PRIVACY POLICY

Last updated on 30th January 2023

Welcome to Freterium’s privacy policy (“Privacy Policy” or “Policy”).

Freterium, Inc. (hereafter, “Company”, “Freterium”, “we”, “us”, or “our”) together own, operate, and maintain the website https://www.freterium.com/ (“Website”), offer and provide services to clients (hereafter, “Clients”), and assist in managing these services in accordance with arrangements with such Clients (collectively, “Services”). In order to provide the Services in an efficient manner, Freterium collects certain information regarding Clients and their end users and customers.

At Freterium, we are committed to protecting your personal data and information, and respecting your privacy.

1. Background And Key Information

1. About Us:

The Services are made available and provided by Freterium. If you have any questions on this Policy, question on how we process or handle your personal data, or otherwise reach out to us with your grievances, feedback, and comments, please reach out to us at contact@freterium.com or contact our data protection officer whose details are provided below.

2. How this Policy applies:

We use Your personal data to provide and improve the Services. By using the Website, you agree to the collection and use of information in accordance with this Privacy Policy.

In certain cases, we process your personal data strictly on behalf of our Clients’ instructions. This processing occurs on the basis of a contract between us and the Client. In such a case, we will be considered the data processor of the Client. To understand how your personal data is treated by the Client on whose behalf we process your data, please review their privacy notices and policies.

In certain cases, such as when you access our Website directly and in individual capacity, we are directly responsible to you for the processing activities that we can undertake in respect of your data.

Notwithstanding our processing of data on behalf of Clients as described above, certain jurisdictions require you to consent to the processing of your data, or otherwise require you to accept these terms of this Policy. In this regard and subject to the data protection laws that apply to you, by using the Services, you agree and consent to the collection, use, storage, disclosure, and sharing of your information as described and collected by us in accordance with this Policy. Please contact us if you have questions on our practices in your country or region.

Finally, this Policy applies specifically with reference to natural persons who use our Services. For the avoidance of doubt, references to “you” across this Policy are to an end user who accesses our Services.

3. Review and Updates:

We regularly review and update our Privacy Policy, and we request you to regularly review this Policy. It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4. Third-Party Services:

The Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy statements. When you leave the Website or access third- party links through the Services, we encourage you to read the privacy policy of each such third party service provider.

2. Personal Data That We Collect

1. We collect different types of personal data about you in different ways, which we have grouped together as follows:

1. Identity Data, such as your name, username, or similar identifier.

2. Contact Data, such as your email address and telephone numbers.

3. Employment-related Data, including details of your education qualification, employment, salary, details of the companies you have worked for or are presently working with, and the industry within which you presently work.

4. Location Data, which includes the state and country you live in.

5. Demographic Data, which includes zip code, age, education details, and income level.

6. Technical Data, which includes your IP address, browser information including browser type and version, time zone setting and location, browser plug-in types and versions, web browser application details, corresponding location details, operating system and platform, and other technology on the devices you use to access the Services.

7. Usage Data, which includes information about how you use the Services.

8. Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

3. We do not knowingly collect or process personal data of children.

4. We do not collect any data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data, or any information about criminal convictions and offences.

5. What happens if I refuse to provide my personal data?
   Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How Do We Collect Personal Data

We use different methods to collect data from and about you including through:

1. Direct Interactions. You provide us your personal data when you interact with us. This includes personal data you provide when you:

1. apply for our products or services;

2. subscribe to our services, publications, or newsletters;

3. request marketing to be sent to you;

4. enter a competition, promotion, or online surveys;

5. register for demonstrations;

6. download case studies;

7. apply for job openings; or

8. give us feedback or contact us.

2. Automated technologies or interactions. As you interact with the Services, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites that employ our cookies.

3. Third parties or publicly available sources. We will receive personal data about you from various third parties:

1. Technical Data from analytics providers such as Google, SEMRush, Wordpress, advertising networks such as [Salesforce, Unbounce, Linkedin Ads, Google Ads, Twitter Ads, Outbrain, Bing Ads], and search information providers such as [Google Search Console, Bing, Gartner, G2Crowd, Zoom Info].

2. Employment-related Data from third-party consultants and websites, including but not limited to websites like LinkedIn and other job portal sites.

3. Identity Data and Contact Data from publicly available sources.

4. How Do We Use Your Personal Data?

1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to perform the contract we are about to enter into or have entered into with you or a Client (as the case may be), where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or where we need to comply with a legal obligation. We use your personal data for the following purposes:

1. To provide you with access to our newsletters, demonstrations, and case studies.

2. To manage our relationship with you which will include notifying you about changes to our Terms or this Policy, or asking you to leave a review or take a survey.

3. To enable you to partake in a prize draw or competition or complete a survey.

4. To administer and protect our business and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).

5. To deliver relevant Services content and advertisements to you and measure or understand the effectiveness of the advertising we serve you.

6. To use data analytics to improve the Services, our products and services, marketing, customer relationships, and your experiences.

7. To make suggestions and recommendations to you about goods or services that may be of interest to you, or to form a view on what we think you may want or need.

8. For recruitment purposes and employment-related opportunities.

9. To manage our third-party relationships, such as those with our vendors and partners.

10. To enforce our Terms and other legal terms and policies.

11. To comply with applicable legal requirements, such as government regulations and industry standards, contracts, and law enforcement requests.

2. Where applicable laws permit us to, we rely on your consent as a ground to process your personal data, including in situations where your data is sourced and it already comes with consent or where we are required by law to ask for your consent in the context of some of our sales and marketing activities.

3. Where applicable law does not permit us to rely on your consent to process personal data), and provided that you are not using the Services as an end user of a Client, we rely on the following legal bases for processing your personal data:

1. Legitimate interest, which means our interest in conducting and managing our business to enable us to provide you with the best services and products, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

2. Performance of a contract, which means we process your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

3. To comply with a legal obligation, which means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

4. If you are based in the EU, we generally do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you through email or text messages. You have the right to withdraw consent to marketing at any time by contacting us.

5. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

6. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

7. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures Of Your Personal Data

1. We may share your personal data with the parties set out below for the purposes set out in Section 4.

   1. Internal third parties, which are the other companies in the Freterium group.

   2. External third parties, such as:

      • Service providers who provide IT and system administration services.

      • Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

      • Regulators and other authorities.

   3. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the manner set out in this Policy.

2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Cross-Border Transfers of Personal Data

1. The personal data that we process may be transferred to countries other than where you are based. For example, we transfer your personal data to the United States and EEA, where our servers are located. Where applicable law permits such transfer, we rely on consent to transfer such data. If you are based in the EU, we rely on standard data protection clauses that are approved by the European Commission for the transfer of personal data outside the European Economic Area.

2. You can find out more information about these transfer mechanisms by contacting us.

7. Data Security

1. We have put in place appropriate security measures that include, but are not limited to, testing for OWASP mobile top 10 vulnerabilities, including root/jailbreak detection and SSL pinning in iOS and Android platforms, to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

2. In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

1. Under certain circumstances, you have rights under data protection laws in relation to your personal data.

2. Subject to the data protection laws that apply to you, you have the right to:

   1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

   2. Request confirmation as to whether or not your personal data is being processed.

   3. Request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

   4. Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

   5. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

   6. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

      • If you want us to establish the data’s accuracy.

      • Where our use of the data is unlawful but you do not want us to erase it.

      • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

      • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

   7. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, and machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

   8. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

3. If you wish to exercise any of the rights set out above, please contact us at the details provided in Section 1(a).

4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

5. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Updates To This Policy

We may occasionally update this Policy. If we make changes to this Policy, we will notify you of the changes through the Services or through other means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this Policy.

We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.

11. Roles and Responsibilities

12. Exception

Currently there are no exceptions that are established within Freterium for this Policy.

Any exception to this policy should be authorized by the Freterium Management or any person specifically designated and authorized by the Management.