Overview

We are firmly committed to protecting and respecting your privacy.  We will only hold, process and transfer the data that we collect about you and which personally identifies you (“Personal Data”) in accordance with applicable laws, this privacy policy and any terms set out at the point(s) at which Personal Data is collected (“Collection Terms”).  If there is any inconsistency between the Collection Terms and this privacy policy, the Collection Terms will prevail.

Except where stated or the context requires otherwise, references in this privacy policy to "you", "your" or "yours" are to be taken as references to the website user and, where applicable, the user’s company, and references to “us” or “we” are to be taken as references to the Fraedom group of companies comprising Fraedom Holdings Limited, Fraedom UK Limited, Fraedom Pty Ltd, Fraedom Company Limited, Fraedom LLC,  Fraedom Japan K.K. and their related group entities (as applicable)  ("Fraedom Group").

Please note that this privacy policy applies to the Personal Data submitted through this website (www.Fraedom.com) only.  A separate privacy policy will apply to Personal Data submitted through the service once you have logged into your account.

By providing us with Personal Data through the website, you agree to the terms and conditions of this privacy policy and consent to us collecting, using, disclosing and holding the Personal Data in accordance with this privacy policy.  If you do not agree to this privacy policy, please do not proceed to use or access the website further.

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
• Information about your computer, including where available your IP address, operating system and browser type through our use of cookies (please see the section headed "Cookies" below for further details).

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;
• create a profile about you to which we may add information collected about you through our use of cookies (please see the section headed "Cookies" below for further details); and
• allow you to participate in interactive features of our website or services, when you choose to do so

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;
• Pardot, LLC (a wholly owned subsidiary of Salesforce.com, Inc), who, on our behalf, process through their servers in the USA the personal data that you provide when you enter your details on our website in order to download a brochure or other marketing material, access certain interactive features of our websites or through our "Get in touch" facility or which we collect through our use of cookies (please see the section headed "Cookies" below for further details);
• 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.
• 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.

General

Cookies

We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. We do this by setting our own cookies ('first-party cookies') but also through certain third party products we use including Google AnalyticsTM, Google AdwordsTM and Google DoubleClickTM. These third party cookies allow us to show you tailored ads for our services when you browse on certain other sites that have the Google Display Network implemented.  When showing you tailored ads through our use of these, we will not associate a cookie or anonymous identifier with sensitive categories, such as those based on race, religion, sexual orientation or health.  We may however combine the information gathered by these cookies with other personally identifiable information on our own database or from another Google service. For more information on Google AnalyticsTM, Google AdwordTM and Google DoubleClickTM, including how to manage the Google ads that you see, please see the Google Privacy Policy here.

Further Information about the use of cookies on this website is set out here.

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.

Changes to our Privacy Policy

We may change this privacy policy from time to time without prior notice and will post the updated privacy policy on the website so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.

Please ensure that you read this privacy policy regularly. Your continued use of the website and/or your subsequent or further provision of Personal Data to us following any changes will constitute acceptance of and consent to the revised terms of the privacy policy.

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:

1. 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.
2. We’ll give you choices about the ways we use and share your Personal Data and we’ll respect the choices you make.
3. 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.
4. 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.
5. We’ll take appropriate steps to make sure the Personal Data in our records is accurate.
6. We’ll provide ways for you to access your Personal Data, as required by law, so you can correct inaccuracies.
7. We’ll take appropriate physical, technical and organizational measures to protect your Personal Data from loss, misuse, unauthorized access or disclosure, alteration and destruction.
8. Except as described in this privacy policy, we won’t share your Personal Data with third parties without your consent.
9. 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.
10. 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.

Dispute Resolution

If you have any questions about this privacy policy or wish to file a complaint regarding this privacy policy, you can contact us by writing to the address detailed under the "Contact" heading below.

We will investigate and attempt to resolve complaints and disputes regarding the collection, use and disclosure of Personal Data by referencing the privacy principles stated in this privacy policy.

Contact

Questions and comments regarding this privacy policy should be submitted to us using the website’s “Get in touch” facility. 

You can contact us by writing to us at:

Fraedom Holdings Limited:

Global House
Victoria Street
Basingstoke
Hampshire
RG21 3BT
UK

FAO: Legal Counsel