revised accordingly.]

With your consent where required, we may send push notifications and display ads on third-party websites tailored to your past engagement and customer history with us. As a result, you may see ads about our company and products elsewhere on the internet.

Improvement and development of our websites and services

We use third-party services to record and analyze behavior on our websites, which helps us identify trends and improve our services and your experience.

GDPR basis: legitimate interest

Training and evaluation of customer support staff

Calls, emails, and chat messages with customer support may be recorded and used in training to maintain service quality.

GDPR basis: legitimate interest
05

Cookies, Global Privacy Control & similar technology

Cookies are small data files your browser places on your device when you visit our websites. They help your browser navigate our site, remember your preferences, and let us analyze how our websites perform. Cookies cannot collect information stored elsewhere on your device or in your files.

We use cookies to learn how you interact with our content, improve your experience, remember your preferences, identify and resolve errors, and analyze website performance. See our Cookie Policy for details on cookie categories and how to manage your preferences.

Global Privacy Control (GPC)

We recognize the Global Privacy Control signal, a browser or device-level signal that communicates a request to opt out of the sale or sharing of Personal Data. Where you have GPC enabled, we treat that signal as a valid opt-out request for the browser or device on which it is enabled, and we will display confirmation that the signal has been honored.

[CONFIRM: technical implementation should be verified with IT/web team.]

“Do Not Track” signals

Because there is no common industry standard for “Do Not Track” browser signals, we do not currently respond to them, other than the Global Privacy Control signal described above. You can enable or disable Do Not Track in your browser's preferences.

06

Do Not Sell or Share My Personal Information

[CONFIRM WITH MARKETING before publishing: this section should be included only if FOH® Worldwide shares Personal Data with third parties for cross-context behavioral advertising, or removed/revised if it does not.]

If we share your Personal Data with third parties for cross-context behavioral advertising, you have the right to opt out. You may do so by using the “Do Not Sell or Share My Personal Information” link on our website, or by enabling Global Privacy Control in your browser. We will display a confirmation once your opt-out request has been processed, and we will not require you to verify your identity to exercise this right. We do not sell Personal Data for money.

07

Who we share your Personal Data with

With other Data Controllers

From time to time, we share contact details with authorized representatives who comply with this Policy.

With Data Processors / Service Providers

We use third-party service providers to help us operate our business, including:

  • Web analytics providers that monitor web traffic
  • Content Management Systems (CMS) that publish and update our website content
  • Customer Relationship Management (CRM) software that manages our business contacts
  • Enterprise Resource Planning (ERP) software that manages our business transactions
  • Email software that manages our business communications
  • Recruiting software that manages candidates and future talent

These providers are contractually restricted to using your Personal Data only to provide services to us and are not permitted to use it for their own purposes.

08

International data transfers

FOH® Worldwide operates across multiple countries, including the United States and the European Union. Where we transfer Personal Data from the EEA, UK, or Switzerland to countries that have not been recognized as providing an adequate level of data protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, to protect your Personal Data.

[CONFIRM: identify the specific transfer mechanism(s) actually in use, e.g., SCCs with named processors, and reference them here.]
09

How long we retain your Personal Data

We retain your Personal Data only for as long as necessary for the purposes described in this Policy, and to the extent needed to comply with our legal, tax, and audit obligations.

[CONFIRM: where possible, state specific retention periods or the criteria used to determine them, such as “account data for the duration of the account plus 7 years for tax records.” Regulators increasingly expect concrete retention criteria rather than open-ended language.]
10

Your privacy rights under GDPR (EU/UK/EEA)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the right to:

  • Access the Personal Data we hold about you
  • Rectify inaccurate or incomplete Personal Data
  • Erase your Personal Data (“right to be forgotten”), subject to legal exceptions
  • Restrict how we process your Personal Data in certain circumstances
  • Data portability, to receive your Personal Data in a structured, machine-readable format
  • Object to processing based on legitimate interest or for direct marketing
  • Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal
  • Lodge a complaint with your local data protection supervisory authority

To exercise any of these rights, contact privacy@foh.cc. We may need to verify your identity before responding. For more information about GDPR generally, visit ec.europa.eu.

11

Your privacy rights under U.S. state privacy laws

A growing number of U.S. states — including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others — have enacted comprehensive privacy laws. While details vary by state, if you are a resident of a state with an applicable privacy law, you generally have the right to:

  • Know what Personal Data we have collected about you and how we have used and disclosed it
  • Access a copy of your Personal Data
  • Correct inaccurate Personal Data
  • Delete your Personal Data, subject to legal exceptions
  • Opt out of the sale or sharing of your Personal Data, and of targeted advertising
  • Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects
  • Not be discriminated against for exercising any of these rights
  • Appeal a denied request, and if the appeal is denied, be provided a method to contact the state Attorney General
  • Designate an authorized agent to submit requests on your behalf

To exercise these rights, contact privacy@foh.cc. We will acknowledge your request and respond within the time period required by the applicable state law, generally within 45 days, and may extend this once by an additional 45 days when reasonably necessary. We will verify your request using a risk-based approach calibrated to the sensitivity of the data involved, and we will not require more information than necessary to verify your identity. If we deny your request, we will explain why and provide instructions for submitting an appeal.

12

California-specific disclosures (CCPA/CPRA)

This section supplements the rights described above for California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”).

We collect Personal Data directly from you, such as when you complete a form or accept our Cookie Policy, and use it to operate, manage, and maintain our business; provide our products and services; develop and improve our offerings; personalize, advertise, and market our products; conduct research and analytics; perform quality, safety, and security monitoring; detect and prevent fraud; verify identity; perform accounting, audit, and internal functions; comply with law; maintain records; and exercise or defend legal claims.

We do not sell Personal Data for money. [CONFIRM: see the Advertising and Do Not Sell or Share sections above regarding whether our practices constitute “sharing” under CPRA.]

You have the right to: request details on the categories or specific pieces of Personal Data we collect and how we use it; request deletion of your Personal Data; correct inaccurate Personal Data; opt out of the sale or sharing of your Personal Data; limit the use of Sensitive Personal Data to what is necessary to provide our services; and not be discriminated against for exercising any of these rights.

You can exercise your California privacy rights by contacting privacy@foh.cc. We will verify your request and may ask for additional identifying information. You may also designate an authorized agent to act on your behalf.

13

Children's privacy

Our websites and services are not directed to children, and we do not knowingly collect Personal Data from children under the age of 13 (or the applicable age of consent in your jurisdiction). If you believe a child has provided us with Personal Data, please contact privacy@foh.cc so we can address it.

14

How we protect your Personal Data

The security of your data is important to us. No method of transmission or electronic storage is 100% secure, but we employ commercially recognized administrative, technical, and physical safeguards designed to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction.

15

Data breach notification

In the event of a security incident affecting your Personal Data, we will notify affected individuals and applicable regulators as required by law, without undue delay.

[CONFIRM: reference the specific notification timelines applicable to your operations, such as 72 hours under GDPR.]
18

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by sending a notice to the email address you provided and/or by posting a prominent notice on our website.

19

Contact us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

By email: privacy@foh.cc

By phone: 305.757.7940