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 you as a website user or you in person at one our events and, where applicable, the user’s company, 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 Limited, Fraedom LLC, and their related group entities (as applicable) ("Fraedom Group").

Please note that this privacy policy 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 policy will apply to Personal Data submitted through the service when you become a customer once you have logged into your account. The Fraedom entity responsible for your Personal Data will be the member of the Fraedom Group that originally collects information from or about you. You can find out more about the Fraedom Group by contacting us using the "Contact" section below.

Fraedom processes Personal Data as set out in this privacy policy, if you do not wish your Personal Data to processed as set out below please do not proceed to use or access the website further.

Changes to our Privacy Policy

We may change this privacy policy from time to time without prior notice in order to keep it up to date with legal requirements. We 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.

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

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);
• 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 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 not a legal requirement.  However, if you elect not to provide certain Personal Data, you may be unable to use the website and we may not be able to contact you and/or 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 and on what basis do we use Personal Data

We will use the Personal Data we hold about you in order to:

Disclosure of Personal Data to Third Parties

We share your information with the Third Parties below and for the purposes described below:

• members of the Fraedom Group for the purposes set out in the section above headed ‘How We Use Personal Data’;
• Third party companies that assist us with the organisation and running of our Events such as Source Media LLC;
• 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 provide consent for us to send you direct marketing by entering your details on our website or by giving us your details in person at one of our Events or via other marketing material, so as to 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.

Where we transfer your Personal Data to third parties (whether they be members of the Fraedom Group or any other third party) in locations of the European Economic Area (EEA), we will only do so where:

• the third party is located in another country which is recognised as providing for an adequate level of protection of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights; and/or
• such transfers are protected by appropriate contractual commitments, where appropriate. 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.

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 Analytics^TM, Google Adwords^TM and Google DoubleClick^TM. 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 Analytics^TM, Google Adword^TM and Google DoubleClick^TM, 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.

Your Rights in relation to Your Personal Data

Depending on the lawful basis for which we use your Personal Data (as described above), you have various rights in relation to your information and the way in which we use it. Those rights may include the following: -

Data portability - where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that Personal Data is processed by automatic means, you have the right to receive all such personal information which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

Right to restriction of processing - you have the right to restrict our processing of your Personal Data where: (i) you contest the accuracy of the Personal Data until we have taken sufficient steps to correct or verify its accuracy;(ii) where the processing is unlawful but you do not want us to erase the data;(iii) where we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or (iv) where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have compelling legitimate grounds to continue processing. Where Personal Data is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.

Right to withdraw consent - where you have provided us with your consent to process Personal Data, you have the right to withdraw such consent at any time. In the case of any email marketing communications, you can do this by following the unsubscribe link in the email.  

Right to object to processing justified on legitimate interest grounds - where we are relying upon legitimate interest to process Personal Data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your Personal Data infringes applicable law.

In order to exercise your rights described above, please contact us via the website’s “Get in touch” facility or using the contact details below.

Retention of Personal Data

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Queries and Complaints

If you have any questions about this privacy policy, 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 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

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

FAO: Legal Department

This page was last updated on 09.01.2020