Privacy Policy

Freeda, Inc. ("Freeda")
a Delaware Corporation
Website: www.freeda.io
Email: support@freeda.io  

FinCEN Registration Number: 31000177946992
Last Updated: December 1, 2020

ACCEPTANCE OF THE PRIVACY POLICY

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

ACCEPTANCE

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

·      You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
·      Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Freeda, Inc.
·      Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
·      Account means a unique account created for You to access our Service or parts of our Service.
·      Service refers to the Website and the App.
·      Country refers to: United States
·      Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
·      Personal Data is any information that relates to an identified or identifiable individual.
·      Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
·      Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
·      Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

·      First name and last name;
·      Phone number;
·      Address, State, Province, ZIP/Postal code, City;
·      Usage Data;
·      Government identification numbers (which may include Social Security Number or equivalent, driver’s license number, or passport number;
      ·   Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;
      ·   Financial Information, such as bank account information, routing number; debit/credit card information; account.            balances via plaid.com;
      ·   Correspondence, such as information that you provide to us in correspondence, including account opening and            customer support;
      ·   Sensory Information, such as images collected for identity verification, audio recordings left on answering machines;                audio recordings of support calls; audio recordings related to Over-the-counter exchange; chat history with support;            chat history related to over-the-counter exchange;
      ·   Employment Information, such as job title, source of wealth; and
      ·   Institutional Information, such as for institutional customers, we may collect additional information, including: institution’s            legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government,            and proof of legal existence (which may include articles of incorporation, certificate of formation, business license, trust            instrument, or other comparable legal document).
·      Date of Birth

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

We may also collect:

·      Online Identifiers, such as IP address; domain name;
·      Device Information, such as hardware, operating system;
·      Usage Data, such as system activity, internal and external information related to Freeda pages that you visit, clickstream     information; and
·      Geolocation Data.

Personal Information we collect from third parties

We may collect and/or verify the following categories of Personal Information about you from Third Parties:

·      Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);
·      Financial Information, such as bank account information, routing number; account balances;
·      Transaction Information, such as public blockchain data (bitcoin, ether, and other).

Additional Information, at the discretion of our Compliance Team to comply with legal obligations, which may include criminal records or alleged criminal activity.

Tracking Technologies and Cookies

We use Cookies to help us recognize you as a customer, collect information about your use of Freeda to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure compliance with our Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”)program (“BSA/AML Program”) (ii) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (iii) assess and improve our services and advertising campaigns.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

Use of Your Personal Data

The Company may use Personal Data pursuant to the terms of our User Agreement for the following purposes:

·      To provide and maintain our Service, including monitoring the usage of our Service.
·      To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
·      For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
·      To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
·      To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
·      To manage Your requests: To attend and manage Your requests to Us.

Other uses for your data include:

·     Compliance with legal and regulatory requirements;
·     To detect and prevent fraud;
·     To provide customer support;
·     To optimize and enhance our services – to understand how our products and services are being used, so we can improve them when developing new products; and
·     Any other legitimate business purposes.

We may share your personal information in the following situations:

·      With Service Providers: Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring.
·      For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
·      With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
·      With Professional Advisors: We may share Your information with our professional advisors to offer You certain products, services or promotions.
·      With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

·      Comply with a legal obligation;
·      Protect and defend the rights or property of the Company;
·      Prevent or investigate possible wrongdoing in connection with the Service;
·      Protect the personal safety of Users of the Service or the public;
·      Protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. We work hard to protect Freeda and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the Freeda website communications with SSL; required two-factor authentication for sessions depending on the Services we provide; PIN codes; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

How You Can Access or Change Your Personal Data

Company understands that you may want to change, access or delete your Personal Data. You may do so by contacting us via email at support@freeda.io. You may delete your account via the App or the Website. To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data. Any request to access your Personal Data will be answered in less than thirty (30) days. Persons under the age of 18 are not eligible to use any services on our Site.

For California:

We are required under the California Consumer Privacy Act of 2018 (“CCPA”) to provide certain information to California residents about how we collect, use and share their personal information, and about the rights and choices California residents may have concerning their personal information. For purposes of this section,“personal information” has the meaning provided in the CCPA.

Personal information that we collect, use, and share. This includes:

·     Identifiers such as Personal Identification Information;
·     Commercial information such as records of products or services purchased, obtained, or considered;
·     Internet or other electronic network activity information, including browsing history and search history;
·     Geolocation data that is sufficient to identify a precise physical location.

We collect Usage Data including:

·     Sensory data, such as audio, electronic, visual, or other similar information;
·     Professional or employment-related information;
·     Inferences about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
·     Photos taken from the Freeda kiosk network; and
·     Self-portraits sent to us from our clients during the onboarding process.

For European Users:

Collection and transfer of data outside the EEA

Freeda operates internationally with many of our systems based in the United States. As a result, we may transfer personal data from Europe to third countries outside of Europe, including the United States, under the following conditions:

·     Contractual Obligation. Where transfers are necessary to satisfy our obligation to you under our User Agreement, including to provide you with our services and customer support services, and to optimize and enhance Freeda; and
·     Consent: where you have consented to the transfer of your personal data to a third country.

Where transfers to a third country are based on your consent, you may withdraw your consent at any time. Please understand, however, that our services may not be available if we are unable to transfer personal data to third countries.

When we transfer personal data to third countries, we endeavor to ensure adequate safeguards are implemented, for example through the use of standard contractual clauses or Privacy Shield certification.

Automated decision-making

We may engage in automated decision-making for purposes of fraud detection and prevention.

What Are your Privacy Rights

As explained above, we collect Personal Information in various ways depending upon your use of our Site an App. We process Personal Information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreements; and (3) as necessary for our legitimate interests in providing services where those interests do not override your fundamental rights and freedom related to data privacy.

Personal Information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates, partners, or service providers maintain facilities.

You are entitled to the following rights through the GDPR. Please note, in order to verify your identity, we may require you to provide us with Personal Information prior to accessing any records containing information about you.

The Right to Access: You have the right to obtain information about our processing of personal data and a copy of your personal data that we store.

The Right to Rectify your Data. You have the right to request that we update your personal data if it is inaccurate or incomplete.

The Right to Request Data Erasure: You have the right to have your Personal Information erased from our files if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

The Right to Restrict or Object to Our Processing: You have the right to restrictor object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

The Right to Lodge a Complaint: You have the right to lodge a complaint about our data collection and processing actions with your data protection authority. Contact details for data protection authorities can be found on this website.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy.

Personal Data Management

According to the Privacy Policy, you agree to share your personal data with our Service. However, you still have the right to update, transfer or delete it from us.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us at support@freeda.io.