What Personal Data Do We Collect Or Receive?
We may collect or receive certain Personal Data about you, including:
- Information you provide when you use the "Get in touch" facility or fill in any enquiry or other forms on the website (for example, your name, email address and telephone number);
- If you contact us, we may keep a record of that correspondence; and
Your provision of Personal Data is voluntary. However, if you elect not to provide certain Personal Data, you may be unable to use the website and we may be unable to provide the information or services that you have requested.
You must always provide accurate Personal Data and you agree to update it as necessary in the manner specified below. You also agree that, in the absence of any update, we can assume that the Personal Data you have provided is correct.
How We Use Personal Data
You hereby explicitly consent to your Personal Data being collected/received by us and processed by us as required in order to:
- contact you and provide you with information or services that you have requested and deal with any matters arising as a result of that contact; and/or
- enable a member of the Fraedom Group or the Hogg Robinson Group of companies to contact you and provide you with information or services that you have requested and deal with any matters arising as a result of that contact;
- display content specific advertisements to you when you go to certain other websites (please see the section headed "Cookies" below for further details);
- monitor your activity on the website and, in some instances, contact you about products and/or services we believe may be of interest to you based on your browsing activity; and
Disclosure of Personal Data to Third Parties
You hereby explicitly consent to your Personal Data being transferred and/or disclosed (whether inside or outside the European Economic Area) to and/or processed by:
- members of the Fraedom Group for the purposes set out in the section above headed ‘How We Use Personal Data’;
- members of the Hogg Robinson Group of companies and/or members of their partner network;
- BMC Software Asia Pacific Pte Ltd who, on our behalf, store on their servers in United States of America Personal Data that you provide to us through our "Get in touch" facility.
- Salesforce.com Singapore Pte. Ltd who, on our behalf, provide CRM technology that is hosted in the United States of America that we use to store information about our customers, prospects and accounts;
- data storage providers used in the operation of the website and/or the provision of any of the services provided through it (these providers do not have direct access to the Personal Data unless specified otherwise on the website);
- a future purchaser of some or all of our assets or, where applicable, the assets of all or part of the Fraedom Group; and
- in the unlikely event that we believe in good faith that we are required to do so: (a) by court order or other legal/regulatory requirement; or (b) in order to protect our rights/property or those of our clients and/or their employees.
Right of Access, Deleting, Deactivating and Amending Your Personal Data
Subject to the provisions of applicable law and for a small fee (where permitted by law) you may obtain copies of the Personal Data (if any) we hold about you by contacting us via the website’s "Get in touch" facility. Additionally, if you wish to delete, deactivate or amend the Personal Data, or find out what Personal Data (if any) we are holding about you, please contact us via the website’s “Get in touch” facility.
Retention of Personal Data
We are only allowed to retain your Personal Data for so long as is necessary having regard to the purpose of the processing. We may therefore delete your Personal Data after an appropriate period of time.
U.S.-E.U. and US-Swiss Safe Harbor Privacy Statement
There has been a recent European Court of Justice (ECJ) ruling that the Safe Harbor Principles are no longer valid. This recent ruling has no impact on our data security standards or the way we transfer and store personal data. There is no increased threat to any personal data we send to the US and no impact on any of our services. We are monitoring the situation closely and we may enter into standard EU model clauses with third parties located in the US to whom we export EU customer data in order to afford our customers the same level of data protection as under the Safe Harbor Principles.
We therefore continue to promise the following:
- Notice. When we collect your Personal Data, we’ll give you timely and appropriate notice describing what Personal Data we’re collecting, how we’ll use it and the types of third parties with whom we may share it.
- Choice. We’ll give you choices about the ways we use and share your Personal Data and we’ll respect the choices you make.
- Relevance. We’ll collect only as much Personal Data as we need for specific, identified purposes and we won’t use it for other purposes without obtaining your consent.
- Retention. We’ll keep your Personal Data only as long as we need it for the purposes for which we collected it or as permitted by law.
- Accuracy. We’ll take appropriate steps to make sure the Personal Data in our records is accurate.
- Access. We’ll provide ways for you to access your Personal Data, as required by law, so you can correct inaccuracies.
- Security. We’ll take appropriate physical, technical and organizational measures to protect your Personal Data from loss, misuse, unauthorized access or disclosure, alteration and destruction.
- International Transfer. If we transfer your Personal Data to another country, we’ll take appropriate measures to protect your privacy and the Personal Data we transfer.
- Enforcement. We’ll regularly review how we’re meeting these privacy promises, and we’ll provide an independent way to resolve complaints about our privacy practices. For complaints that cannot be resolved internally, Fraedom LLC has agreed to cooperate with independent dispute resolution services provided by the Data Protection Authorities in the EEA.
You can contact us by writing to us at:
Fraedom Holdings Limited:
FAO: Legal Counsel