Overview

At Fraedom, our mission is to provide customers with technology that can help them to succeed and grow. Respecting your privacy is central to our mission.

Personal data is any information that can be used to identify, locate, or contact you, along with other associated information (“Personal Data”). It also includes other information that may be associated with your personal data. We will only hold, process and transfer Personal Data in accordance with applicable laws, this privacy notice and any terms set out at the point(s) at which Personal Data is collected.  

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 you as a website user or you in person at one our events and references to “us” “our” 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, Fraedom LLC, and their related group entities (as applicable) ("Fraedom Group").

Please note that this privacy notice applies to the Personal Data submitted through our website (www.Fraedom.com) or in person by you when you attend one of our marketing events, for example a trade show (“Events”).

A separate privacy notice will apply to Personal Data submitted through the service when you become a customer once you have logged into your account. If you are using the service, then Fraedom customer (“Company”) making the service available to you will be the data controller and the Company is primarily responsible for the processing of Personal Data on the service.

What Personal Data Do We Collect Or Receive?

We may collect or receive certain Personal Data about your interactions with Fraedom, 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);
• Information you provide to us in person when you attend one of our Events and provide your details via an enquiry or other forms in person (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 use of our websites or apps, including information collected using Cookies and other technologies (please see our Cookie Notice).

How and on what basis do we use Personal Data

We only process Personal Data when we have a legal basis for the processing, as follows: 

• With your consent (or provided you have not objected, or opted-out, as may be appropriate under applicable law), to provide you with marketing communications, or
• To comply with the laws that are applicable to us around the world.

We may also process your Personal Data for the purposes of our own legitimate interests or for the legitimate interests of others, provided that processing does not and shall not outweigh your rights and freedoms. In particular, we will process your Personal Data as needed to:

• Understand and improve our business or customer relationships generally,
• Protect you, us or others from threats (such as security threats or fraud),
• Enable or administer our business, such as for quality control, consolidated reporting, and customer service, and
• Manage corporate transactions, such as mergers or acquisitions.

Disclosure of Personal Data to Third Parties

We may disclose your Personal Data as follows:

• with our service providers, who are bound by law or contract to protect your Personal Data and only use your Personal Data in accordance with our instructions.
• with our affiliates, which may only use your Personal Data for purposes that are compatible with this privacy notice or other applicable privacy notices
• with other partners through our partnerships or promotional programmes (for example, event partners).
• where permitted by law, such as when needed to affect the sale or transfer of business assets, to enforce our rights, including our service, to protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Data when required to do so by law, such as in response to a witness summons, including disclosure to law enforcement agencies and courts in countries where we operate.

Your Personal Data may be transferred to, stored at or processed in other countries, that are outside the European Economic Area, Switzerland and/ or the UK that may not have equivalent privacy or data protection laws.  However, regardless of where your Personal Data is transferred, we will protect it in accordance with this privacy notice and the applicable law. 

We generally use approved Standard Contractual Clauses to assure that Personal Data is adequately protected when it is transferred out of the European Economic Area, Switzerland and/ or the UK but we may also make transfers to recipients with approved binding corporate rules or to recipients in the United States who have signed up to the EU-US and/or Swiss-US Privacy Shield Framework.  You have the right to ask us for more information about the safeguards we have put in place in relation to such international transfers - please contact us using the “Get in touch” facility for further information.

Your Rights in relation to Your Personal Data

You have choices about how we use your Personal Data. You always have the right to object to marketing communications.

Fraedom also respects the rights of EEA, Switzerland and/ or UK citizens to access, correct and request the deletion or restriction of their Personal Data as required by law. Where Fraedom is a data controller, this means:

• You generally have a right to know if Fraedom is storing your Personal Data. If we are, you have the right to request that we provide you with a copy of that Personal Data, or in some cases, provide the information to another data controller. If your information is incorrect or incomplete, you have the right to ask us to update it.
• You have the right to object to our processing of your Personal Data.
• You may also ask us to delete or restrict your Personal Data. If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time.

To exercise these rights, please contact us via the website’s “Get in touch” facility or using the contact details below and a member of our Privacy Team will assist you. Please understand that we may need to verify your identity before we can process your request.

If we are processing your Personal Data as a data processor, we will refer you to the Company (such as to your employer) for assistance with these requests.  We support our clients in responding to requests as required by law.

If you believe that we have processed your Personal Data in violation of applicable law, you may also file a complaint with us, who can be reached by the “Get in touch” facility, or with a supervisory authority.

Security and Retention of Personal Data

We use physical, technical, organisational, and administrative safeguards to help protect your Personal Data from unauthorised access or loss. For example, we may use technology such as encryption to protect any sensitive Personal Data. 

We will retain your Personal Data for as long as the information is needed for the purposes listed above and for any additional period that may be required or permitted by law.

Queries and Complaints

If you have any questions about this privacy notice, wish to exercise any of your rights as described above, 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 notice.

Changes to our Privacy Notice

We may change this privacy notice from time to time without prior notice in order to keep it up to date with legal requirements. We will post the updated privacy notice 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 notice regularly.

You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site.

Contact

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

You can contact us by writing to us at:

Fraedom UK Limited:

Level 4, 
1 Sheldon Square,
London, 
W2 6TT 
United Kingdom

FAO: Legal Department

This page was last updated on 27.05.2020