Privacy Notice FreeX Solutions Ltd.

Last Updated: September 2024

Operator

FreeX Solutions and companies licensed by FreeX Solutions to operate in various jurisdictions are the operator and are responsible for Personal Data.

Contact information

E-mail address of the Operator: [email protected]

Changes to the privacy notice

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes.

If your details change and you do not tell us, we reserve the right to block our mobile app for you completely and stop providing our services.

Third-party links

This website may contain links to third party websites, plug-ins and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of each website you visit.

Data we collect about you

Personal data or personal information means any information about an individual from which that individual can be identified.

We may collect, use, store and transfer different types of personal data about you, which we have grouped as follows:

Identification data

includes first name, maiden name, last name, username or similar identifier, marital status, date of birth, and gender.

Contact information includes billing address, shipping address, email address, and phone numbers.

Financial data includes bank account and payment card details.

Transaction Data includes data about payments to and from you and other information about the products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, login, browser type and version, time zone and location setting, browser plugin types and versions, operating system and platform, and other technologies on the devices you use to access this website/mobile application.

Profile data includes your username and password, purchases or orders you have made, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences for receiving marketing from us and our third parties and your communication preferences.

Cryptographic Data includes your crypto wallet address.

We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data under the law because this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a particular website feature. However, if we combine or combine the aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data to be used in accordance with this privacy policy.

We do not collect special categories of personal data about you (this includes information about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data). We also do not collect any information about criminal records or offenses.

If you do not provide personal data

If we need to collect personal data by law or under the terms of a contract and you do not provide that data, we may not be able to fulfill the contract (for example, to provide you with goods or services). In this case, we may cancel the product or service.

How personal data is collected

We use a variety of methods to collect data from and about you, including through:

• Direct interaction. You may provide us with your (Personal, Contact and Financial Data) by filling in forms or correspondence by post, telephone, email or otherwise. This includes the Personal Data you provide when you:
  • leave an application for our products or services;
  • create an account on our website;
  • download our mobile application;
  • subscribe to our services or publications;
  • leave a marketing request to be sent to you;
  • participate in a contest, promotion or survey; or
  • leave feedback.
• Automated technologies or interactions. When you interact with our website/mobile app, we may automatically collect technical data about your equipment, actions and browsing patterns. We collect this personal data using cookies and other similar technologies. We may also collect technical data about you if you visit other websites that use our cookies. Please see our cookie policy for more information.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
  • Technical data from the following parties:
    • (a) analytics service providers
    • (b) advertising networks
    • (c) search information providers
  • Contact, financial and operational data from providers of technical, payment and delivery services.
  • Identity and contact data from publicly available sources.

How we use personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• When we need to fulfill a contract we are about to enter into or have entered into with you.
• When it is necessary for our legitimate interests (or the interests of a third party).
• When we need to comply with a legal or regulatory obligation.

We do not generally rely on consent as a legal basis for processing personal data other than in relation to sending you direct third party marketing communications by email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

The purposes for which we will use your personal data

Below is a description of all the ways in which we plan to use your personal data and the legal basis on which we rely to do so. We have also identified what our legitimate interests are where relevant.

Please note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we use your data. Please contact us if you require details of the specific legal bases we rely on to process your personal data.

Purpose/activity

Data type Legitimate grounds for processing, including grounds of legitimate interest

Register you as a new customer

• (a) Identification
• (b) Contract

Performance of the contract

• (a) Identification
• (b) Contract

To process and deliver an order, including:

• (a) Management of payments, fees
• (b) Collection and collection of money owed to us
• (c) Transaction
• (d) Marketing and communication
• (e) Performance of a contract with you
• (f) Necessity for our legitimate interests (to collect debts owed to us)

Managing our relationship with you, which will include:

• (a) managing notices of changes to our terms or privacy policy
• (b) a request for feedback or participation in a survey
• (c) Profile
• (d) Marketing and communication
• (e) The need to comply with the obligation
• (f) Necessary for our legitimate interests (to update our records and to study how customers use our products/services)

Administering and protecting our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting)

• (a) Identification
• (b) Contract
• (c) Necessary for our legitimate interests (to operate our business, provide administrative and IT services, network security, for fraud prevention and in the context of a business reorganisation or group restructuring)
• (d) The need to comply with the obligation

To provide relevant site content and advertising, and to measure or understand the effectiveness of the advertising we provide

• (a) Identification
• (b) Contract
• (c) Profile
• (d) Use
• (e) Marketing and Communication
• (f) Technical data

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to develop our business and to inform our marketing strategy)

Use data analytics to improve our website, products/services, marketing, customer relationships and experience

• (a) Technical data
• (b) Usage

Necessary for our legitimate interests (to identify customer types for our products and services, to keep our website up to date and relevant, to develop our business and to inform our marketing strategy)

Make suggestions and recommendations about products or services that may be of interest to you

• (a) Identification
• (b) Contract
• (c) Use
• (d) Profile

Necessary for our legitimate interests (to develop our products/services and to develop our business)

Marketing

We are committed to giving you choices about how we use some personal data, especially in the areas of marketing and advertising.

Promotional offers from us

We may use your personal, contact, technical, user and profile data to form an idea of what we think you may need or be interested in. This is how we decide what products, services and offers may be relevant to you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or if you have provided us with your details when you entered a competition or registered for a promotion, and in each case, you have not opted out of receiving this marketing.

Third party marketing

We do not obtain your express consent to register before we share your personal data with any non-group company for marketing purposes.

Unsubscribe

You can ask us or third parties to stop sending you marketing communications at any time by contacting us by email at any time.

If you opt out of receiving these marketing communications, this does not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookie

By downloading and accepting the cookie policy on the website, you agree to our cookie policy. If you disable or refuse cookies, please note that some parts of this website may become unavailable or not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably believe that we should use it for a different reason and that reason is compatible with the original purpose. If you would like an explanation of how processing for a new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for a different purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent in accordance with the above policies where required or permitted by law.

Disclosure of your personal data

For the purposes set out in the table in the paragraph above, we may need to share your personal data with the parties listed below.

• Internal third parties
• External third parties
• Specific third parties
• Third parties to whom we may sell, transfer or merge parts of our business or our assets. Alternatively, we may attempt to acquire or merge with other businesses. If there are changes to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and process 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 allow them to process your personal data for specific purposes and in accordance with our instructions.

Data Security

We have put in place appropriate security measures to prevent accidental loss, use or unauthorized access, alteration or disclosure of your personal data. In addition, we restrict 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 bound by confidentiality.

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

Data Retention

We retain your personal data only for as long as is necessary to fulfill the purposes for which we collected it, including to comply with any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount of personal data, the nature of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

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

Your legal rights

In certain circumstances you have rights under data protection laws in relation to your personal data:

• Request access to your personal data.
• Request rectification of your personal data.
• Request the erasure of your personal data.
• Object to the processing of your personal data.
• Request restriction of the processing of your personal data.
• Request the transfer of your personal data.
• The right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Otherwise, we may refuse to honor your request.

We may need to request specific information from you so that we can confirm your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measure designed to prevent personal data from being disclosed to unauthorized persons. We may also contact you for additional information in connection with your request to expedite our response.

We try to respond to all requests within one month. Sometimes it may take longer than one 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 informed.

Terms used

Legitimate interest means the interest of our business in enabling us to give you the best service/product and the best and most secure experience. We ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are prejudiced by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests in relation to any potential impact on you in relation to a particular activity.

Contract performance means processing your data where this is necessary for the performance of a contract to which you are a party or to take action at your request before entering into such a contract.

Compliance with legal or regulatory obligations means processing your personal data where this is necessary to comply with legal or regulatory obligations that we are required to comply with.

Third parties

Internal Third Parties

Other FreeX Solutions group companies acting as joint controllers or data processors, providing IT and system administration services, and providing management reporting.

External third parties

Service providers who provide IT and systems management services.

Banks, professional advisors, lawyers, auditors, insurance and accounting companies.

Cryptocurrency exchanges that provide cryptocurrency exchange services.

You have the right to:

• Request access to your personal data (commonly referred to as a 'data subject access request'). This allows you to obtain a copy of the personal data we hold about you and to check that we are processing it lawfully.
• Requesting the correction of personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although we may need to check the accuracy of new data you provide to us.
• Request to delete personal data. This allows you to ask us to delete or remove personal data where we have no compelling reason to continue processing. 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, where we have unlawfully processed your information or where we are required to delete your personal data under local law. Please note, however, that we may not always be able to comply with your deletion request for specific legal reasons, which will be communicated to you, if applicable, at the time of your request.
• Object to the processing of your personal data where we rely on legitimate interests (or those of a third party) or if there is something about your particular situation that causes you to object to processing on that basis because you feel it affects your fundamental rights and freedoms. You also have the right to object where we process your personal data for direct marketing purposes. In some cases we may be able to demonstrate that we have a valid lawful basis for processing your information.
• Request to restrict the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following cases: (a) if you want us to establish the accuracy of the data; (b) if our use of the data is unlawful but you do not want us to delete it; (c) if you want us to retain the data even if we no longer need it because you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to check whether we have more compelling legitimate grounds for using it.
• Request transfer of your personal data to you or a third party. We will provide you or a third party of your choice with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you originally consented to use or where we have used that information to fulfill a contract with you.
• Withdrawing consent at any time where we rely 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 you with certain products or services.