Privacy Policy 

Overview 

This website (www.fraedom.com) and the services and information available through it ("Service") are provided as part of the travel technology, expense management and other services that Fraedom Holdings Limited, Fraedom UK Limited, Fraedom Pty Ltd, Fraedom Company Limited, Fraedom LLC and their related group entities (as applicable) ("Fraedom Group") are providing to your company or organisation ("Company") under a contract with that Company ("Contract")

The purpose of this privacy policy is to provide information about the way data that personally identifies the user or subject of the Service ("Personal Data") is collected and processed by us in connection with the Service.  It is not intended to set out our obligations and those of your Company in relation to Personal Data - those are addressed in the Contract.

By using this website or the Service or providing us with Personal Data, you acknowledge that we are collecting, using, disclosing and holding the Personal Data in accordance with this privacy policy. 

If you are using the Service on behalf of someone else (for example, you are authorised to make travel bookings on their behalf), you must ensure that you have that person's consent to provide us with their Personal Data and for our processing of that Personal Data as described in this privacy policy. If you are not certain whether you have such consent, then you must not input any Personal Data in this Service.

If you have any questions regarding our authority to collect and/or process Personal Data or any other terms of the Contract, please contact your manager. 

In the event of any conflict between this privacy policy and the Contract, the Contract shall prevail. 

Except where stated or the context requires otherwise, references in this privacy policy to 'you' or 'your' are to be taken to include references to the website user and, where applicable, the Company and references to 'us','we' or 'our' are to be taken as references to the Fraedom Group. 

What Personal Data Do We Collect Or Receive? 

In order to provide the Service and other services required by your Company, we may require various Personal Data from time to time. This Personal Data may include: 

• your name, title, gender and date of birth; 
• your company name and employee ID number; 
• your contact information, including your telephone number and email address;
• your credit card details; 
• your passport details; and 
• your travel itinerary and special travel requirements.

It could also include sensitive data, such as data relating to your health (e.g. if you request wheelchair access), religion or racial or ethnic origin (e.g. if you have special dietary requirements). To the extent required by any applicable law only, where your consent has not already been obtained in accordance with the Contract or by or on behalf of your Company, if you provide any sensitive data to us, you consent to such sensitive data being processed by us in accordance with this privacy policy.

Through our use of cookies, we may collect traffic data or receive information about your use of this website, although the cookies we use do not collect information that identifies individual users. 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 Service and we may be unable to provide the information or services that you have requested.

How Do We Collect or Receive Personal Data? 

We may collect or receive Personal Data directly from your Company or its nominee(s), from you, your administrator, your travel booker (where applicable) or through data submitted to the website or through our use of cookies on the website.  We may also collect Personal Data over the telephone, email or internet or when you contact us through the website, whether using the ‘Get in touch’ facility or otherwise.    

What We Do With Personal Data 

We (and those acting on our behalf) may collect, store, use, process and transfer Personal Data across international borders in accordance with this privacy policy in and/or to countries around the world (Countries). The main Countries in which we may use and to which we may disclose the Personal Data include the United Kingdom and other European Economic Area (EEA) countries, Australia, New Zealand, the United States of America, Canada, Japan, Hong Kong and Singapore. Not all Countries necessarily offer the same level of protection over your Personal Data.

We (and those acting on our behalf) may collect, store, use and process Personal Data both inside and outside the Countries:

• in accordance with your Company's written instructions; 
• as required to provide the Service and/or fulfil our obligations under the Contract; 
• in accordance with any terms set out at the point at which Personal Data is collected; and 
• as necessary to comply with legal, regulatory, immigration or customs requirements.

This may include:

• the creation, storage and administration of your traveller and expense administration profiles; 
• the transfer and disclosure of Personal Data to travel service providers which the Company requires or requests us to provide as part of our provision of services under the Contract;
• the transfer and disclosure of Personal Data to service providers, in and to the Countries, that are relevant to the provision of the Service to you (for example, the provision of IT infrastructure for the logging and management of support queries and for the purpose of optical character recognition associated with the technology we use); 
• responding to you or your Company's requests for information concerning your expense transactions or to respond to questions you or your Company might have;
• the transfer, disclosure and storage of Personal Data of your Company's registered administrators to enable us to contact them about the Services we provide to you (for example, to keep them informed about future releases of our technology, the status of support queries that have been logged, advising of upcoming maintenance windows and other issues that may affect the Service); 
• addressing questions relating to our services from you or your Company and pursuant to the Contract; 
• the transfer and disclosure of Personal Data to the Fraedom Group in any of the Countries; 
• the provision to your Company of management information, data aggregation (including aggregation using data provided to us by third parties at your Company's request), quality assurance surveys and any other services required from time to time by your Company; 
• the transfer and disclosure of Personal Data to your Company as required by your Company from time to time, including as part of its management information, expense management and travel monitoring requirements; 
• the transfer of data to third parties at your Company's request; 
• responding to an audit of the Service under the Contract by your Company;
• the detection and prevention of fraud in connection with the Service;
• improving your experience of the website and the Service that we provide to you based on information we collect or receive from our use of cookies (please see the section headed 'Cookies' below for further details); and 
• the transfer and disclosure of data in and to the Countries to assignees, sub-contractors and advisers of the Fraedom Group from time to time and any successor business that assumes any of Fraedom Group's obligations under the Contract. 

If applicable, you authorise us (and those acting on our behalf) to use and disclose sensitive data or protected health information for the purpose of the Health Insurance Portability and Accountability Act (1966) USA.

In the event of any conflict between any terms set out at the point at which Personal Data is collected and this privacy policy, the terms at the point of collection shall prevail. 

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 but also through certain third party products we use including Google Analytics, Fraedom Session Cookie and Fraedom Language preferences cookie. These third party cookies allow us to improve your experience of this website and to improve the Service we provide through this site. The cookies that we use on this website do not collect information that identifies individual users.

Further information about the use of cookies on this site is set out in the site's Cookie Policy which can be accessed here. 

Additional information about the use of Google Analytics can be found at www.google.com/policies/privacy/partners.

Location Based Services 

Certain Services require details of your location (for example, in order to provide you with local weather information). Depending on your browser and mobile device settings, we may receive this information automatically or following a request which you accept. We may share this data with certain third parties in order to provide these location based services. If you elect to disable location based services, you may not be able to use some or all of the features of the relevant Service. 

Accessing the Website using our App 

If you are a user of the Service pursuant to a Contract you may use our app to access the website and the Service. By registering a mobile device in order to access the website and the Service via our app, you consent to the collection of information about your device's Operating System (OS) version, manufacturer, model, and carrier. This information is used for the duration of your session and is not stored by us. 

Accuracy 

Please provide accurate Personal Data and update it as necessary in the manner specified below. In the absence of any update, we will assume that the Personal Data submitted is correct.

Right of Access, Deleting, Deactivating and Amending your Personal Information 

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 at the address given below. Additionally, if you wish to delete, deactivate or amend the Personal Data other than by using the functionality provided on or through the website, please contact us at the address given below. 

Security 

We recognise the need and take reasonable steps to ensure that Personal Data we have collected remains secure. While we have security measures in place as required by the Contract and at law in order to protect against the loss, misuse, alteration of and unauthorised access to Personal Data under our control, you acknowledge that there remains a risk that Personal Data transmitted over the internet and stored by computer may be intercepted or accessed by an unauthorised third party. 

Marketing 

We will not send you marketing material unless you or your Company has requested it and we will not sell your Personal Data to anyone, or otherwise disclose your Personal Data to any third party except as may be requested from time to time by your Company, as outlined in this privacy policy or as may otherwise be required or permitted by law.

Retention of Personal Data 

We are only permitted 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 a reasonable period of time and, where applicable, if you have not used the Service for some time, you may have to re-enter your Personal Data. 

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. 

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. 

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